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13 results for “transfer pricing”+ Section 6(2)clear

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Key Topics

Section 143(3)28Section 2(15)12Section 271C9Section 270A8Section 118Section 194I7Survey u/s 133A7Section 2635Capital Gains5

M/S. VARANASI DEVELOPMENT AUTHORITY,VARANASI vs. ASSISTANT COMMISSIONER OF INCOME TAX , VARANASI

In the result appeal filed by assessee in ITA no

ITA 264/ALLD/2017[2011-12]Status: DisposedITAT Varanasi06 Jul 2022AY 2011-12

Bench: Shri Vijay Pal Rao & Shri Ramit Kochar

For Appellant: ShriAshishBansal, AdvocateFor Respondent: ShriSunil Bajpai, CIT- D.R
Section 11Section 12Section 12ASection 143(3)Section 2(15)

Section 60 to 63 of the 1961 Act deals with revocable transfer of assets, and for creation of valid trust, transfer of the assets for charitable purposes should be irrevocable, which as per AO is not fulfilled in the case of the assessee. The AO observed that the assessee is neither in the field of education , nor in the field

Long Term Capital Gains5
Penny Stock5
Revision u/s 2635

VARANASI DEVELOPMENT AUTHORITY,VARANASEE vs. ASSISTANT COMMISSIONER OF INCOME TAX (EXEMPTION), LUCKNOW

In the result appeal filed by assessee in ITA no

ITA 267/ALLD/2017[2014-15]Status: DisposedITAT Varanasi06 Jul 2022AY 2014-15

Bench: Shri Vijay Pal Rao & Shri Ramit Kochar

For Appellant: ShriAshishBansal, AdvocateFor Respondent: ShriSunil Bajpai, CIT- D.R
Section 11Section 12Section 12ASection 143(3)Section 2(15)

Section 60 to 63 of the 1961 Act deals with revocable transfer of assets, and for creation of valid trust, transfer of the assets for charitable purposes should be irrevocable, which as per AO is not fulfilled in the case of the assessee. The AO observed that the assessee is neither in the field of education , nor in the field

VARANASI DEVELOPMENT AUTHORITY,VARANASEE vs. ASSISTANT COMMISSIONER OF INCOME TAX (EXEMPTION), LUCKNOW

In the result appeal filed by assessee in ITA no

ITA 266/ALLD/2017[2013-14]Status: DisposedITAT Varanasi06 Jul 2022AY 2013-14

Bench: Shri Vijay Pal Rao & Shri Ramit Kochar

For Appellant: ShriAshishBansal, AdvocateFor Respondent: ShriSunil Bajpai, CIT- D.R
Section 11Section 12Section 12ASection 143(3)Section 2(15)

Section 60 to 63 of the 1961 Act deals with revocable transfer of assets, and for creation of valid trust, transfer of the assets for charitable purposes should be irrevocable, which as per AO is not fulfilled in the case of the assessee. The AO observed that the assessee is neither in the field of education , nor in the field

M/S. VARANASI DEVELOPMENT AUTHORITY,VARANASI vs. DEPUTY COMMISSIONER OF INCOME TAX (EXEMPTION), VARANASI

In the result appeal filed by assessee in ITA no

ITA 265/ALLD/2017[2012-13]Status: DisposedITAT Varanasi06 Jul 2022AY 2012-13

Bench: Shri Vijay Pal Rao & Shri Ramit Kochar

For Appellant: ShriAshishBansal, AdvocateFor Respondent: ShriSunil Bajpai, CIT- D.R
Section 11Section 12Section 12ASection 143(3)Section 2(15)

Section 60 to 63 of the 1961 Act deals with revocable transfer of assets, and for creation of valid trust, transfer of the assets for charitable purposes should be irrevocable, which as per AO is not fulfilled in the case of the assessee. The AO observed that the assessee is neither in the field of education , nor in the field

