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1,598 results for “condonation of delay”+ Transfer Pricingclear

Sorted by relevance

Mumbai289Delhi244Chennai238Kolkata192Bangalore106Hyderabad89Chandigarh68Jaipur67Pune59Ahmedabad54Calcutta38Rajkot25Indore20Surat17Nagpur11SC10Lucknow10Cuttack10Amritsar7Cochin6Varanasi6Karnataka5Visakhapatnam5Dehradun4Jodhpur3Agra3Raipur2Telangana2Jabalpur2Andhra Pradesh2A.K. SIKRI N.V. RAMANA1Rajasthan1Punjab & Haryana1Patna1

Key Topics

Addition to Income47Section 143(3)36Section 153C33Limitation/Time-bar27Condonation of Delay25Section 143(2)22Penalty22Section 25020Section 143(1)20

DEMI REALTORS,HYDERABAD vs. DCIT, CIRCLE-6(1), HYDERABAD

In the result, the appeal of the assessee is partly allowed for statistical purposes on the above terms

ITA 156/HYD/2023[2008-09]Status: DisposedITAT Hyderabad05 Feb 2024AY 2008-09

Bench: Shri R.K. Panda & Shri Laliet Kumar

For Respondent: Ms. T. Vijaya Lakhsmi, CIT-DR
Section 143(3)Section 37(1)Section 40Section 40A(3)Section 40a

condoning the delay. and the remaining ground nos.4 to 16 for discussion can be summarized as follows: 1) Ground 4: Disallowance of Rs.24,94,00,000 under section 40A(3) of the Act. 2) Grounds 5 to 7: Disallowance of Rs.21,08,45,001 under section 40(a)(ia) of the Act. 3) Grounds 8 and 9: Payments made

Showing 1–20 of 1,598 · Page 1 of 80

...
Disallowance19
Section 14715
Section 142(1)15

ZYDUS LIFESCIENCES LIMITED (FORMERLY KNOWN AS CADILA HEALTHCARE LTD.),AHMEDABAD vs. THE DCIT, CIRCLE-1(1)(1), AHMEDABAD

In the result, appeal preferred by the assessee is allowed

ITA 162/AHD/2021[2016-17]Status: DisposedITAT Ahmedabad30 May 2024AY 2016-17

Bench: Shri Waseem Ahmed & Ms. Madhumita Royआयकर अपील सं./I.T.A. No. 162/Ahd/2021 ("नधा"रण वष" / Assessment Years : 2016-17)

Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 144BSection 144C(13)Section 153Section 92BSection 92C

Transfer Pricing Officer to pass the order was on 31.10.2019 and since the order was passed on 01.11.2019, the said order is barred by limitation. 4. Learned Standing Counsels appearing for the respondents would not dispute the judgment dated 31.03.2022, passed in the aforementioned Writ Appeals by the Division Bench of this Court, involving a similar issue. They would however

M/S. RMZ HOTELS PRIVATE LIMITED,BANGALORE vs. NATIONAL E-ASSESSMENT CENTRE, DELHI

In the result, the appeal of the assessee is allowed

ITA 954/BANG/2022[2018-19]Status: DisposedITAT Bangalore22 Feb 2023AY 2018-19

Bench: Shri Chandra Poojariassessment Year: 2018-19

For Appellant: Shri V. Srinivasan, A.RFor Respondent: Shri Ganesh R. Ghale, Standing Counsel for Department
Section 234Section 255Section 255(3)Section 36

condone the above delay and admit the appeal for adjudication. 4. The first ground for our consideration is with regard to the disallowance of Rs.99,02,829/-, which is claimed by assessee as an interest payment. The assessee in the year under consideration advanced a sum of Rs.41 crores towards purchase of shares. The AO questioned the sources of Rs.41

HUMBOLDT WEDAG INDIA PVT. LTD.,NEW DELHI vs. ACIT, NEW DELHI

In the result ITA 3207/Del/2016 stands allowed

ITA 1154/DEL/2016[2011-12]Status: DisposedITAT Delhi11 Jun 2018AY 2011-12

Bench: Shri R.K. Panda & Shri Sudhanshu Srivastava

For Appellant: Shri Sanjay I. Bara, CIT DRFor Respondent: Shri Rajneesh Verma, CA
Section 143(1)Section 154(3)Section 92C

