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6,171 results for “transfer pricing”+ Section 143(3)clear

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Key Topics

Section 143(3)109Addition to Income78Section 92C45Transfer Pricing39Disallowance33Section 14A31Section 153A29Section 271(1)(c)26Section 69C24Section 263

BARMER LIGNITE MINING CO. LTD.,C-SCHEME, JAIPUR vs. DCIT, CIRCLE-6, JAIPUR

ITA 460/JPR/2023[2016-17]Status: DisposedITAT Jaipur16 Dec 2024AY 2016-17
Section 234ASection 250Section 94E

transferred, before the expiry of the period of ten years specified in sub-section (1),\nto another Indian company in a scheme of demerger, —\n(i) no deduction shall be admissible under sub-section (1) in the case of the demerged\ncompany for the previous year in which the demerger takes place; and\n(ii) the provisions of this section

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)

Showing 1–20 of 6,171 · Page 1 of 309

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23
Comparables/TP23
Section 143(2)22
Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 144BSection 144C(13)Section 153Section 92BSection 92C

143(3) read with Section 144C(13) read with Section 144B of the Income Tax Act, 1961 (hereinafter referred as to ‘the Act’) for Assessment Year 2016-17. 2. The maintainability of the very proceeding is under challenge before us to this effect that the Transfer Pricing

ESSEL MINING & INDUSTRIES LIMITED,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX - CENTRAL CIRCLE 1(4), MUMBAI

In the result, the appeal of the Revenue for assessment year the result, the appeal of the Revenue for assessment year the result, the appeal of the Revenue for assessment year

ITA 1020/MUM/2018[2011-12]Status: DisposedITAT Mumbai31 Jan 2023AY 2011-12

Bench: Shri Aby T Varkey () & Shri Om Prakash Kant () Assessment Year: 2011-12 & Assessment Year: 2012-13 Essel Mining & Industries Ltd., Dy. Cit, Central Circle-1(4), Industry House, 18Th Floor, 10, 9Th Floor, Old Cgo Building, Camac Street, Vs. Mk Road, Kolkata-700017. Mumbai-400020. Pan No. Aaace 6607 L Appellant Respondent Assessment Year: 2011-12 & Assessment Year: 2012-13 Jcit, Central Circle-1(4), M/S Essel Mining & Industries Room No. 902, Pratishtha Ltd., Bhavan, 9Th Floor, Old Cgo Vs. Industry House, 18Th Floor, 10, Building Annexe, Camac Street, Mumbai-400020. Kolkata-700017. Pan No. Aaace 6607 L Appellant Respondent Assessment Year: 2011-12 M/S Essel Mining & Industries Dy. Cit, Central Circle-1(4), Ltd., 9Th Floor, Old Cgo Building, Vs. Industry House, 18Th Floor, 10, Mk Road

For Appellant: Mr. Yogesh Thar/
Section 132(1)Section 153C

3, the Revenue is aggrieved with the deletion of In ground No. 3, the Revenue is aggrieved with the deletion of In ground No. 3, the Revenue is aggrieved with the deletion of disallowance of deduction u/s 80IA of the Act amounting to disallowance of deduction u/s 80IA of the Act amounting to disallowance of deduction u/s 80IA

ESSEL MINING & INDUSTRIES LIMITED,MUMBAI vs. DY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4), MUMBAI

In the result, the appeal of the Revenue for assessment year the result, the appeal of the Revenue for assessment year the result, the appeal of the Revenue for assessment year

ITA 1970/MUM/2022[2011-12]Status: DisposedITAT Mumbai31 Jan 2023AY 2011-12

Bench: Shri Aby T Varkey () & Shri Om Prakash Kant () Assessment Year: 2011-12 & Assessment Year: 2012-13 Essel Mining & Industries Ltd., Dy. Cit, Central Circle-1(4), Industry House, 18Th Floor, 10, 9Th Floor, Old Cgo Building, Camac Street, Vs. Mk Road, Kolkata-700017. Mumbai-400020. Pan No. Aaace 6607 L Appellant Respondent Assessment Year: 2011-12 & Assessment Year: 2012-13 Jcit, Central Circle-1(4), M/S Essel Mining & Industries Room No. 902, Pratishtha Ltd., Bhavan, 9Th Floor, Old Cgo Vs. Industry House, 18Th Floor, 10, Building Annexe, Camac Street, Mumbai-400020. Kolkata-700017. Pan No. Aaace 6607 L Appellant Respondent Assessment Year: 2011-12 M/S Essel Mining & Industries Dy. Cit, Central Circle-1(4), Ltd., 9Th Floor, Old Cgo Building, Vs. Industry House, 18Th Floor, 10, Mk Road

