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19 results for “transfer pricing”+ Section 109clear

Sorted by relevance

Delhi572Mumbai428Karnataka309Bangalore190Ahmedabad142Chennai97Hyderabad91Kolkata90Jaipur87Cochin76Indore62Pune59Calcutta51Chandigarh47Lucknow20Raipur20Surat20Visakhapatnam19SC12Nagpur11Cuttack11Rajkot9Telangana8Amritsar5Agra4Varanasi4Jodhpur3Rajasthan3Allahabad2Orissa1Andhra Pradesh1Jabalpur1A.K. SIKRI ROHINTON FALI NARIMAN1

Key Topics

Section 143(3)7Addition to Income7Disallowance6Section 92C4Section 1484Section 1444Section 43B4Section 434Deduction

GVR POWER & INFRASTRUCTURE LIMITED,KADIYAM vs. ACIT, CIRCLE - 2(1), RAJAHMUNDRY

In the result, the appeal filed by the assessee is partly allowed

ITA 530/VIZ/2017[2013-14]Status: DisposedITAT Visakhapatnam18 May 2018AY 2013-14

Bench: Shri V. Durga Rao & Shri D.S. Sunder Singh

For Appellant: Shri Deba Kumar Sonowal
Section 92C

transfer pricing officer found GVK Power & Infrastructure Ltd., Jegurupadu that the assessee has receivables of Rs.7,32,97,465/- as at the end of the year. The TPO requested the assessee to submit the details of raising the invoice and subsequent receipt of the amount and also called for an explanation as to why notional interest should not be charged

ASST. COMMISSIONER OF INCOME TAX, VIJAYAWADA vs. FYSOLATE TECHNOLOGIES, VIJAYAWADA

In the result, appeal of the Revenue is dismissed

ITA 182/VIZ/2023[2017-18]Status: DisposedITAT Visakhapatnam
3
Section 143(1)2
Section 162
Transfer Pricing2
15 Jul 2024
AY 2017-18

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./ I.T.A. No.182/Viz/2023 (िनधा"रण वष" / Assessment Year : 2017-18) Assistant Commissioner Of Vs. Fysolate Technologies, Income Tax, Vijayawada. Vijawayada. Pan: Aacff5633L (अपीलाथ"/ Appellant) (""यथ"/ Respondent) अपीलाथ" क" ओर से/ Assessee By : Sri Mithilesh Sannareddy ""याथ" क" ओर से / Revenue By : Dr. Satyasai Rath, Cit-Dr सुनवाई क" तारीख / Date Of Hearing : 16/04/2024 घोषणा क" तारीख/Date Of : 15/07/2024 Pronouncement O R D E R

For Appellant: Sri Mithilesh SannareddyFor Respondent: Dr. Satyasai Rath, CIT-DR
Section 10ASection 143(2)Section 143(3)Section 92C

Transfer Pricing Officer [“Ld. TPO”] issued notices on various dates U/s. 92CA of the Act. In response, the assessee furnished the information as called for along with the T.P. Documentation. The assessee claimed deduction U/s. 10AA of the Act. The domestic transactions reflected in 3CEB/T.P. Study report are as follows: Description In Rs. Purchase of crude Herbal Extracts and oils

VISAKHAPATNAM PORT AUTHORITY,,VISAKHAPATNAM vs. THE ADDL. CIT.,, VISAKHAPATNAM

In the result, CO raised by the assessee is disposed off as discussed herein above

ITA 25/VIZ/2014[2010-11]Status: DisposedITAT Visakhapatnam27 Sept 2023AY 2010-11

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.25/Viz/2014 ("नधा"रणवष"/ Assessment Year :2010-11) Visakhapatnam Port Authority, Vs. Addl. Cit, (Formerly Known As M/S. Range-1, Visakhapatnam Port Trust) Visakhapatnam. Visakhapatnam. Pan: Aaalv0035C (अपीलाथ"/ Appellant) (""यथ"/ Respondent)

price. A method of accounting adopted by the trader consistently and regularly cannot be discarded by the departmental authorities on the view that he should have adopted a different method of keeping account or of valuation. The method of accounting regularly employed may be discarded only if, in the opinion of the taxing authorities income of the trade cannot