Transfer Pricing Officer (TPO) has been challenged. All these appeals were heard together and for the sake of convenience, they are being disposed of through this consolidated order. 2. At the outset, the Ld. CIT DR submitted that the department’s appeal for assessment year 2010-11 and bearing ITA No. 567/Kol/2015 was delayed in filing by a period

ACIT, NEW DELHI vs. M/S. HUMBOLDT WEDAG INDIA PVT. LTD., NEW DELHI

In the result ITA 3207/Del/2016 stands allowed

ITA 1057/DEL/2016[2011-12]Status: DisposedITAT Delhi11 Jun 2018AY 2011-12

Bench: Shri R.K. Panda & Shri Sudhanshu Srivastava

For Appellant: Shri Sanjay I. Bara, CIT DRFor Respondent: Shri Rajneesh Verma, CA
Section 143(1)Section 154(3)Section 92C

Transfer Pricing Officer (TPO) has been challenged. All these appeals were heard together and for the sake of convenience, they are being disposed of through this consolidated order. 2. At the outset, the Ld. CIT DR submitted that the department’s appeal for assessment year 2010-11 and bearing ITA No. 567/Kol/2015 was delayed in filing by a period

HUMBOLDT WEDAG INDIA PVT. LTD.,DELHI vs. ACIT, NEW DELHI

In the result ITA 3207/Del/2016 stands allowed

ITA 3207/DEL/2016[2011-12]Status: DisposedITAT Delhi11 Jun 2018AY 2011-12

Bench: Shri R.K. Panda & Shri Sudhanshu Srivastava

For Appellant: Shri Sanjay I. Bara, CIT DRFor Respondent: Shri Rajneesh Verma, CA
Section 143(1)Section 154(3)Section 92C

Transfer Pricing Officer (TPO) has been challenged. All these appeals were heard together and for the sake of convenience, they are being disposed of through this consolidated order. 2. At the outset, the Ld. CIT DR submitted that the department’s appeal for assessment year 2010-11 and bearing ITA No. 567/Kol/2015 was delayed in filing by a period

AEGIS LTD,MUMBAI vs. DCIT RG 5(1), MUMBAI

In the result, whereas appeal of the assessee is partly allowed, that of the Revenue is dismissed

ITA 7694/MUM/2014[2010-11]Status: DisposedITAT Mumbai08 Feb 2017AY 2010-11

Bench: Shri G.S.Pannu & Shri Sandeep Gosainaegis Limited, Essar Techno Park, Old Swan Mill Compound, Lbs Marg, Kurla (W), Mumbai 400 070 Pan:Aaace 8354Q ...... Appellant

For Appellant: S/Shri Rajan Vora/For Respondent: Shri N.K.Chand
Section 143(3)Section 92CSection 92C(2)

transferred to the AO of this charge i.e. DCIT 6(1)(1), Mumbai on 23.01.2015 and following three days were public holidays. The comments of TPO were obtained on 25.02.2015 by the AO. Thus the delay is regretted and therefore it is humbly requested that the delay may kindly be condoned. 3. Before we proceed to address the respective Grounds

DCIT CIR 6(1), MUMBAI vs. AEGIS LTD, MUMBAI

In the result, whereas appeal of the assessee is partly allowed, that of the Revenue is dismissed

ITA 1209/MUM/2015[2010-11]Status: DisposedITAT Mumbai08 Feb 2017AY 2010-11

Bench: Shri G.S.Pannu & Shri Sandeep Gosainaegis Limited, Essar Techno Park, Old Swan Mill Compound, Lbs Marg, Kurla (W), Mumbai 400 070 Pan:Aaace 8354Q ...... Appellant

For Appellant: S/Shri Rajan Vora/For Respondent: Shri N.K.Chand
Section 143(3)Section 92CSection 92C(2)

transferred to the AO of this charge i.e. DCIT 6(1)(1), Mumbai on 23.01.2015 and following three days were public holidays. The comments of TPO were obtained on 25.02.2015 by the AO. Thus the delay is regretted and therefore it is humbly requested that the delay may kindly be condoned. 3. Before we proceed to address the respective Grounds

