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891 results for “transfer pricing”+ Revision u/s 263clear

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Key Topics

Section 263235Section 143(3)128Addition to Income43Section 14A39Disallowance36Deduction33Revision u/s 26328Transfer Pricing20Section 14719Section 80

A.B. SUGARS LIMITED,PUNJAB vs. PRINCIPAL COMMISSIONER OF INCOME TAX -1, CHANDIGARH, CHANDIGARH

In the result, the appeal of the assessee is allowed

ITA 299/CHANDI/2024[2018-2019]Status: DisposedITAT Chandigarh16 Dec 2024AY 2018-2019

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member), SHRI. PARESH M. JOSHI (Judicial Member)

For Appellant: Shri T.N. Singla, C.AFor Respondent: Shri Rohit Sharma, CIT DR
Section 143(3)Section 263Section 80ISection 92C

revision of order of Transfer Pricing Order: • We would like to state that complete information along with complete details were provided to the Transfer Pricing Officer and after examining complete details a possible view has been taken by the Transfer Pricing Officer before passing order u/s 92CA(3). • The notice issued u/s 263

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Section 92C15
Depreciation14

A.B. SUGARS LIMITED,PUNJAB vs. PRINCIPAL COMMISSIONER OF INCOME TAX-1, CHANDIGARH

In the result, the appeal of the assessee is allowed

ITA 300/CHANDI/2024[2017-2018]Status: DisposedITAT Chandigarh16 Dec 2024AY 2017-2018

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member), SHRI. PARESH M. JOSHI (Judicial Member)

For Appellant: Shri T.N. Singla, C.AFor Respondent: Shri Rohit Sharma, CIT DR
Section 143(3)Section 263Section 80ISection 92C

revision of order of Transfer Pricing Order: • We would like to state that complete information along with complete details were provided to the Transfer Pricing Officer and after examining complete details a possible view has been taken by the Transfer Pricing Officer before passing order u/s 92CA(3). • The notice issued u/s 263

PINCITY JEWLHOUSE PVT. LTD.,JAIPUR vs. PCIT, CC, JAIPUR, JAIPUR

In the result, the appeal of the assessee is allowed

ITA 63/JPR/2021[2015-16]Status: DisposedITAT Jaipur07 Mar 2024AY 2015-16

Bench: the date of hearing." 3. At the outset of hearing, the Bench observed that there is delay of 58 days in filing of the present appeal by the assessee for which the Id. AR of 3

For Appellant: Sh. Siddharth Ranka, Adv. &For Respondent: Sh. Ajey Malik, CIT
Section 10ASection 147Section 253(5)Section 263Section 5

REVISION U/S. 263 7. CIT v. Manna Trust 42 44 {2022 (01) TMI 693} Rajasthan High Court 27 Pinkcity Jewelhouse Pvt. Ltd. vs. PCIT 8. Gayatri Devi v. PCIT 45 78 {2023 (10) TMI 23} ITAT - Jaipur PAPER BOOK-II SNo. Particulars Page No. From To 1. Copy of Order dated 18.12.2017 passed u/s 147 r.w.s

PHILIPS FOODS INDIA PRIVATE LIMITED,TUTICORIN vs. PCIT-1, MADURAI

In the result, the appeal of the assesse is allowed

ITA 640/CHNY/2023[2016-17]Status: DisposedITAT Chennai30 Sept 2024AY 2016-17
Section 143(3)Section 263Section 92C

Transfer Pricing)\nChennai would have lawful authority u/s 263 to revise the orders passed\nby DCIT / ACIT (Transfer Pricing) 2(2), Chennai

PINK CITY JEWEL HOUSE PRIVATE LIMITED ,JAIPUR vs. PRINCIPAL COMMISSIONER OF INCOME TAX (CENTRAL), JAIPUR

ITA 598/JPR/2024[2018-2019]Status: DisposedITAT Jaipur26 Dec 2024AY 2018-2019
For Appellant: Sh. Siddharth Ranka, AdvFor Respondent: \nSh. Saurav Harsh, Adv.&
Section 142(1)Section 143(2)Section 144oSection 14ASection 263Section 69

u/s. 263 by the Id. PCIT is bad in law and\ndeserves to be quashed and set-aside.\nGround No. 5:\nDeduction under section 10AA of the Act:\n6. That as submitted hereinabove subsequent to survey conducted on 17-\n18.08.2017, reassessment proceedings u/s. 148 of the Act were initiated and\n37\nITA No. 598/JP/2024\nPinkcity Jewelhouse Pvt. Ltd. vs. PCIT

