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1,836 results for “transfer pricing”+ Unexplained Investmentclear

Sorted by relevance

Mumbai457Delhi325Hyderabad144Jaipur134Chennai103Bangalore87Cochin81Chandigarh70Indore60Ahmedabad60Rajkot52Kolkata47Nagpur35Surat29Guwahati21Agra20Amritsar20Pune19Visakhapatnam16Jodhpur15Cuttack11Raipur11Lucknow9Patna5Allahabad2Jabalpur2Varanasi1

Key Topics

Addition to Income75Search & Seizure46Section 13244Section 6841Section 6938Section 153C31Section 143(3)31Section 139(1)30Section 10(38)28Survey u/s 133A

THOMAS COOK (INDIA) LTD.,MUMBAI vs. ADDL/ JT/ DY/CIT/ASSTT/ITO, NATIONAL E-ASSESSMENT CENTRE, DELHI

In the result, appeal filed by the assessee is partly allowed

ITA 1218/MUM/2021[2016-17]Status: DisposedITAT Mumbai24 Nov 2023AY 2016-17

Bench: Shri S. Rifaur Rahman, Hon'Ble & Ms. Kavitha Rajagopal, Hon'Ble

Section 92CSection 92C(3)

price at which the shares are issued to the employees in order to compensate the payout obligation which might arise on ESOP shares either at buyback or at liquidation. 9.10 Allowability of ESOP expense in the income Tax Act- There is no specific section under which ESOP expenditure is allowable under the Income Tax Act 1961 ('Act). The only provision

MUJMMEEL ,KOTA vs. ACIT-CENTRAL CIRCLE , KOTA

In the result, appeal of the assessee is allowed

ITA 620/JPR/2024[2020-21]Status: DisposedITAT Jaipur

Showing 1–20 of 1,836 · Page 1 of 92

...
22
Section 14819
Long Term Capital Gains16
14 Feb 2025
AY 2020-21

Bench: SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: Miss. Swatika Jha, AdvFor Respondent: Ms. Alka Gautam, CIT a
Section 115BSection 133ASection 139Section 143(2)Section 143(3)Section 263Section 69Section 69A

unexplained investments lead to unwarranted litigation and harassment of the assessee-appellant. 43. That it is trite that the exercise of power u/s. 263 of the Act is ousted in case of a debatable issue. An assessment order can be termed as erroneous and prejudicial to the interest of the Revenue, if the Assessing Officer has taken a view which

NASSER AZIZ AN, B'LORE,BANGALORE vs. DCIT, CENTRAL CIRCLE 3, HYDERABAD, HYDERABAD

In the result, ITA.No.486/Hyd

ITA 373/HYD/2016[2007-08]Status: DisposedITAT Hyderabad24 Mar 2025AY 2007-08

Bench: Shri Manjunatha G & Shri K. Narasimha Chary

For Appellant: CA K C DevdasFor Respondent: Shri B Bala Krishna, CIT-DR
Section 127Section 132Section 143(2)Section 143(3)Section 153A

transferring the case of M/s. 5 ITA.Nos.373, 374 & 486/Hyd./2016 Span Design and Development Private Limited to ACIT, Central Circle-3, Hyderabad and the Hon’ble High Court of Karnataka vide it’s interim order dated 29.11.2010 in WP.No.6452/2010 directed the Assessing Officer that any order passed by the assessing authority shall be subject to the outcome

DCIT,CENTRAL CIRCLE-2(1), HYD, HYDERABAD vs. ALIYA NASSER AZIZ (LATE) L/R NASSER AZIZ, B'LORE, BANGALORE

In the result, ITA.No.486/Hyd

ITA 486/HYD/2016[2009-10]Status: DisposedITAT Hyderabad24 Mar 2025AY 2009-10

Bench: Shri Manjunatha G & Shri K. Narasimha Chary

For Appellant: CA K C DevdasFor Respondent: Shri B Bala Krishna, CIT-DR
Section 127Section 132Section 143(2)Section 143(3)Section 153A

transferring the case of M/s. 5 ITA.Nos.373, 374 & 486/Hyd./2016 Span Design and Development Private Limited to ACIT, Central Circle-3, Hyderabad and the Hon’ble High Court of Karnataka vide it’s interim order dated 29.11.2010 in WP.No.6452/2010 directed the Assessing Officer that any order passed by the assessing authority shall be subject to the outcome