For Appellant: Mr. Yogesh Thar/
Section 132(1)Section 153C

3, the Revenue is aggrieved with the deletion of In ground No. 3, the Revenue is aggrieved with the deletion of In ground No. 3, the Revenue is aggrieved with the deletion of disallowance of deduction u/s 80IA of the Act amounting to disallowance of deduction u/s 80IA of the Act amounting to disallowance of deduction u/s 80IA

TATA AIG GENERAL INSURANCE COMAPANY LTD,MUMBAI vs. ASST CIT 2(3), MUMBAI

In the result, the appeal of the assessee is allowed

ITA 3512/MUM/2015[2009-10]Status: DisposedITAT Mumbai30 Jun 2023AY 2009-10
For Appellant: Shri Percy Pardiwala/Shri NishantFor Respondent: Shri Samuel Pitta (Sr. AR)
Section 143Section 143(3)Section 144Section 144C(3)Section 15Section 153Section 2Section 32Section 92C

143(3) read with section 144C(3) of the Income-tax Act, 1961 is void and bad in law as it has been passed beyond the period of limitation referred to in section 153 of the Act. Additional Ground No.3 3. The learned CIT(A) erred in confirming the action of the learned AO of not allowing the claim

DCIT, CIRCLE- 16(2), NEW DELHI vs. MENETA AUTOMOTIVE COMPONENTS PVT. LTD., NEW DELHI

In the result, the appeal of the Revenue is dismissed

ITA 1058/DEL/2018[2008-09]Status: DisposedITAT Delhi07 Feb 2023AY 2008-09

Bench: Dr. B. R. R. Kumarsh. Yogesh Kumar Us

For Appellant: Sh. G. C. Srivastava, Adv. &For Respondent: Sh. Bhagwati Charan, Sr. DR
Section 92C

3) of Section 92CA of the Act, the AO has to compute the total income of the assessee under sub-section (4) of Section 92C (read with sub-section (4) of Section 92CA) in conformity with the ALP so determined by the TPO. 6. Maintenance of Data Base It is to be ensured by the CIT (Transfer Pricing) that

COLGATE PALMOLIVE (INDIA) LTD,MUMBAI vs. ASST CIT CIR 15(1)(2), MUMBAI

Accordingly, number 75/M/2018 filed by the assessee for assessment year 2013 – 14 is allowed

ITA 75/MUM/2018[2013-14]Status: DisposedITAT Mumbai11 Apr 2023AY 2013-14

Bench: Shri Prashant Maharishi, Am & Shri Kuldip Singh, Jm

For Appellant: Shri Madhur AgrawalFor Respondent: Dr. Yogesh Kamat, CIT DR
Section 115JSection 143(3)Section 144CSection 14ASection 80ISection 92C

pricing officer for passing an order under section 92CA a further period available for completion of the assessment was to be extended by 12 months. Thus, the time limit for passing order under section 143 (3) was available up to 31/12/2016. According to the provisions of section 92CA (3A) the transfer

COLGATE PALMOLIVE (INDIA) LTD,MUMBAI vs. ASST CIT CIR 15(1)(2), MUMBAI

Accordingly, number 75/M/2018 filed by the assessee for assessment year 2013 – 14 is allowed

ITA 3488/MUM/2016[2011-12]Status: DisposedITAT Mumbai11 Apr 2023AY 2011-12

Bench: Shri Prashant Maharishi, Am & Shri Kuldip Singh, Jm

For Appellant: Shri Madhur AgrawalFor Respondent: Dr. Yogesh Kamat, CIT DR
Section 115JSection 143(3)Section 144CSection 14ASection 80ISection 92C

pricing officer for passing an order under section 92CA a further period available for completion of the assessment was to be extended by 12 months. Thus, the time limit for passing order under section 143 (3) was available up to 31/12/2016. According to the provisions of section 92CA (3A) the transfer

COLGATE -PALMOLIVE (INDIA) LTD,MUMBAI vs. ASST CIT CIR 15(1)(2), MUMBAI

Accordingly, number 75/M/2018 filed by the assessee for assessment year 2013 – 14 is allowed