VANAVIL ESTATE,CHENNAI vs. PCIT CENTRAL, CHENNAI

In the result, the appeal for both AYs 2017

ITA 926/CHNY/2024[2018-19]Status: DisposedITAT Chennai12 Feb 2025AY 2018-19

Bench: Shri Aby T. Varkey & Shri Jagadishआयकरअपीलसं./Ita Nos.925 & 926/Chny/2024 िनधा"रणवष"/Assessment Years: 2017-18 & 2018-19 V. Vanavil Estate, The Pcit (Central), 4/20, Duraiswamy Reddy Street, Chennai-1. West Tambaram, Chennai-600 045. [Pan: Aalfv 0770 H] (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Shri S. Sridhar, AdvocateFor Respondent: Shri R. Clement Ramesh-
Section 133ASection 148Section 263

revised by the Ld. CIT only when it is shown that the said order is prejudicial to the interests of Revenue. When this aspect is examined, one prejudicial to the interests of Revenue. When this aspect is examined, one prejudicial to the interests of Revenue. When this aspect is examined, one has to understand what is prejudicial

VANAVIL ESTATE,CHENNAI vs. PCIT(CENTRAL), CHENNAI

In the result, the appeal for both AYs 2017

ITA 925/CHNY/2024[2017-18]Status: DisposedITAT Chennai12 Feb 2025AY 2017-18

Bench: Shri Aby T. Varkey & Shri Jagadishआयकरअपीलसं./Ita Nos.925 & 926/Chny/2024 िनधा"रणवष"/Assessment Years: 2017-18 & 2018-19 V. Vanavil Estate, The Pcit (Central), 4/20, Duraiswamy Reddy Street, Chennai-1. West Tambaram, Chennai-600 045. [Pan: Aalfv 0770 H] (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Shri S. Sridhar, AdvocateFor Respondent: Shri R. Clement Ramesh-
Section 133ASection 148Section 263

revised by the Ld. CIT only when it is shown that the said order is prejudicial to the interests of Revenue. When this aspect is examined, one prejudicial to the interests of Revenue. When this aspect is examined, one prejudicial to the interests of Revenue. When this aspect is examined, one has to understand what is prejudicial

ZENZI PHARMACEUTICAL INDUSTIES PVT LTD.,MUMBAI vs. CIT (TRANSFER PRICING)-4, MUMBAI

In the result all the four appeals filed by the assessee are dismissed

ITA 2002/MUM/2023[2012-13]Status: DisposedITAT Mumbai29 Nov 2023AY 2012-13

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

For Appellant: Shri Devendra Jain &For Respondent: Shri Vivek Perumpura
Section 131Section 143Section 147Section 148Section 263Section 271BSection 68Section 92C

263 of the income tax act. Therefore any order passed under section 92CA (3) of the act by the transfer pricing officer prior to 1/4/2022 is not subject to the revision proceedings. Thus, the impugned revisionary order revising the TP Assessment Order passed u/s

ZENZI PHARMACEUTICAL INDUSTIES PVT LTD.,MUMBAI vs. CIT (TRANSFER PRICING)-4, MUMBAI

In the result all the four appeals filed by the assessee are dismissed

ITA 2003/MUM/2023[2017-18]Status: DisposedITAT Mumbai29 Nov 2023AY 2017-18

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

For Appellant: Shri Devendra Jain &For Respondent: Shri Vivek Perumpura
Section 131Section 143Section 147Section 148Section 263Section 271BSection 68Section 92C

263 of the income tax act. Therefore any order passed under section 92CA (3) of the act by the transfer pricing officer prior to 1/4/2022 is not subject to the revision proceedings. Thus, the impugned revisionary order revising the TP Assessment Order passed u/s

