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5,135 results for “transfer pricing”+ Section 28clear

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Key Topics

Addition to Income82Search & Seizure35Deduction35Section 143(3)34Section 153C34Section 13234Section 6931Section 139(1)31Disallowance28Section 69B

COMMISSIONER OF INCOME TAX vs. AMADEUS INDIA PVT LTD

Appeal is dismissed

ITA/938/2011HC Delhi28 Nov 2011
For Appellant: Ms Suruchi AggarwalFor Respondent: Mr M.S. Syali, Sr. Advocate with Mr Mayank Nagi &
Section 144CSection 260ASection 92BSection 92CSection 92E

Transfer Pricing Officer could not take cognizance suo moto of any international transaction for adjustment in the arm’s length price under Section 2011:DHC:6027-DB ITA 938/11 Page 20 of 20 92C of the Income-tax Act, 1961. As a consequence, the revenue’s appeal is dismissed. There shall be no order as to costs. BADAR DURREZ AHMED

THE COMMISSIONER OF INCOME TAX V vs. NAGESH KNITWEARS P. LTD.

Showing 1–20 of 5,135 · Page 1 of 257

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16
Section 115J16
Section 14A12
ITA/591/2008HC Delhi01 Jun 2012
Section 260ASection 28Section 5Section 80H

transfer of Duty Free Replenishment Certificate, being the Duty Remission Scheme, under the export and import policy formulated and announced under section 5 of the Foreign Trade (Development and Regulation) Act, 1992 (22 of 1992);” 4. Sub-Section (3) of Section 80HHC and the Explanation (baa) read as under : “Section 80HHC- Deduction in respect of profits retained for export business

(Now known as Sony India Limited)

ITA/16/2014HC Delhi16 Mar 2015

Sections (1) and (2) to Section 92C are applicable to the assessed, as well as the Assessing Officer invoking power under Sub-Section (3) to Section 92C of the Act. As noted above, sub-section (2) to Section 92C stipulates that most appropriate method, out of the methods specified in sub-section (1) shall be applied to determine

PUBLICIS COMMUNICATIONS P. LTD,MUMBAI vs. DCIT CIR 7(3)(1), MUMBAI

In the result, for assessment year 2012 – 13, appeal of the assessee is allowed for statistical purposes whereas the cross objection of the assessing officer is dismissed

ITA 462/MUM/2016[2011-12]Status: DisposedITAT Mumbai27 Apr 2023AY 2011-12

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

For Appellant: Shri Ketan VedFor Respondent: Shri Asif Karmali
Section 143(3)Section 144C(13)Section 144C(5)Section 32(1)(ii)Section 92C

section 92CA (3) of the act wherein the learned transfer pricing officer has proposed the adjustment of ₹ 9,481,275/– with respect to the availing of services from its associated enterprises which was scaled down to ₹ 6,278,920/– as per the direction of the learned dispute resolution panel recomputed by the learned transfer pricing officer. The learned AO further

PUBLICS COMMUNICATIONS P.LTD,MUMBAI vs. DCIT CIR 6(1), MUMBAI

In the result, for assessment year 2012 – 13, appeal of the assessee is allowed for statistical purposes whereas the cross objection of the assessing officer is dismissed

ITA 7523/MUM/2016[2010-11]Status: DisposedITAT Mumbai27 Apr 2023AY 2010-11

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

For Appellant: Shri Ketan VedFor Respondent: Shri Asif Karmali
Section 143(3)Section 144C(13)Section 144C(5)Section 32(1)(ii)Section 92C

section 92CA (3) of the act wherein the learned transfer pricing officer has proposed the adjustment of ₹ 9,481,275/– with respect to the availing of services from its associated enterprises which was scaled down to ₹ 6,278,920/– as per the direction of the learned dispute resolution panel recomputed by the learned transfer pricing officer. The learned AO further

PUBLICIS COMMUNICATIONS P.LTD,MUMBAI vs. DCIT CIR 7(1), MUMBAI

In the result, for assessment year 2012 – 13, appeal of the assessee is allowed for statistical purposes whereas the cross objection of the assessing officer is dismissed

ITA 1994/MUM/2014[2009-10]Status: DisposedITAT Mumbai27 Apr 2023AY 2009-10

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

For Appellant: Shri Ketan VedFor Respondent: Shri Asif Karmali
Section 143(3)Section 144C(13)Section 144C(5)Section 32(1)(ii)Section 92C

section 92CA (3) of the act wherein the learned transfer pricing officer has proposed the adjustment of ₹ 9,481,275/– with respect to the availing of services from its associated enterprises which was scaled down to ₹ 6,278,920/– as per the direction of the learned dispute resolution panel recomputed by the learned transfer pricing officer. The learned AO further

