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3,103 results for “penalty u/s 271”+ Transfer Pricingclear

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Delhi1,069Mumbai764Bangalore217Ahmedabad184Jaipur141Pune110Chennai102Kolkata100Hyderabad72Indore64Surat53Chandigarh36Calcutta34Visakhapatnam29Raipur27Lucknow25Rajkot21Nagpur12Cuttack7Agra5SC4Cochin4Panaji3Dehradun3Jodhpur3Amritsar3Allahabad3Telangana3Karnataka2Rajasthan2Jabalpur1

Key Topics

Section 143(3)83Section 271(1)(c)69Addition to Income59Penalty34Disallowance33Section 14A29Transfer Pricing25Section 14824Section 92C22Deduction

DCIT - (LTU) - 1 , MUMBAI vs. RELIANCE INDUSTRIES LTD., MUMBAI

In the result, the appeals filed by the Revenue and Cross Objections filed by the assessee are dismissed

ITA 6267/MUM/2018[2009-10]Status: DisposedITAT Mumbai04 Mar 2020AY 2009-10

Bench: Shri G. Manjunatha & Shri Ravish Sood

For Appellant: Shri Jitendra Yadav &For Respondent: Shri H.N. Singh (CIT-DR)
Section 271(1)(c)Section 92C

transfer pricing adjustment u/s 92C of the Act, towards interest on loan to subsidiaries. 5. Thereafter, the A.O has initiated penalty proceedings u/s 271

VAIBHAV GLOBAL LIMITED,JAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-5, JAIPUR

In the result, the penalty is directed to be deleted and appeal of the assessee is allowed

Showing 1–20 of 3,103 · Page 1 of 156

...
18
Comparables/TP16
Section 144C15
ITA 731/JPR/2018[2010-11]Status: DisposedITAT Jaipur19 Dec 2018AY 2010-11
For Appellant: Shri Vijay Mehta (C.A.) &For Respondent: Smt. Roli Agarwal (CIT)
Section 143(3)Section 271(1)(c)Section 92C

transfer pricing adjustment/addition of Rs. 18,68,02,513/-and has Vaibhav Global Ltd. vs. ACIT stated that penalty U/s 271

VAIBHAV GLOBAL LIMITED,JAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-5, JAIPUR

In the result, the penalty is directed to be deleted and appeal of the assessee is allowed

ITA 730/JPR/2018[2009-10]Status: DisposedITAT Jaipur19 Dec 2018AY 2009-10
For Appellant: Shri Vijay Mehta (C.A.) &For Respondent: Smt. Roli Agarwal (CIT)
Section 143(3)Section 271(1)(c)Section 92C

transfer pricing adjustment/addition of Rs. 18,68,02,513/-and has Vaibhav Global Ltd. vs. ACIT stated that penalty U/s 271

NSE IT LTD,MUMBAI vs. DCIT 8(2), MUMBAI

In the result, the appeal of the assessee is allowed

ITA 5935/MUM/2014[2005-06]Status: DisposedITAT Mumbai28 Mar 2018AY 2005-06

Bench: Shri Joginder Singh & Shri Ramit Kocharआयकर अपीऱ सं./I.T.A. No.5935/Mum/2014 (नििाारण वर्ा / Assessment Year: 2005-06) बिाम/ M/S. Nse. It Ltd, Dcit 8(2), Mumbai Trade Globe, Ground Floor, Andheri Kurla Road, V. Andheri (E), Mumbai 400059 स्थायी ऱेखा सं./ Pan : Aabcn0159P (अपीऱाथी /Appellant) (प्रत्यथी / Respondent) ..