KAHM PROPERTIES PVT. LTD.,VARANASI vs. DC/ACIT, CENTRAL CIRCLE, VARANASI

In the result, the appeal of the assessee is allowed

ITA 63/VNS/2023[2018-2019]Status: DisposedITAT Varanasi26 Sept 2023AY 2018-2019

Bench: Shri. B. R. Baskaran & Shri Amit Shuklaassessment Year:2018-19 M/S Kahm Properties Pvt. Ltd. V. The Dc/Acit B-21/192, Kamaccha Central Circle Varanasai Varanasi Tan/Pan:Aacck7739F (Appellant) (Respondent) Appellant By: Shri V. K. Jindal Respondent By: Shri A. K. Singh, D.R. Date Of Hearing: 26 09 2023 Date Of Pronouncement: 29 09 2023

For Appellant: Shri V. K. JindalFor Respondent: Shri A. K. Singh, D.R
Section 133ASection 139(1)Section 143(2)Section 270ASection 270A(9)

Transfer Pricing Officer, where the assessee had maintained information and documents as prescribed under section 92D, declared the international transaction under Chapter X, and, disclosed all the material facts relating to the transaction; and :-8-: (e) the amount of undisclosed income referred to in section 271AAB. (7) The penalty referred to in sub-section (1) shall be a sum equal

INDRA NARAYAN TRIPATHI,GORAKHPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, RANGE - 02,, GORAKHPUR

In the result, appeal filed by the assessee in ITA

ITA 5/VNS/2020[2014-2015]Status: DisposedITAT Varanasi04 Jul 2022AY 2014-2015

Bench: Shri Vijay Pal Rao & Shri Ramit Kochar

For Appellant: Shri Ashutosh BhardwajFor Respondent: Shri A.K. Singh, Sr. D.R
Section 143(2)Section 143(3)Section 143(3)(ii)Section 253(3)Section 253(5)Section 52C(2)

6) of 1961 Act. The Learned Counsel for the assessee, therefore, prayed that the matter may be set aside and restored to the file of A.O. for fresh adjudication of the issue on merits in accordance with law, with a direction to the A.O. to refer the matter to DVO for valuing the property and thereafter, if there

ANJU JHUNJHUNWALA,VARANASI vs. PCIT, VARANASI

In the result, appeal of the assessee is allowed

ITA 198/VNS/2019[2015-2016]Status: DisposedITAT Varanasi07 Dec 2023AY 2015-2016
Section 143(3)Section 263

6. Before us, ld. Counsel for the assessee first of all drew our attention to various documents filed before the AO in support of purchase of shares, D-mat Account in which shares were transferred and finally online sale of shares on Bombay Stock Exchange through broker M/s. Karvy Stock Broking Ltd. He further pointed out that in this case

VINOD KUMAR SARAF HUF,GORAKHPUR vs. PCIT,, GORAKHPUR

In the result, appeal of the assessee is allowed

ITA 112/VNS/2020[2015-2016]Status: DisposedITAT Varanasi07 Dec 2023AY 2015-2016
Section 143(3)Section 263

6. Before us, ld. Counsel for the assessee first of all drew our attention to various documents filed before the AO in support of purchase of shares, D-mat Account in which shares were transferred and finally online sale of shares on Bombay Stock Exchange through broker M/s. Karvy Stock Broking Ltd. He further pointed out that in this case

GOPI KRISHNA VINOD KUMAR HUF,GORAKHPUR vs. PCIT,, GORAKHPUR

In the result, appeal of the assessee is allowed

ITA 111/VNS/2020[2015-2016]Status: DisposedITAT Varanasi07 Dec 2023AY 2015-2016
Section 143(3)Section 263

6. Before us, ld. Counsel for the assessee first of all drew our attention to various documents filed before the AO in support of purchase of shares, D-mat Account in which shares were transferred and finally online sale of shares on Bombay Stock Exchange through broker M/s. Karvy Stock Broking Ltd. He further pointed out that in this case