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

28 days January = 2 days 7 Transfer Pricing Order u/s 92CA(3) of the Act 29.01.2013 Ought to be passed on/or before 8 Date on which Transfer Pricing Order u/s 92CA(3) is passed 30.01.2013 9 Date on which Final Assessment order was passed 26.04.2013 4. According to Sr. Counsel, as per the Section

SMT. SHANKRI DEVI,PANCHKULA vs. ACIT, PANCKULA CIRCLE, PANCHKULA

ITA 596/CHANDI/2022[2013-14]Status: DisposedITAT Chandigarh11 Nov 2025AY 2013-14

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

For Appellant: Shri Suraj Bhan Nain, AdvocateFor Respondent: Shri Manav Bansal, CIT, DR

Section 16 or Section 17 of the Act. We, therefore, hold that the statutory interest paid under Section 34 of the Act is interest paid for the delayed payment of the compensation amount and, therefore, is a revenue receipt liable to tax under the Income Tax Act." 9. This position of law has been consistently reiterated by this Court

INCOME TAX OFFICER, FATEHABAD vs. MAHESH NAGPAL, FATEHABAD

ITA 531/CHANDI/2024[2018-19]Status: DisposedITAT Chandigarh11 Nov 2025AY 2018-19

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

For Appellant: Shri Suraj Bhan Nain, AdvocateFor Respondent: Shri Manav Bansal, CIT, DR

Section 16 or Section 17 of the Act. We, therefore, hold that the statutory interest paid under Section 34 of the Act is interest paid for the delayed payment of the compensation amount and, therefore, is a revenue receipt liable to tax under the Income Tax Act." 9. This position of law has been consistently reiterated by this Court

SH. AMARDEEP SINGH ATHWAL,YAMUNANAGAR vs. ITO, WARD-1, YAMUNANAGAR

ITA 566/CHANDI/2023[2015-16]Status: DisposedITAT Chandigarh11 Nov 2025AY 2015-16

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

For Appellant: Shri Suraj Bhan Nain, AdvocateFor Respondent: Shri Manav Bansal, CIT, DR

Section 16 or Section 17 of the Act. We, therefore, hold that the statutory interest paid under Section 34 of the Act is interest paid for the delayed payment of the compensation amount and, therefore, is a revenue receipt liable to tax under the Income Tax Act." 9. This position of law has been consistently reiterated by this Court

BALBIR KUMAR HUF,CHANDIGARH vs. ITO , CHANDIGARH

ITA 172/CHANDI/2024[2017-18]Status: DisposedITAT Chandigarh11 Nov 2025AY 2017-18

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

For Appellant: Shri Suraj Bhan Nain, AdvocateFor Respondent: Shri Manav Bansal, CIT, DR

Section 16 or Section 17 of the Act. We, therefore, hold that the statutory interest paid under Section 34 of the Act is interest paid for the delayed payment of the compensation amount and, therefore, is a revenue receipt liable to tax under the Income Tax Act." 9. This position of law has been consistently reiterated by this Court

PAWAN KUMAR,FATEHABAD vs. INCOME TAX OFFICER WARD-1, FATEHABAD

ITA 1112/CHANDI/2024[2018-19]Status: DisposedITAT Chandigarh11 Nov 2025AY 2018-19

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

For Appellant: Shri Suraj Bhan Nain, AdvocateFor Respondent: Shri Manav Bansal, CIT, DR

Section 16 or Section 17 of the Act. We, therefore, hold that the statutory interest paid under Section 34 of the Act is interest paid for the delayed payment of the compensation amount and, therefore, is a revenue receipt liable to tax under the Income Tax Act." 9. This position of law has been consistently reiterated by this Court

SAROJ CHAUDHARY BALA,PANCHKULA vs. ITO, WARD-4, PANCHKULA

ITA 635/CHANDI/2022[2017-18]Status: DisposedITAT Chandigarh11 Nov 2025AY 2017-18

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

For Appellant: Shri Suraj Bhan Nain, AdvocateFor Respondent: Shri Manav Bansal, CIT, DR

Section 16 or Section 17 of the Act. We, therefore, hold that the statutory interest paid under Section 34 of the Act is interest paid for the delayed payment of the compensation amount and, therefore, is a revenue receipt liable to tax under the Income Tax Act." 9. This position of law has been consistently reiterated by this Court

SH. AMARDEEP SINGH ATHWAL,YAMUNANAGAR vs. ITO, WARD-1, YAMUNANAGAR

ITA 565/CHANDI/2023[2014-15]Status: DisposedITAT Chandigarh11 Nov 2025AY 2014-15

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

For Appellant: Shri Suraj Bhan Nain, AdvocateFor Respondent: Shri Manav Bansal, CIT, DR