For Appellant: Shri. Sunil NahtaFor Respondent: Shri. T.A Khan(DR)
Section 143(3)Section 148Section 271(1)Section 271(1)(c)

penalty will be levied u/s 271(1)(c) even if the said income is declared in the return of income filed in pursuance to notices issued u/s 148 . It was submitted that no challenge has been made by the assessee to the issuance of notice u/s. 148. The assessee relied upon the decision of the Hon’ble Supreme Court

PROCTER AND GAMBLE HEALTH PVT LTD,MUMBAI vs. DCIT 8(2)(1), MUMBAI

In the result, the appeal of the assessee is allowed

ITA 328/MUM/2025[2005-06]Status: DisposedITAT Mumbai04 Apr 2025AY 2005-06

Bench: Shri Om Prakash Kant () & Shri Rahul Chaudhary () Assessment Year: 2005-06 Procter & Gamble Heath Ltd., The Dy. Cit-8(2)(1), P& G Plaza, Cardinal Gracias Road, Room No. 624, 6Th Floor, Vs. Chakala Andheri (East), Aayakar Bhavan, Sir M.K. Mumbai-400099. Road, Mumbai-400020. Pan No. Aaace 2616 F Appellant Respondent

For Appellant: Mr. Ajit Shah
Section 250Section 271(1)(c)

penalty u/s 271(1)(c) is leviable for filing inaccurate particul 271(1)(c) is leviable for filing inaccurate particulars of income. ars of income. (ii) Addition u/s 92CA on account of transfer pricing

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, the learned CIT(A) has erred in confirming levy of penalty under Section 271(l)(c) of the Act even in a situation wherein the learned AO has neither referred nor relied upon Explanation 7 to Section 271(l)(c) at the time of initiation of the penalty proceedings under the Act. 4. On the facts

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, the learned CIT(A) has erred in confirming levy of penalty under Section 271(l)(c) of the Act even in a situation wherein the learned AO has neither referred nor relied upon Explanation 7 to Section 271(l)(c) at the time of initiation of the penalty proceedings under the Act. 4. On the facts

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 1392/AHD/2019[2010-11]Status: DisposedITAT Ahmedabad13 Oct 2022AY 2010-11
For Appellant: Shri S.N. Soparkar, Shri Parin ShahFor Respondent: None
Section 250Section 271Section 271(1)(c)Section 274

transfer pricing adjustment, the learned CIT(A) has erred in confirming levy of penalty under Section 271(l)(c) of the Act even in a situation wherein the learned AO has neither referred nor relied upon Explanation 7 to Section 271(l)(c) at the time of initiation of the penalty proceedings under the Act. 4. On the facts

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, the learned CIT(A) has erred in confirming levy of penalty under Section 271(l)(c) of the Act even in a situation wherein the learned AO has neither referred nor relied upon Explanation 7 to Section 271(l)(c) at the time of initiation of the penalty proceedings under the Act. 4. On the facts

FRANKLIN TEMPLETON INTERNATIONAL SERVICES (INDIA) P.LTD,MUMBAI vs. DCIT CIR 6(3)(1), MUMBAI

ITA 1495/MUM/2015[2010-11]Status: DisposedITAT Mumbai20 Feb 2026AY 2010-11
Section 133(6)Section 92D

pricing order passed by Additional Commissioner of\nIncome-tax (Transfer Pricing) - 1(3), Mumbai is beyond jurisdiction -\nThe ground was not pressed\n1. Reference to the Additional Commissioner of Income-Tax (Transfer\nPricing) - 1(3), Mumbai and the transfer pricing order under section\n92CA(3) of the Act passed by the Additional Commissioner of Income-Tax\n(Transfer Pricing

ACIT-3(4), MUMBAI vs. RELIANCE INDUSTRIES LIMITED, MUMBAI

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

ITA 2898/MUM/2024[2016-17]Status: DisposedITAT Mumbai22 Nov 2024AY 2016-17

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2016-17 Reliance Industries Ltd., Dy. Cit Circle 3(4), 3Rd Floor, Maker Chamber Iv 222 Room No. 559, Aayakar Bhavan, Nariman Point, Vs. Maharshi Karve Road, Mumbai-400021. Mumbai-400020. Pan No. Aaacr 5055 K Appellant Respondent Assessment Year: 2016-17 Acit-3(4), Reliance Industries Ltd., Room No. 481(2), 4Th Floor, 3Rd Floor, Maker Chamber Iv Aayakar Bhavan, N.M. Road, Vs. Nariman Point, New Marine Lines, Mumbai-400021. Mumbai-400020. Pan No. Aaacr 5055 K Appellant Respondent