VISAKHAPATNAM PORT AUTHORITY,,VISAKHAPATNAM vs. THE ACIT, CIRCLE - 1(1),, VISAKHAPATNAM

In the result, CO raised by the assessee is disposed off as discussed herein above

ITA 26/VIZ/2014[2011-12]Status: DisposedITAT Visakhapatnam27 Sept 2023AY 2011-12

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.25/Viz/2014 ("नधा"रणवष"/ Assessment Year :2010-11) Visakhapatnam Port Authority, Vs. Addl. Cit, (Formerly Known As M/S. Range-1, Visakhapatnam Port Trust) Visakhapatnam. Visakhapatnam. Pan: Aaalv0035C (अपीलाथ"/ Appellant) (""यथ"/ Respondent)

price. A method of accounting adopted by the trader consistently and regularly cannot be discarded by the departmental authorities on the view that he should have adopted a different method of keeping account or of valuation. The method of accounting regularly employed may be discarded only if, in the opinion of the taxing authorities income of the trade cannot

THE ACIT, CIRCLE - 1(1),, VISAKHAPATNAM vs. VISAKHAPATNAM PORT AUTHORITY,, VISAKHAPATNAM

In the result, CO raised by the assessee is disposed off as discussed herein above

ITA 399/VIZ/2014[2011-12]Status: DisposedITAT Visakhapatnam27 Sept 2023AY 2011-12

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.25/Viz/2014 ("नधा"रणवष"/ Assessment Year :2010-11) Visakhapatnam Port Authority, Vs. Addl. Cit, (Formerly Known As M/S. Range-1, Visakhapatnam Port Trust) Visakhapatnam. Visakhapatnam. Pan: Aaalv0035C (अपीलाथ"/ Appellant) (""यथ"/ Respondent)

price. A method of accounting adopted by the trader consistently and regularly cannot be discarded by the departmental authorities on the view that he should have adopted a different method of keeping account or of valuation. The method of accounting regularly employed may be discarded only if, in the opinion of the taxing authorities income of the trade cannot

VISAKHAPATNAM PORT AUTHORITY,,VISAKHAPATNAM vs. THE ACIT,, VISAKHAPATNAM

In the result, CO raised by the assessee is disposed off as discussed herein above

ITA 397/VIZ/2014[2011-12]Status: DisposedITAT Visakhapatnam27 Sept 2023AY 2011-12

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.25/Viz/2014 ("नधा"रणवष"/ Assessment Year :2010-11) Visakhapatnam Port Authority, Vs. Addl. Cit, (Formerly Known As M/S. Range-1, Visakhapatnam Port Trust) Visakhapatnam. Visakhapatnam. Pan: Aaalv0035C (अपीलाथ"/ Appellant) (""यथ"/ Respondent)

price. A method of accounting adopted by the trader consistently and regularly cannot be discarded by the departmental authorities on the view that he should have adopted a different method of keeping account or of valuation. The method of accounting regularly employed may be discarded only if, in the opinion of the taxing authorities income of the trade cannot

VISAKHAPATNAM PORT AUTHORITY,,VISAKHAPATNAM vs. THE ACIT,, VISAKHAPATNAM

In the result, CO raised by the assessee is disposed off as discussed herein above

ITA 12/VIZ/2015[2011-12]Status: DisposedITAT Visakhapatnam27 Sept 2023AY 2011-12

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.25/Viz/2014 ("नधा"रणवष"/ Assessment Year :2010-11) Visakhapatnam Port Authority, Vs. Addl. Cit, (Formerly Known As M/S. Range-1, Visakhapatnam Port Trust) Visakhapatnam. Visakhapatnam. Pan: Aaalv0035C (अपीलाथ"/ Appellant) (""यथ"/ Respondent)

price. A method of accounting adopted by the trader consistently and regularly cannot be discarded by the departmental authorities on the view that he should have adopted a different method of keeping account or of valuation. The method of accounting regularly employed may be discarded only if, in the opinion of the taxing authorities income of the trade cannot