Section 16 or Section 17 of the Act. We, therefore, hold that the statutory interest paid under Section 34 of the Act is interest paid for the delayed payment of the compensation amount and, therefore, is a revenue receipt liable to tax under the Income Tax Act." 9. This position of law has been consistently reiterated by this Court

ARJESH KUMAR,PATIALA vs. ITO NATIONAL E-ASSESSMENT CENTRE , DELHI

ITA 876/CHANDI/2024[2018-19]Status: DisposedITAT Chandigarh11 Nov 2025AY 2018-19
For Appellant: Shri Suraj Bhan Nain, AdvocateFor Respondent: Shri Manav Bansal, CIT, DR

Section 16 or Section 17 of the Act. We, therefore, hold that the statutory interest paid under Section 34 of the Act is interest paid for the delayed payment of the compensation amount and, therefore, is a revenue receipt liable to tax under the Income Tax Act." 9. This position of law has been consistently reiterated by this Court

RANJIT SINGH,PANCHKULA vs. DEPUTY DIRECTOR, CPC DEPARTMENT

ITA 992/CHANDI/2025[2023-24]Status: DisposedITAT Chandigarh11 Nov 2025AY 2023-24

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

For Appellant: Shri Suraj Bhan Nain, AdvocateFor Respondent: Shri Manav Bansal, CIT, DR

Section 16 or Section 17 of the Act. We, therefore, hold that the statutory interest paid under Section 34 of the Act is interest paid for the delayed payment of the compensation amount and, therefore, is a revenue receipt liable to tax under the Income Tax Act." 9. This position of law has been consistently reiterated by this Court

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

section 31 March 2013 153 of the Act for AY 2009-10 Transfer Pricing Order due date: Number of Days in 30 March 2013 (At least sixty days before the Number of Days in 28

DCIT, CIRCLE-1(1), HYDERABAD, HYDERABAD vs. PRAKASH NIMMAGADDA, HYDERABAD, SECUNDERABAD

In the result, appeal filed by the Revenue is dismissed

ITA 974/HYD/2017[2008-09]Status: DisposedITAT Hyderabad16 Dec 2024AY 2008-09

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha, G.आ.अपी.सं /Ita No.974/Hyd/2017 (िनधा"रण वष"/Assessment Year: 2008-09) Dy.Cit Vs. Shri Prakash Nimmagadda Circle 1(1) Hyderabad Hyderabad Pan:Acbpn4246R (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri K.C. Devdas, Ca राज" व "ारा/Revenue By:: Dr. Meghnath Chowhan, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 06/11/2024 घोषणा की तारीख/Pronouncement: 16/12/2024 आदेश/Order Per Vijay Pal Raothis Appeal Filed By The Revenue Is Directed Against The Order, Dated 20/03/2017 Of The Learned Cit (A)-9, Hyderabad, Relating To A.Y.2008-09. 2. The Revenue Has Raised The Following Grounds:

For Appellant: Shri K.C. Devdas, CAFor Respondent: : Dr. Meghnath Chowhan, CIT(DR)
Section 17(2)(c)Section 28

transfer of a capital asset to income-tax. The asset must be one which falls within the contemplation of the section. It must bear that quality which brings section 45 into play. To determine whether the goodwill of a new business is such an asset, it is permissible, as we shall presently show, to refer to certain other section

HARMALA,CHANDIGARH vs. ITO, WARD 1(1), NANGAL

ITA 432/CHANDI/2022[2015-16]Status: DisposedITAT Chandigarh11 Nov 2025AY 2015-16

Section 16 or Section 17 of the Act. We, therefore, hold that the\nstatutory interest paid under Section 34 of the Act is interest paid for the\ndelayed payment of the compensation amount and, therefore, is a revenue\nreceipt liable to tax under the Income Tax Act.\"\n9. This position of law has been consistently reiterated by this Court

KAKA SINGH ALIAS GULJAR SINGH,PATIALA vs. INCOME TAX OFFICER , PATIALA

ITA 663/CHANDI/2024[2020-21]Status: DisposedITAT Chandigarh11 Nov 2025AY 2020-21
For Respondent: \nShri Suraj Bhan Nain, Advocate

section 57.\nThe said provision reads thus:\n\"57. Deductions.-The income chargeable under the head 'Income from other\nsources' shall be computed after making the following deductions, namely :.\n(iv) in the case of income of the nature referred to in clause (viii) of sub-\nsection (2) of section 56, a deduction of a sum equal to fifty