For Respondent: Mr. Madhur Agrawal
Section 14ASection 271(1)(c)Section 32A

u/s 271(1)(c) of the Act is leviable as per I.T. Act, 1961. 6. Whether on the facts and circumstances of the case and in law, the Ld. CIT(A) is deleting the penalty levied on transfer pricing

M/S PRICEWATERHOUSE COOPERS PVT. LTD.,KOLKATA vs. ACIT, CIRCLE-2(2), KOLKATA, KOLKATA

In the result, appeal of the assessee is allowed in part

ITA 2298/KOL/2016[2011-2012]Status: DisposedITAT Kolkata29 May 2020AY 2011-2012

Bench: Sri J. Sudhakar Reddy & Sri S.S. Godara) Assessment Year: 2011-12 M/S. Pricewaterhouse Coopers Private Limited……...............................……………………......Appellant Block-Ep, Plot –Y14 Salt Lake City Sector-V Kolkata – 700 091 [Pan : Aabcp 9181 H] Vs. Deputy Commissioner Of Income Tax (It), Circle-2(1), Kolkata……..........................…....Appellant Appearances By: Shri Kanchun Kaushal, A/R & Shri Bikash Kr. Jain, Ca, Appeared On Behalf Of The Assessee. Shri Vijay Shankar, Cit, D/R, Appearing On Behalf Of The Revenue. Date Of Concluding The Hearing : February 25Th, 2020 Date Of Pronouncing The Order : May 29Th, 2020 Order Per J. Sudhakar Reddy, Am :-

Section 144C(13)

penalty notice under section 274 read with section 271(1)(C) of the Act along with the draft assessment order section 274 read with section 271(1)(C) of the Act along with the draft assessment order section 274 read with section 271(1)(C) of the Act along with the draft assessment order dated 27 November 2015, which renders

NARAYAN HEIGHTS & TOWERS,JAIPUR vs. ITO, JAIPUR

In the result, the appeal of the assessee is allowed

ITA 1033/JPR/2016[2012-13]Status: DisposedITAT Jaipur20 Feb 2017AY 2012-13

Bench: The Hearing Of Appeal.”

For Appellant: Vijay Goyal (CA)For Respondent: Shri R.A. Verma (Addl. CIT)
Section 143(3)Section 271Section 271(1)(c)Section 274

u/s 274 of the Act should specifically state as to whether penalty is being proposed for concealment of particulars of income or inaccurate particulars of income. In the present case notice under section 274 dated 25/3/2015 enclosed at paper book page 16 reads as under: “Penalty Notice Under Section 274, Read with Section 271

CAPRICON REALTY LTD.,MUMBAI vs. ACIT CIR 2(1), MUMBAI

In the result, appeal of assessee is allowed

ITA 5724/MUM/2013[2005-06]Status: DisposedITAT Mumbai28 Nov 2017AY 2005-06

Bench: Shri Saktijit Dey & Shri Ramit Kocharआयकर अपीऱ सं./I.T.A. No. 5724/Mum/2013 (नििाारण वर्ा / Assessment Year : 2005-06)

For Appellant: Shri. K. Gopal/For Respondent: Shri H.N Singh,CIT-DR
Section 143(3)Section 271(1)(c)

penalty levied by the AO u/s 271(1)(c) which was later confirmed by learned CIT(A) . 6. We have considered rival contentions and have perused the material on record including orders of authorities below and cited case laws. The assessee is engaged in the business of property developments. The assessee company is one of the three Special Purpose Vehicles

SANDEEP BHIMRAO LAD,MUMBAI vs. DCIT CIRCLE-3, THANE

ITA 1620/MUM/2018[2009-10]Status: DisposedITAT Mumbai31 Oct 2019AY 2009-10

Bench: Shri S. Rifaur Rahman, Am & Shri Ram Lal Negi, Jm आयकरअपीलसं./ I.T.A. No. 1620/Mum/2018 (निर्धारणवर्ा / Assessment Year: 2009-10)

For Appellant: Shri Subodh RatnaparkhiFor Respondent: Shri V. Vinod Kumar, DR
Section 133(6)Section 148Section 271Section 274

transfer deeds duly signed, have been impounded in the course of survey proceedings under Section 133A conducted on 16.12.2003, in the case of a sister concern of the assessee. The survey was conducted more than 10 17 I.T.A. No. 1617 to 1620/Mum/2018 Sandeep Bhimrao Lad & Sunny Ashok Lad months before the assessee filed its return of income. Had it been