THE VISAKHAPATNAM PORT AUTHORITY,,VISAKHAPATNAM vs. THE ASST. CIT,, VISAKHAPATNAM

In the result, CO raised by the assessee is disposed off as discussed herein above

ITA 325/VIZ/2017[2012-2013]Status: DisposedITAT Visakhapatnam27 Sept 2023AY 2012-2013

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.25/Viz/2014 ("नधा"रणवष"/ Assessment Year :2010-11) Visakhapatnam Port Authority, Vs. Addl. Cit, (Formerly Known As M/S. Range-1, Visakhapatnam Port Trust) Visakhapatnam. Visakhapatnam. Pan: Aaalv0035C (अपीलाथ"/ Appellant) (""यथ"/ Respondent)

price. A method of accounting adopted by the trader consistently and regularly cannot be discarded by the departmental authorities on the view that he should have adopted a different method of keeping account or of valuation. The method of accounting regularly employed may be discarded only if, in the opinion of the taxing authorities income of the trade cannot

VISAKHAPATNAM PORT AUTHORITY, ,VISAKHAPATNAM vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1),, VISAKHAPATNAM

In the result, CO raised by the assessee is disposed off as discussed herein above

ITA 235/VIZ/2020[2015-16]Status: DisposedITAT Visakhapatnam27 Sept 2023AY 2015-16

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.25/Viz/2014 ("नधा"रणवष"/ Assessment Year :2010-11) Visakhapatnam Port Authority, Vs. Addl. Cit, (Formerly Known As M/S. Range-1, Visakhapatnam Port Trust) Visakhapatnam. Visakhapatnam. Pan: Aaalv0035C (अपीलाथ"/ Appellant) (""यथ"/ Respondent)

price. A method of accounting adopted by the trader consistently and regularly cannot be discarded by the departmental authorities on the view that he should have adopted a different method of keeping account or of valuation. The method of accounting regularly employed may be discarded only if, in the opinion of the taxing authorities income of the trade cannot

VISAKHAPATNAM PORT AUTHORITY,,VISAKHAPATNAM vs. THE ACIT,, VISAKHAPATNAM

In the result, CO raised by the assessee is disposed off as discussed herein above

ITA 396/VIZ/2014[2010-11]Status: DisposedITAT Visakhapatnam27 Sept 2023AY 2010-11

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.25/Viz/2014 ("नधा"रणवष"/ Assessment Year :2010-11) Visakhapatnam Port Authority, Vs. Addl. Cit, (Formerly Known As M/S. Range-1, Visakhapatnam Port Trust) Visakhapatnam. Visakhapatnam. Pan: Aaalv0035C (अपीलाथ"/ Appellant) (""यथ"/ Respondent)

price. A method of accounting adopted by the trader consistently and regularly cannot be discarded by the departmental authorities on the view that he should have adopted a different method of keeping account or of valuation. The method of accounting regularly employed may be discarded only if, in the opinion of the taxing authorities income of the trade cannot

THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1),, VISAKHAPATNAM vs. VISAKHAPATNAM PORT AUTHORITY,, VISAKHAPATNAM

In the result, CO raised by the assessee is disposed off as discussed herein above

ITA 49/VIZ/2021[2015-16]Status: DisposedITAT Visakhapatnam27 Sept 2023AY 2015-16

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.25/Viz/2014 ("नधा"रणवष"/ Assessment Year :2010-11) Visakhapatnam Port Authority, Vs. Addl. Cit, (Formerly Known As M/S. Range-1, Visakhapatnam Port Trust) Visakhapatnam. Visakhapatnam. Pan: Aaalv0035C (अपीलाथ"/ Appellant) (""यथ"/ Respondent)

price. A method of accounting adopted by the trader consistently and regularly cannot be discarded by the departmental authorities on the view that he should have adopted a different method of keeping account or of valuation. The method of accounting regularly employed may be discarded only if, in the opinion of the taxing authorities income of the trade cannot

THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1),, VISAKHAPATNAM vs. VISAKHAPATNAM PORT AUTHORITY, , VISAKHAPTNAM

In the result, CO raised by the assessee is disposed off as discussed herein above

ITA 67/VIZ/2021[2016-17]Status: DisposedITAT Visakhapatnam27 Sept 2023AY 2016-17

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.25/Viz/2014 ("नधा"रणवष"/ Assessment Year :2010-11) Visakhapatnam Port Authority, Vs. Addl. Cit, (Formerly Known As M/S. Range-1, Visakhapatnam Port Trust) Visakhapatnam. Visakhapatnam. Pan: Aaalv0035C (अपीलाथ"/ Appellant) (""यथ"/ Respondent)

price. A method of accounting adopted by the trader consistently and regularly cannot be discarded by the departmental authorities on the view that he should have adopted a different method of keeping account or of valuation. The method of accounting regularly employed may be discarded only if, in the opinion of the taxing authorities income of the trade cannot

VISAKHAPATNAM PORT AUTHORITY,,VISAKHAPATNAM vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1),, VISAKHAPATNAM

In the result, CO raised by the assessee is disposed off as discussed herein above

ITA 236/VIZ/2020[2016-17]Status: DisposedITAT Visakhapatnam27 Sept 2023AY 2016-17

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.25/Viz/2014 ("नधा"रणवष"/ Assessment Year :2010-11) Visakhapatnam Port Authority, Vs. Addl. Cit, (Formerly Known As M/S. Range-1, Visakhapatnam Port Trust) Visakhapatnam. Visakhapatnam. Pan: Aaalv0035C (अपीलाथ"/ Appellant) (""यथ"/ Respondent)

price. A method of accounting adopted by the trader consistently and regularly cannot be discarded by the departmental authorities on the view that he should have adopted a different method of keeping account or of valuation. The method of accounting regularly employed may be discarded only if, in the opinion of the taxing authorities income of the trade cannot

THE ARYAPURAM CO-OPERATIVE URBAN BANK LTD.,RAJAHMUNDRY vs. THE ACIT,, RAJAHMUNDRY

In the result, all the appeals filed by the assessee are partly allowed for statistical purposes; and the appeal filed by the Revenue is dismissed

ITA 173/VIZ/2015[2011-12]Status: DisposedITAT Visakhapatnam28 May 2018AY 2011-12

Bench: Shri V. Durga Rao, Hon’Ble & Shri D.S. Sunder Singh, Hon’Ble

For Appellant: Shri G.V.N. Hari – AdvocateFor Respondent: Shri Deba Kumar Sonawal – CIT DR
Section 143(3)Section 144Section 148Section 43Section 43B

109)(A.P), the rebate to be given to its members was ascertained only at the end of the year at the time of making up of accounts. The revenue treated the said payment as appropriation of profit. However, the Hon'ble Andhra Pradesh High Court has held that the rebate so given is not part of profit

ARYAPURAM CO=OP. URBANK LTD.,,RAJAHMUNDRY vs. THE ACIT,, RAJAHMUNDRY

In the result, all the appeals filed by the assessee are partly allowed for statistical purposes; and the appeal filed by the Revenue is dismissed

ITA 517/VIZ/2014[2010-11]Status: DisposedITAT Visakhapatnam28 May 2018AY 2010-11

Bench: Shri V. Durga Rao, Hon’Ble & Shri D.S. Sunder Singh, Hon’Ble

For Appellant: Shri G.V.N. Hari – AdvocateFor Respondent: Shri Deba Kumar Sonawal – CIT DR
Section 143(3)Section 144Section 148Section 43Section 43B

109)(A.P), the rebate to be given to its members was ascertained only at the end of the year at the time of making up of accounts. The revenue treated the said payment as appropriation of profit. However, the Hon'ble Andhra Pradesh High Court has held that the rebate so given is not part of profit

THE ACIT,CIRCLE - 1,, RAJAHMUNDRY vs. M/STHE ARYAPURAM CO-OPRATIVE URBAN BANK LTD.,, RAJAHMUNDRY

In the result, all the appeals filed by the assessee are partly allowed for statistical purposes; and the appeal filed by the Revenue is dismissed