RANDOX LABORATORIES (INDIA) P.LTD,MUMBAI vs. ITO 7(2)(1) OR CIT(A) 7, MUMBAI

In the result, Revenue’s appeal is dismissed

ITA 507/MUM/2015[2010-11]Status: DisposedITAT Mumbai07 Jun 2019AY 2010-11

Bench: Shri Saktijit Dey & Shri Rajesh Kumar

For Appellant: Shri Ajit Kumar JainFor Respondent: Shri Rakesh Ranjan
Section 143(3)Section 144C(13)

Transfer Pricing Officer to adopt the correct purchase figure as debited to the Profit & Loss account after due verification. 14. In the result, assessee’s appeal is allowed. IT(TP)A no.1568/Mum./2015 Revenue’s Appeal 15. The Registry has pointed out a delay of six days in filing the appeal. The Department has filed application seeking condonation

ACIT, CIRCLE - 2(1), KOLKATA , KOLKATA vs. M/S. ITC INFOTECH INDIA LTD., , KOLKATA

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

ITA 221/KOL/2018[2012-13]Status: DisposedITAT Kolkata31 Jan 2020AY 2012-13

Bench: Shri S.S.Godara, Jm &Dr. A.L.Saini, Am आयकरअपीलसं./Ita No.2075/Kol/2017 आयकरअपीलसं./Ita Nos.220 To 222/Kol/2018 ("नधा"रणवष" / Assessment Year:2010-11 To 2013-14)

For Appellant: Dr. P. K Srihari, CIT(DR) & Shri Supriyo Pal, JCIT Sr. DRFor Respondent: Shri J. P. Khaitan, Sr. Advocate & Shri Bikash Chanda, FCA
Section 143(3)Section 40

condone the delay in all appeals filed by the assessee, as these contain the identical grounds. 5. Although these appeals filed by the Revenue as well as Assessee for A.Y. 2010- 11 to 2013-14 contained multiple grounds of appeal. However, at the time of hearing, we have carefully perused all the grounds raised by the Revenue as well

ACIT, CIRCLE - 2(1), KOLKATA, KOLKATA vs. M/S. ITC INFOTECH INDIA LIMITED, KOLKATA

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

ITA 2075/KOL/2017[2010-11]Status: DisposedITAT Kolkata31 Jan 2020AY 2010-11

Bench: Shri S.S.Godara, Jm &Dr. A.L.Saini, Am आयकरअपीलसं./Ita No.2075/Kol/2017 आयकरअपीलसं./Ita Nos.220 To 222/Kol/2018 ("नधा"रणवष" / Assessment Year:2010-11 To 2013-14)

For Appellant: Dr. P. K Srihari, CIT(DR) & Shri Supriyo Pal, JCIT Sr. DRFor Respondent: Shri J. P. Khaitan, Sr. Advocate & Shri Bikash Chanda, FCA
Section 143(3)Section 40

condone the delay in all appeals filed by the assessee, as these contain the identical grounds. 5. Although these appeals filed by the Revenue as well as Assessee for A.Y. 2010- 11 to 2013-14 contained multiple grounds of appeal. However, at the time of hearing, we have carefully perused all the grounds raised by the Revenue as well

M/S ITC INFOTECH INDIA LTD.,KOLKATA vs. DCIT,CIR - 2(1),, KOLKATA

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

ITA 488/KOL/2019[2013-14]Status: DisposedITAT Kolkata31 Jan 2020AY 2013-14

Bench: Shri S.S.Godara, Jm &Dr. A.L.Saini, Am आयकरअपीलसं./Ita No.2075/Kol/2017 आयकरअपीलसं./Ita Nos.220 To 222/Kol/2018 ("नधा"रणवष" / Assessment Year:2010-11 To 2013-14)

For Appellant: Dr. P. K Srihari, CIT(DR) & Shri Supriyo Pal, JCIT Sr. DRFor Respondent: Shri J. P. Khaitan, Sr. Advocate & Shri Bikash Chanda, FCA
Section 143(3)Section 40

condone the delay in all appeals filed by the assessee, as these contain the identical grounds. 5. Although these appeals filed by the Revenue as well as Assessee for A.Y. 2010- 11 to 2013-14 contained multiple grounds of appeal. However, at the time of hearing, we have carefully perused all the grounds raised by the Revenue as well