ITA 1977/MUM/2017[2012-13]Status: DisposedITAT Mumbai11 Apr 2023AY 2012-13

Bench: Shri Prashant Maharishi, Am & Shri Kuldip Singh, Jm

For Appellant: Shri Madhur AgrawalFor Respondent: Dr. Yogesh Kamat, CIT DR
Section 115JSection 143(3)Section 144CSection 14ASection 80ISection 92C

pricing officer for passing an order under section 92CA a further period available for completion of the assessment was to be extended by 12 months. Thus, the time limit for passing order under section 143 (3) was available up to 31/12/2016. According to the provisions of section 92CA (3A) the transfer

DCIT 15(1)(2), MUMBAI vs. COLGATE PALMOLIVE (INDIA) LTD., MUMBAI

Accordingly, number 75/M/2018 filed by the assessee for assessment year 2013 – 14 is allowed

ITA 2799/MUM/2016[2011-12]Status: DisposedITAT Mumbai11 Apr 2023AY 2011-12

Bench: Shri Prashant Maharishi, Am & Shri Kuldip Singh, Jm

For Appellant: Shri Madhur AgrawalFor Respondent: Dr. Yogesh Kamat, CIT DR
Section 115JSection 143(3)Section 144CSection 14ASection 80ISection 92C

pricing officer for passing an order under section 92CA a further period available for completion of the assessment was to be extended by 12 months. Thus, the time limit for passing order under section 143 (3) was available up to 31/12/2016. According to the provisions of section 92CA (3A) the transfer

F5 NETWORKS INNOVATION PRIVATE LIMITED,HYDERABAD vs. INCOME TAX OFFICER, WARD-17(1), HYDERABAD

In the result, the appeal of the assessee is partly allowed for

ITA 912/HYD/2024[2020-21]Status: DisposedITAT Hyderabad30 Jun 2025AY 2020-21

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

For Appellant: Shri Sharath Rao & ShriFor Respondent: Shri Narender Kumar Naik
Section 143(1)Section 143(3)Section 92C

transfer pricing adjustment. He further submitted that, the assessee had entered into a Bilateral Advance Pricing Agreement (“BAPA”) u/s.92CC of the Act, which cover the assessment year under consideration and in the light of the BAPA, the assessee seeks the withdraw ground no.1. Accordingly, the Ld. AR invited our attention to the withdrawal request of ground no.1 placed at page

TOYOTA BOSHOKU AUTOMOTIVE INDIA PRIVATE LIMITED,BIDADI vs. ASSESSMENT UNIT, INCOME TAX DEPARTMENT OR THE DCIT, CIRCLE - 7(1)(1), KORAMANGALA

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

ITA 1539/BANG/2024[AY 2020-21]Status: DisposedITAT Bangalore09 May 2025

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri K.R Vasudevan, AdvocateFor Respondent: Ms. Neera Malhotra, CIT (DR)
Section 234ASection 270A

transfer pricing. In holding so, the learned DRP referred various case laws. 21. Being aggrieved by the order of the learned DRP/AO/TPO, the assessee is in appeal before us. 22. The learned AR before us argued that the TPO erred in benchmarking the outstanding receivables as a separate international transaction and proposing an adjustment

MARIE PRODUCTS PRIVATE LIMITED,JAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE 7, JAIPUR

In the result, the appeal of the assessee is partly allowed

ITA 771/JPR/2023[2018-19]Status: DisposedITAT Jaipur21 Apr 2025AY 2018-19

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Sh. P. C. Parwal, CAFor Respondent: Sh. Ajay Malik, CIT
Section 14Section 142(1)Section 143(3)

transferred under sub-section (8)], on or after the 1st day of April, 2021, shall be non est if such assessment is not made in accordance with the procedure laid down under this section." (emphasis supplied) 14. Keeping in view the aforesaid, this Court is of the opinion that learned counsel for the petitioner is correct in submitting that Section

DCIT(CC)-8(3), MUMBAI vs. SHAPOORJI PALLONI AND COMPANY PRIVATE LIMITED, MUMBAI

ITA 1217/MUM/2025[2013-14]Status: DisposedITAT Mumbai23 Jan 2026AY 2013-14
Section 143(3)Section 144C(3)Section 92Section 92B

143(3)", "Section 144C(3)", "Section 92B", "Section 35DD", "Section 43B", "Section 92CA(1)", "Section 115JB", "Section 153" ], "issues": "1. Whether the issuance of letters of comfort, financial guarantees, and performance guarantees by the assessee to its AEs constituted international transactions and whether the transfer pricing