ITA 195/VIZ/2013[2009-10]Status: DisposedITAT Visakhapatnam28 May 2018AY 2009-10

Bench: Shri V. Durga Rao, Hon’Ble & Shri D.S. Sunder Singh, Hon’Ble

For Appellant: Shri G.V.N. Hari – AdvocateFor Respondent: Shri Deba Kumar Sonawal – CIT DR
Section 143(3)Section 144Section 148Section 43Section 43B

109)(A.P), the rebate to be given to its members was ascertained only at the end of the year at the time of making up of accounts. The revenue treated the said payment as appropriation of profit. However, the Hon'ble Andhra Pradesh High Court has held that the rebate so given is not part of profit

THE ARYAPURAM CO-OPERATIVE URBAN BANK LTD.,,RAJAHMUNDRY vs. THE ACIT, CIRCLE - 1, RAJAHMUNDRY

In the result, all the appeals filed by the assessee are partly allowed for statistical purposes; and the appeal filed by the Revenue is dismissed

ITA 177/VIZ/2013[2009-10]Status: DisposedITAT Visakhapatnam28 May 2018AY 2009-10

Bench: Shri V. Durga Rao, Hon’Ble & Shri D.S. Sunder Singh, Hon’Ble

For Appellant: Shri G.V.N. Hari – AdvocateFor Respondent: Shri Deba Kumar Sonawal – CIT DR
Section 143(3)Section 144Section 148Section 43Section 43B

109)(A.P), the rebate to be given to its members was ascertained only at the end of the year at the time of making up of accounts. The revenue treated the said payment as appropriation of profit. However, the Hon'ble Andhra Pradesh High Court has held that the rebate so given is not part of profit

THE JAMPETA CO-OPERATIVE URBAN BANK LTD.,,RAJAHMUNDRY vs. THE ACIT, CIRCLE - 1,, RAJAHMUNDRY

In the result, appeals filed by the assessee in ITA No

ITA 510/VIZ/2014[2010-11]Status: DisposedITAT Visakhapatnam28 May 2018AY 2010-11

Bench: Shri V. Durga Rao, Hon’Ble & Shri D.S. Sunder Singh, Hon’Ble & The Jampeta Co-Operative Vs. Acit, Circle-1, Urban Bank Ltd., Jampeta, Rajahmundry. Rajahmundry. Pan No. Aaaat 4048 E (Appellant) (Respondent)

For Appellant: Shri G.V.N. Hari, AdvocateFor Respondent: Shri S. Ravi Shankar Narayan, Sr.DR
Section 143(1)Section 143(3)Section 16Section 45

109)(A.P), the rebate to be given to its members was ascertained only at the end of the year at the time of making up of accounts. The revenue treated the said payment as appropriation of profit. However, the Hon'ble Andhra Pradesh High Court has held that the rebate so given is not part of profit

M/S. THE JAMPETA CO- OP URBAN BANK LTD,,RAJAHMUNDRY vs. THE JOIT CIT,, RAJAHMUNDRY

In the result, appeals filed by the assessee in ITA No

ITA 160/VIZ/2017[2011-2012]Status: DisposedITAT Visakhapatnam28 May 2018AY 2011-2012

Bench: Shri V. Durga Rao, Hon’Ble & Shri D.S. Sunder Singh, Hon’Ble & The Jampeta Co-Operative Vs. Acit, Circle-1, Urban Bank Ltd., Jampeta, Rajahmundry. Rajahmundry. Pan No. Aaaat 4048 E (Appellant) (Respondent)

For Appellant: Shri G.V.N. Hari, AdvocateFor Respondent: Shri S. Ravi Shankar Narayan, Sr.DR
Section 143(1)Section 143(3)Section 16Section 45

109)(A.P), the rebate to be given to its members was ascertained only at the end of the year at the time of making up of accounts. The revenue treated the said payment as appropriation of profit. However, the Hon'ble Andhra Pradesh High Court has held that the rebate so given is not part of profit