M/S. ITC INFOTECH INDIA LTD., ,KOLKATA vs. ACIT, CIRCLE - 2(1), , KOLKATA

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

ITA 487/KOL/2019[2012-13]Status: DisposedITAT Kolkata31 Jan 2020AY 2012-13

Bench: Shri S.S.Godara, Jm &Dr. A.L.Saini, Am आयकरअपीलसं./Ita No.2075/Kol/2017 आयकरअपीलसं./Ita Nos.220 To 222/Kol/2018 ("नधा"रणवष" / Assessment Year:2010-11 To 2013-14)

For Appellant: Dr. P. K Srihari, CIT(DR) & Shri Supriyo Pal, JCIT Sr. DRFor Respondent: Shri J. P. Khaitan, Sr. Advocate & Shri Bikash Chanda, FCA
Section 143(3)Section 40

condone the delay in all appeals filed by the assessee, as these contain the identical grounds. 5. Although these appeals filed by the Revenue as well as Assessee for A.Y. 2010- 11 to 2013-14 contained multiple grounds of appeal. However, at the time of hearing, we have carefully perused all the grounds raised by the Revenue as well

M/S. ITC INFOTECH INDIA LTD., ,KOLKATA vs. ACIT, CIRCLE - 2(1), , KOLKATA

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

ITA 486/KOL/2019[2011-12]Status: DisposedITAT Kolkata31 Jan 2020AY 2011-12

Bench: Shri S.S.Godara, Jm &Dr. A.L.Saini, Am आयकरअपीलसं./Ita No.2075/Kol/2017 आयकरअपीलसं./Ita Nos.220 To 222/Kol/2018 ("नधा"रणवष" / Assessment Year:2010-11 To 2013-14)

For Appellant: Dr. P. K Srihari, CIT(DR) & Shri Supriyo Pal, JCIT Sr. DRFor Respondent: Shri J. P. Khaitan, Sr. Advocate & Shri Bikash Chanda, FCA
Section 143(3)Section 40

condone the delay in all appeals filed by the assessee, as these contain the identical grounds. 5. Although these appeals filed by the Revenue as well as Assessee for A.Y. 2010- 11 to 2013-14 contained multiple grounds of appeal. However, at the time of hearing, we have carefully perused all the grounds raised by the Revenue as well

ACIT, CIRCLE - 2(1), KOLKATA , KOLKATA vs. M/S. ITC INFOTECH INDIA LTD., , KOLKATA

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

ITA 220/KOL/2018[2011-12]Status: DisposedITAT Kolkata31 Jan 2020AY 2011-12

Bench: Shri S.S.Godara, Jm &Dr. A.L.Saini, Am आयकरअपीलसं./Ita No.2075/Kol/2017 आयकरअपीलसं./Ita Nos.220 To 222/Kol/2018 ("नधा"रणवष" / Assessment Year:2010-11 To 2013-14)

For Appellant: Dr. P. K Srihari, CIT(DR) & Shri Supriyo Pal, JCIT Sr. DRFor Respondent: Shri J. P. Khaitan, Sr. Advocate & Shri Bikash Chanda, FCA
Section 143(3)Section 40

condone the delay in all appeals filed by the assessee, as these contain the identical grounds. 5. Although these appeals filed by the Revenue as well as Assessee for A.Y. 2010- 11 to 2013-14 contained multiple grounds of appeal. However, at the time of hearing, we have carefully perused all the grounds raised by the Revenue as well

ITC INFOTECH INDIA LTD.,KOLKATA vs. A.C.I.T.,CIR-2(1), KOLKATA

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

ITA 552/KOL/2019[2010-11]Status: DisposedITAT Kolkata31 Jan 2020AY 2010-11

Bench: Shri S.S.Godara, Jm &Dr. A.L.Saini, Am आयकरअपीलसं./Ita No.2075/Kol/2017 आयकरअपीलसं./Ita Nos.220 To 222/Kol/2018 ("नधा"रणवष" / Assessment Year:2010-11 To 2013-14)