ZENZI PHARMACEUTICAL INDUSTIES PVT LTD.,MUMBAI CITY vs. CIT (TRANSFER PRICING)-4, MUMBAI CITY

In the result all the four appeals filed by the assessee are dismissed

ITA 2004/MUM/2023[2018-19]Status: DisposedITAT Mumbai29 Nov 2023AY 2018-19

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

For Appellant: Shri Devendra Jain &For Respondent: Shri Vivek Perumpura
Section 131Section 143Section 147Section 148Section 263Section 271BSection 68Section 92C

263 of the income tax act. Therefore any order passed under section 92CA (3) of the act by the transfer pricing officer prior to 1/4/2022 is not subject to the revision proceedings. Thus, the impugned revisionary order revising the TP Assessment Order passed u/s

ZENZI PHARMACEUTICAL INDUSTIES PVT LTD.,MUMBAI CITY vs. CIT (TRANSFER PRICING)-4, MUMBAI CITY

In the result all the four appeals filed by the assessee are dismissed

ITA 2005/MUM/2023[2019-20]Status: DisposedITAT Mumbai29 Nov 2023AY 2019-20

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

For Appellant: Shri Devendra Jain &For Respondent: Shri Vivek Perumpura
Section 131Section 143Section 147Section 148Section 263Section 271BSection 68Section 92C

263 of the income tax act. Therefore any order passed under section 92CA (3) of the act by the transfer pricing officer prior to 1/4/2022 is not subject to the revision proceedings. Thus, the impugned revisionary order revising the TP Assessment Order passed u/s

SURJEET SINGH,SIRSA vs. PCIT, ROHTAK, ROHTAK

In the result, all the above appeals filed by the respective assessee’s are dismissed

ITA 488/CHANDI/2024[2018-19]Status: DisposedITAT Chandigarh24 Feb 2026AY 2018-19

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

Section 143(3)Section 263

u/s 263 of the Act it is noted as under: “5.1. I have carefully examined the facts of the case and It is evident that the assessee has received interest on enhanced compensation during the assessment year under consideration which ought to be treated as "income from other sources" and should have been taxed accordingly, under the head "income from

SH. KASHMIR SINGH SANDHA,SIRSA vs. PCIT, ROHTAK

In the result, all the above appeals filed by the respective assessee’s are dismissed

ITA 288/CHANDI/2023[2018-19]Status: DisposedITAT Chandigarh24 Feb 2026AY 2018-19

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

Section 143(3)Section 263

u/s 263 of the Act it is noted as under: “5.1. I have carefully examined the facts of the case and It is evident that the assessee has received interest on enhanced compensation during the assessment year under consideration which ought to be treated as "income from other sources" and should have been taxed accordingly, under the head "income from

SH. RANDHIR SINGH,SIRSA vs. PCIT ROHTAK, ROHTAK

In the result, all the above appeals filed by the respective assessee’s are dismissed

ITA 494/CHANDI/2024[2013-14]Status: DisposedITAT Chandigarh24 Feb 2026AY 2013-14

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

Section 143(3)Section 263

u/s 263 of the Act it is noted as under: “5.1. I have carefully examined the facts of the case and It is evident that the assessee has received interest on enhanced compensation during the assessment year under consideration which ought to be treated as "income from other sources" and should have been taxed accordingly, under the head "income from

DHUNI CHAND HUF,SIRSA vs. PCIT, ROHTAK

In the result, all the above appeals filed by the respective assessee’s are dismissed

ITA 289/CHANDI/2023[2018-19]Status: DisposedITAT Chandigarh24 Feb 2026AY 2018-19

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

Section 143(3)Section 263

u/s 263 of the Act it is noted as under: “5.1. I have carefully examined the facts of the case and It is evident that the assessee has received interest on enhanced compensation during the assessment year under consideration which ought to be treated as "income from other sources" and should have been taxed accordingly, under the head "income from

SH. ARVAIL SINGH,SIRSA vs. PCIT, ROHTAK

In the result, all the above appeals filed by the respective assessee’s are dismissed