VISHAL KANODIA,VARANASI vs. PCIT,, VARANASI

In the result, appeal of the assessee is allowed

ITA 85/VNS/2019[2014-2015]Status: DisposedITAT Varanasi07 Dec 2023AY 2014-2015
Section 143(3)Section 263

6. Before us, ld. Counsel for the assessee first of all drew our attention to various documents filed before the AO in support of purchase of shares, D-mat Account in which shares were transferred and finally online sale of shares on Bombay Stock Exchange through broker M/s. Karvy Stock Broking Ltd. He further pointed out that in this case

SARVESH KUMAR AGARWAL HUF,VARANASI vs. PCIT,, VARANASI

In the result, appeal of the assessee is allowed

ITA 252/VNS/2019[2015-2016]Status: DisposedITAT Varanasi07 Dec 2023AY 2015-2016
Section 143(3)Section 263

6. Before us, ld. Counsel for the assessee first of all drew our attention to various documents filed before the AO in support of purchase of shares, D-mat Account in which shares were transferred and finally online sale of shares on Bombay Stock Exchange through broker M/s. Karvy Stock Broking Ltd. He further pointed out that in this case

DY. COMMISSIONER OF INCOME TAX, CIRCLE - 01,, VARANASI vs. M/S RATANDEEP GOLD & DIAMOND PVT. LTD., CHANDAULI

ITA 136/VNS/2020[2017-2018]Status: DisposedITAT Varanasi03 Feb 2023AY 2017-2018

Bench: Shri Vijay Pal Rao & Shri Ramit Kocharassessment Year: 2017-18 The Deputy Commissioner M/S Ratandeep Gold & Diamond Of Income Tax, V. Pvt. Ltd. Circle-1, M A Road, 19, New Mohal, Varanasi-211001, U.P. Near Balika Inter College, Mugalsarai, Chandauli- 232101, U.P. Pan:Aahcr4764Q (Appellant) (Respondent) C.O. No. 02/Vns/2021 (Arising Out Of Ita No. 136/Vns/2020) Assessment Year: 2017-18 M/S Ratandeep Gold & The Deputy Commissioner Of Diamond Pvt. Ltd. V. Income Tax,Circle-1, M.A. Road 19, New Mohal, Varanasi-211001, U.P. Near Balika Inter College, Mugalsarai, Chandauli- 232101, U.P.

For Appellant: Shri Shishir Bajpai, CAFor Respondent: Shri Amalendu Nath Mishra, CIT DR
Section 143(3)Section 69A

6-7( also reproduced in this order ) . Thus, as per Section 292C, there will be presumption that the contents of this documents found during survey are true and the documents belong to the assessee. This presumption is rebuttable, for which the assessee has to bring on record cogent/credible evidences to rebut the said presumption. There is a difference

MANISH JAISWAL,GORAKHPUR vs. ADDL. CIT, (TDS), ALLAHABAD

ITA 216/VNS/2019[2016-2017]Status: DisposedITAT Varanasi31 May 2022AY 2016-2017

Bench: Shri Vijay Pal Rao & Shri Ramit Kocharassessment Year: 2016-17 Mr. Manish Jaiswal, Addl.Cit (Tds), Prop. New Manish Medical V. Allahabad-211001, U.P. Agencies Pashupati Market, Gandhi Park, Gorakhpur, U.P. Pan: Akdpj7675D (Appellant) (Respondent)

For Appellant: Shri Ashish Bansal, AdvocateFor Respondent: Shri A.K. Singh, Sr. DR
Section 139Section 194ISection 271CSection 273BSection 274

2 Assessment Year: 2016-17 Manish Jaiswal vs. Addl. CIT purchasing the aforesaid property . The penalty proceedings u/s 271C was initiated against the assessee by the AO for failure to deduct income tax at source u/s 194IA of the 1961 Act , on payments made for transfer of immovable property(other than agricultural land). Show cause notice (SCN) dated