For Appellant: Dr. P. K Srihari, CIT(DR) & Shri Supriyo Pal, JCIT Sr. DRFor Respondent: Shri J. P. Khaitan, Sr. Advocate & Shri Bikash Chanda, FCA
Section 143(3)Section 40

condone the delay in all appeals filed by the assessee, as these contain the identical grounds. 5. Although these appeals filed by the Revenue as well as Assessee for A.Y. 2010- 11 to 2013-14 contained multiple grounds of appeal. However, at the time of hearing, we have carefully perused all the grounds raised by the Revenue as well

DCIT CIR 15(3)(1), MUMBAI vs. TRANSOCEAN DRILLING SERVICES (INDIA) PLT, MUMBAI

In the result, the cross objection of the assessee is partly allowed

ITA 2988/MUM/2019[2012-13]Status: DisposedITAT Mumbai28 Mar 2023AY 2012-13
Section 143(2)Section 143(3)Section 92F

delay in filing of cross objections is hereby condoned and the same is taken up for adjudication. 3. The ground Nos.1-6 raised by the assessee in cross objections are general in nature and does not require any specific adjudication as stated by the ld. AR before us. 3.1. The other grounds raised by the assessee in its cross objections would

SHELL GLOBAL SOLUTIONS INTERNATIONAL B.V,,AHMEDABAD vs. THE DCIT, INTL. TAXN.-1,, AHMEDABAD

The appeal of the assessee is allowed and CO filed by the Department is being dismissed for assessment year 2010-11

ITA 1390/AHD/2019[2008-09]Status: DisposedITAT Ahmedabad13 Oct 2022AY 2008-09
For Appellant: Shri S.N. Soparkar, Shri Parin ShahFor Respondent: None
Section 250Section 271Section 271(1)(c)Section 274

transfer pricing adjustment, when the said Explanation was neither referred nor relied upon at the time of initiation of the penalty proceedings under the Act. I.T.A Nos.1389 to1392/Ahd/2019 & CO Nos. 16 to 19/Ahd/2022 Page No. 18 Shell Global Solutions International B.V. vs. DCIT & ACIT(IT) vs. Shell Global Solutions International B.V. Another noteworthy point is that in our view

SHELL GLOBAL SOLUTIONS INTERNATIONAL B.V,,AHMEDABAD vs. THE DCIT, INTL. TAXN.-1,, AHMEDABAD

The appeal of the assessee is allowed and CO filed by the Department is being dismissed for assessment year 2010-11

ITA 1391/AHD/2019[2009-10]Status: DisposedITAT Ahmedabad13 Oct 2022AY 2009-10
For Appellant: Shri S.N. Soparkar, Shri Parin ShahFor Respondent: None
Section 250Section 271Section 271(1)(c)Section 274

transfer pricing adjustment, when the said Explanation was neither referred nor relied upon at the time of initiation of the penalty proceedings under the Act. I.T.A Nos.1389 to1392/Ahd/2019 & CO Nos. 16 to 19/Ahd/2022 Page No. 18 Shell Global Solutions International B.V. vs. DCIT & ACIT(IT) vs. Shell Global Solutions International B.V. Another noteworthy point is that in our view

SHELL GLOBAL SOLUTIONS INTERNATIONAL B.V,,AHMEDABAD vs. THE DCIT, INTL. TAXN.-1,, AHMEDABAD

The appeal of the assessee is allowed and CO filed by the Department is being dismissed for assessment year 2010-11

ITA 1389/AHD/2019[2007-08]Status: DisposedITAT Ahmedabad13 Oct 2022AY 2007-08
For Appellant: Shri S.N. Soparkar, Shri Parin ShahFor Respondent: None
Section 250Section 271Section 271(1)(c)Section 274

transfer pricing adjustment, when the said Explanation was neither referred nor relied upon at the time of initiation of the penalty proceedings under the Act. I.T.A Nos.1389 to1392/Ahd/2019 & CO Nos. 16 to 19/Ahd/2022 Page No. 18 Shell Global Solutions International B.V. vs. DCIT & ACIT(IT) vs. Shell Global Solutions International B.V. Another noteworthy point is that in our view