ITA 286/CHANDI/2023[2018-19]Status: DisposedITAT Chandigarh24 Feb 2026AY 2018-19

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

Section 143(3)Section 263

u/s 263 of the Act it is noted as under: “5.1. I have carefully examined the facts of the case and It is evident that the assessee has received interest on enhanced compensation during the assessment year under consideration which ought to be treated as "income from other sources" and should have been taxed accordingly, under the head "income from

M/S GANESH DASS HUF,SIRSA vs. PCIT, ROHTAK

In the result, all the above appeals filed by the respective assessee’s are dismissed

ITA 287/CHANDI/2023[2018-19]Status: DisposedITAT Chandigarh24 Feb 2026AY 2018-19

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

Section 143(3)Section 263

u/s 263 of the Act it is noted as under: “5.1. I have carefully examined the facts of the case and It is evident that the assessee has received interest on enhanced compensation during the assessment year under consideration which ought to be treated as "income from other sources" and should have been taxed accordingly, under the head "income from

SH. PARAMJEET SINGH,SIRSA vs. PCIT, ROHTAK

In the result, all the above appeals filed by the respective assessee’s are dismissed

ITA 290/CHANDI/2023[2018-19]Status: DisposedITAT Chandigarh24 Feb 2026AY 2018-19

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

Section 143(3)Section 263

u/s 263 of the Act it is noted as under: “5.1. I have carefully examined the facts of the case and It is evident that the assessee has received interest on enhanced compensation during the assessment year under consideration which ought to be treated as "income from other sources" and should have been taxed accordingly, under the head "income from

3I INFOTECH LIMITED,MUMBAI vs. PR. CIT- 15, MUMBAI

In the result, appeal of the assessee is allowed

ITA 3705/MUM/2019[2013-14]Status: DisposedITAT Mumbai10 May 2023AY 2013-14

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm 3I Infotech Limited Pcit-15 Tower No.5, 5Th Floor, Aaykar Bhavan, 3Rd To 6Th Floors, Vs. International Infotech Park, Mumbai-400 020 Vashi, Navi Mumbai-400 703 (Appellant) (Respondent) Pan No. Aaaci5205Q Assessee By : Shri Bhupendra Karkhanis, Shri Jay Dharod, Ars Revenue By : Ms. Samruddhi Hande, Dr Date Of Hearing: 17.02.203 Date Of Pronouncement : 10.05.2023

For Appellant: Shri Bhupendra KarkhanisFor Respondent: Ms. Samruddhi Hande, DR
Section 143(3)Section 144C(3)Section 263Section 263(1)

Transfer Pricing Order. 2. Without prejudice to the above, the Id. Pr. Commissioner of Income Tax erred in passing revision order u/s. 263

RIVET ELECTRICAL PVT LTD,FARIDABAD vs. PR. CIT, FARIDABAD

In the result, the appeal of the assessee is allowed

ITA 6225/DEL/2019[2014-15]Status: DisposedITAT Delhi15 Nov 2022AY 2014-15

Bench: Shri Kul Bharat & Shri Pradip Kumar Kedia[Assessment Year : 2014-15] Rivet Electrical Pvt.Ltd., Vs Pr.Cit, Ff-9, Vishnu Place, Faridabad, Near Neelam Flyover, Sec-20B, Haryana. Faridabad, Haryana-121002. Pan-Aafcr8803C Appellant Respondent Appellant By Shri Rajeev Saxena, Adv., Ms. Sumangl Saxena, Adv. & Shri Sahyamsunder, Adv. Respondent By Shri Anuj Garg, Sr.Dr Date Of Hearing 12.10.2022 Date Of Pronouncement 15.11.2022

Section 133(6)Section 142(1)Section 143(2)Section 143(3)Section 263

price of Rs. 80/- including share premium of Rs. 70/- per share to the following investors: M/s Best Buildmart (P) Ltd., M/s Goodluck Industries Ltd., M/s Metalcity Construction Kovai (P) Ltd., M/s Radha Ballabh Nest Build (P) Ltd, M/s Texcity Constructions Kovai (P) Ltd. 4. Due to unfavourable market conditions, the assessee company could not start its business activities. During