NASSER AZIZ AN, B'LORE,BANGALORE vs. DCIT, CENTRAL CIRCLE 3, HYDERABAD, HYDERABAD

In the result, ITA.No.486/Hyd

ITA 374/HYD/2016[2009-10]Status: DisposedITAT Hyderabad24 Mar 2025AY 2009-10

Bench: Shri Manjunatha G & Shri K. Narasimha Chary

For Appellant: CA K C DevdasFor Respondent: Shri B Bala Krishna, CIT-DR
Section 127Section 132Section 143(2)Section 143(3)Section 153A

transferring the case of M/s. 5 ITA.Nos.373, 374 & 486/Hyd./2016 Span Design and Development Private Limited to ACIT, Central Circle-3, Hyderabad and the Hon’ble High Court of Karnataka vide it’s interim order dated 29.11.2010 in WP.No.6452/2010 directed the Assessing Officer that any order passed by the assessing authority shall be subject to the outcome

JAGDISH KUMAR ARORA,BHAWANIMANDI vs. DCIT, CENTRAL CIRCLE- KOTA, KOTA

In the result, the appeal of the assessee is allowed

ITA 1195/JPR/2024[2017-18]Status: DisposedITAT Jaipur11 Feb 2025AY 2017-18

Bench: SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: Sh. Shrawan Kumar Gupta, AdvFor Respondent: Mrs. Anita Rinesh, JCIT-Sr. DR
Section 115BSection 143(3)Section 145(3)Section 234ASection 69

transfer of cash to such unexplained advances. If the undisclosed income earned and accumulated over the years is taxed in the year in which it is detected by the Revenue and the same is merely taxed as per normal provisions of the law such an interpretation will place a premium on dishonesty i.e. it tantamounts to rewarding the dishonesty. There

DCIT CC 7(4), MUMBAI vs. PODDAR RENAISSANCE REALITY PVT LTD (NOW KNOWN AS IMPERIAL RENAISSAICE RENIASANCE REALITY PVT. LTD), MUMBAI

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

ITA 2045/MUM/2019[2012-13]Status: DisposedITAT Mumbai20 Dec 2024AY 2012-13

Bench: Shri Om Prakash Kant & Shri Sandeep Singh Karhaildcit, Cc-7(4), Mumbai V/S. Poddar Renaissance Reality Room No. 659, Aaykar बनाम Pvt. Ltd. (Now Known As Bhavan, M.K. Road, Imperial Renaissance Mumbai-400020 Renaissance Reality Pvt. Ltd.) 501/601, Aqua Marine, Carter Road, Mumbai-400050030 "थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aagcp2657R Appellant/अपीलाथ" .. Respondent/"ितवादी

For Appellant: Mr. Rishabh MehtaFor Respondent: Mr. R. A. Dhyani
Section 143Section 143(3)Section 68Section 69

unexplained investment and undisclosed income on substantive basis. The on substantive basis. The same addition has been made made on protective basis in the hand s of the assessee in the hand s of the assessee as those flats were purchased in the name of the assessee entity. as those flats were purchased in the name of the assessee entity

SHREE CEMENT LIMITED,BEAWAR vs. NATIONAL FACELESS ASSESSMENT ASSESSMENT CENTRE, DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2, AJMER, AJMER

ITA 497/JPR/2023[2017-18]Status: DisposedITAT Jaipur21 Feb 2024AY 2017-18
Section 115JSection 143Section 143(3)Section 144B(1)(xvi)Section 80Section 80I

transfer power directly to the ultimate industrial consumer i.e. the manufacturing units of assessee.\n30.13. Further, the aspect as to why rate at which power is sold to 3rd parties including Power distribution companies should not be considered as internal CUP and hence considered for computing arm's length price under the Transfer Pricing regulations, needs to be dealt with

SHREE CEMENT LIMITED,BEAWAR vs. NATIONAL FACELESS ASSESSMENT CENTRE, DELHI

In the result, the appeal of the Revenue in ITA No

ITA 500/JPR/2023[215-16]Status: DisposedITAT Jaipur21 Feb 2024

Bench: or at the time of hearing of this appeal.