SWARAN NADHAN SALARIA,MUMBAI vs. DCIT CENTRAL CIRCLE 1(2), MUMBAI

In the result all In the result all appeals of the assesses from AY 2014

ITA 1054/MUM/2025[2019-20]Status: DisposedITAT Mumbai30 Jul 2025AY 2019-20

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan ()

For Appellant: Mr. Virabhadra S. Mahajan, Sr. DRFor Respondent: Mr. Rakesh Joshi
Section 143(3)Section 153ASection 37(1)

271(1)(c) of the Act are fulfilled. In view of the above, the penalty in respect of interest and the excess the penalty in respect of interest and the excess the penalty in respect of interest and the excess depreciation is also cancelled cancelled. The relevant grounds of the appeal of The relevant grounds of the appeal

SWARAN NADHAN SALARIA,MUMBAI vs. DCIT CENTRAL CIRCLE 1(2), MUMBAI

In the result all In the result all appeals of the assesses from AY 2014

ITA 1051/MUM/2025[2016-17]Status: DisposedITAT Mumbai30 Jul 2025AY 2016-17

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan ()

For Appellant: Mr. Virabhadra S. Mahajan, Sr. DRFor Respondent: Mr. Rakesh Joshi
Section 143(3)Section 153ASection 37(1)

271(1)(c) of the Act are fulfilled. In view of the above, the penalty in respect of interest and the excess the penalty in respect of interest and the excess the penalty in respect of interest and the excess depreciation is also cancelled cancelled. The relevant grounds of the appeal of The relevant grounds of the appeal

SWARAN NADHAN SALARIA,MUMBAI vs. DICT CENTRAL CIRCLE 1(2), MUMBAI

In the result all In the result all appeals of the assesses from AY 2014

ITA 1052/MUM/2025[2017-18]Status: DisposedITAT Mumbai30 Jul 2025AY 2017-18

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan ()

For Appellant: Mr. Virabhadra S. Mahajan, Sr. DRFor Respondent: Mr. Rakesh Joshi
Section 143(3)Section 153ASection 37(1)

271(1)(c) of the Act are fulfilled. In view of the above, the penalty in respect of interest and the excess the penalty in respect of interest and the excess the penalty in respect of interest and the excess depreciation is also cancelled cancelled. The relevant grounds of the appeal of The relevant grounds of the appeal

SWARAN NADHAN SALARIA,MUMBAI vs. DCIT CENTRAL CIRCLE 1(2), MUMBAI

In the result all In the result all appeals of the assesses from AY 2014

ITA 1053/MUM/2025[2018-19]Status: DisposedITAT Mumbai30 Jul 2025AY 2018-19

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan ()

For Appellant: Mr. Virabhadra S. Mahajan, Sr. DRFor Respondent: Mr. Rakesh Joshi
Section 143(3)Section 153ASection 37(1)

271(1)(c) of the Act are fulfilled. In view of the above, the penalty in respect of interest and the excess the penalty in respect of interest and the excess the penalty in respect of interest and the excess depreciation is also cancelled cancelled. The relevant grounds of the appeal of The relevant grounds of the appeal

DCM SHRIIRAM LTD.,NEW DELHI vs. ADDL.CIT, SPECIAL RANGE- 3 , NEW DELHI

In the result appeal of assessee is partly allowed

ITA 7362/DEL/2018[2014-15]Status: DisposedITAT Delhi28 Oct 2021AY 2014-15

Bench: Shri Kul Bharat & Shri Prashant Maharishi(Through Video Conferencing)

For Appellant: Shri Pradeep Dinodia, C. A.; &For Respondent: Shri Surendra Pal [CIT] – DR
Section 133(6)Section 143Section 143(3)Section 144Section 92C

price of the steam transferred by the assessee from eligible unit to non eligible unit. (Covered by ground number 2 – 3) ii. Disallowance confirmed by the learned dispute resolution panel in its direction to the extent of Rs 1, 55,48,790/– u/s 14 A of the income tax act and consequent adjustment to the book profit u/s 115JB