SHAPOORJI PALLONJI AND COMPANY PRIVATE LIMITED ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE -3(3)(1), MUMBAI

Appeals are partly allowed

ITA 1150/MUM/2025[2012-13]Status: DisposedITAT Mumbai23 Jan 2026AY 2012-13

Bench: SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SHRI JAGADISH (Accountant Member)

For Appellant: Shri Rajan Vora, Shri Nikhil TiwariFor Respondent: Shri Ajay Chandra & Shri Pravin
Section 143(3)Section 144C(3)Section 92Section 92B

Pricing Addition. Since the Assessee preferred not to file any objections before the Dispute Resolution Panel, the Assessing Officer passed the Assessment Order, dated 20/04/2016 under Section 143(3) read with Section 144C(3) of the Act. After making the aforesaid Transfer

SHAPOORJI PALLONJI AND COMPANY PVT LTD,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 8(3), MUMBAI

Appeals are partly allowed

ITA 1149/MUM/2025[2013-14]Status: DisposedITAT Mumbai23 Jan 2026AY 2013-14

Bench: SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SHRI JAGADISH (Accountant Member)

For Appellant: Shri Rajan Vora, Shri Nikhil TiwariFor Respondent: Shri Ajay Chandra & Shri Pravin
Section 143(3)Section 144C(3)Section 92Section 92B

Pricing Addition. Since the Assessee preferred not to file any objections before the Dispute Resolution Panel, the Assessing Officer passed the Assessment Order, dated 20/04/2016 under Section 143(3) read with Section 144C(3) of the Act. After making the aforesaid Transfer

DCIT(CC)-8(3), MUMBAI vs. SHAPOORJI PALLONJI AND COMPANY PRIVATE LIMITED, MUMBAI

ITA 1211/MUM/2025[2012-13]Status: DisposedITAT Mumbai23 Jan 2026AY 2012-13
Section 143(3)Section 144C(3)Section 92Section 92B

Pricing Addition.\nSince the Assessee preferred not to file any objections before the\nDispute Resolution Panel, the Assessing Officer passed the\nAssessment Order, dated 20/04/2016 under Section 143(3) read\nwith Section 144C(3) of the Act. After making the aforesaid Transfer

M/S. ATUL PROJECTS INDIA PVT LTD.,,MUMBAI vs. DCIT- 9(1)(2), ( NOW JURIDICTION WITH DC CC-2(4), MUMBAI

ITA 1880/MUM/2023[2019-20]Status: DisposedITAT Mumbai27 Sept 2023AY 2019-20

Bench: Ms. Kavitha Rajagopal () & Ms. Padmavathy S. ()

Section 132Section 143(2)Section 14ASection 153CSection 37(1)Section 43CSection 69CSection 80I

143(3) of the Act dated 29.12.2016 did not allow the deduction claimed by the assessee under section 80IB(10) for Rs.86,30,612/- for the reason that –  The deduction was not claimed in the original return of income filed under section 139(1) and, therefore, not allowable as per provision of section 80AC;  Certain units are having the built

M/S. ATUL PROJECTS INDIA PVT LTD.,,MUMBAI vs. DCIT- 9(1)(2), ( NOW JURIDICTION WITH DC CC-2(4), MUMBAI

ITA 1876/MUM/2023[2015-16]Status: DisposedITAT Mumbai27 Sept 2023AY 2015-16

Bench: Ms. Kavitha Rajagopal () & Ms. Padmavathy S. ()

Section 132Section 143(2)Section 14ASection 153CSection 37(1)Section 43CSection 69CSection 80I

143(3) of the Act dated 29.12.2016 did not allow the deduction claimed by the assessee under section 80IB(10) for Rs.86,30,612/- for the reason that –  The deduction was not claimed in the original return of income filed under section 139(1) and, therefore, not allowable as per provision of section 80AC;  Certain units are having the built

M/S. ATUL PROJECTS INDIA PVT LTD.,,MIMBAI vs. DCIT- 9(1)(2), ( NOW JURIDICTION WITH DC CC-2(4), MUMBAI

ITA 1877/MUM/2023[2016-17]Status: DisposedITAT Mumbai27 Sept 2023AY 2016-17

Bench: Ms. Kavitha Rajagopal () & Ms. Padmavathy S. ()

Section 132Section 143(2)Section 14ASection 153CSection 37(1)Section 43CSection 69CSection 80I

143(3) of the Act dated 29.12.2016 did not allow the deduction claimed by the assessee under section 80IB(10) for Rs.86,30,612/- for the reason that –  The deduction was not claimed in the original return of income filed under section 139(1) and, therefore, not allowable as per provision of section 80AC;  Certain units are having the built