For Appellant: Sh. Dilip B Desai(C.A.)For Respondent: Sh. Alka Gautam (CIT) (V.H) &
Section 115JSection 143Section 143(3)Section 144BSection 144B(1)(xvi)Section 80Section 80I

Transfer Price of Power for the purpose of Deduction u/s 80-IA in respect to its eligible power undertakings. 4. That on the facts and in the circumstances of the case, the Ld. CIT(Appeals) erred in restricting the claim of deduction u/s 80-IA on account of Solid Waste Management System upto the amount as claimed in the return

SHREE CEMENT LIMITED,BEAWAR vs. NATIONAL FACELESS ASSESSMENT CENTRE, DEPUTY COMMISSIONEROF INCOME TAX, CIRCLE -2, AJMER, AJMER

In the result, the appeal of the Revenue in ITA No

ITA 496/JPR/2023[2016-17]Status: DisposedITAT Jaipur21 Feb 2024AY 2016-17

Bench: or at the time of hearing of this appeal.

For Appellant: Sh. Dilip B Desai(C.A.)For Respondent: Sh. Alka Gautam (CIT) (V.H) &
Section 115JSection 143Section 143(3)Section 144BSection 144B(1)(xvi)Section 80Section 80I

Transfer Price of Power for the purpose of Deduction u/s 80-IA in respect to its eligible power undertakings. 4. That on the facts and in the circumstances of the case, the Ld. CIT(Appeals) erred in restricting the claim of deduction u/s 80-IA on account of Solid Waste Management System upto the amount as claimed in the return

GROWMORE RESEARCH AND ASSETS MANAGEMENT ,MUMBAI vs. DCIT, CC-4(1) (ERSTWHILE DCIT-31, MUMBAI

In the result, both the appeals are treated as partly allowed

ITA 453/MUM/2023[1992-93]Status: DisposedITAT Mumbai21 Jan 2025AY 1992-93

Bench: Shri B.R. Baskaran & Shri Anikesh Banerjee

For Appellant: Shri Vijay Mehta and ShriDharmeshFor Respondent: Dr.P. Daniel – Spl. Counsel
Section 144

price as on 31-03-1992. Hence, we are of the view that there may be error in mentioning the name of the company. Since no detail was produced by the revenue also, we deem it proper to restore this addition to the file of the AO with the direction to furnish the material relating to the addition

LANXES INDIA P.LTD,THANE vs. ASST CIT CIR 1, THANE

In the result, both the appeals are treated as partly allowed

ITA 1125/MUM/2017[2012-13]Status: DisposedITAT Mumbai01 Jan 2025AY 2012-13

Bench: Shri B.R. Baskaran & Shri Anikesh Banerjee

For Appellant: Shri Vijay Mehta and ShriDharmeshFor Respondent: Dr.P. Daniel – Spl. Counsel
Section 144

price as on 31-03-1992. Hence, we are of the view that there may be error in mentioning the name of the company. Since no detail was produced by the revenue also, we deem it proper to restore this addition to the file of the AO with the direction to furnish the material relating to the addition

DY. COMMISSIONER OF INCOME TAX, CC-4(3) CENTRAL RANGE-4 , MUMBAI vs. M/S GROWMORE RESEARCH AND ASSETS MANAGEMENT LIMITED, MUMBAI

In the result, both the appeals are treated as partly allowed

ITA 1125/MUM/2023[1992-93]Status: DisposedITAT Mumbai21 Jan 2025AY 1992-93
For Appellant: Shri Vijay Mehta and ShriDharmesh ShahFor Respondent: Dr.P. Daniel – Spl. Counsel
Section 144

unexplained investment u/s.69 of the Act.\n\n19. 2. Before the Ld.CIT(A), the assessee contended thatthe AO has not given details of shares, viz., the name of the holders, the place wherefrom they were seized etc. It also submitted that the AO did not allow inspection of the shares seized by the department. It submitted that the registered shares

KANTAR ANALYTICS INDIA PRIVATE LIMITED (FORMERLY KNOWN AS FIREFLY MARKET RESERCH INDIA PRIVATE LIMITED (SUCCESSOR OF ANALYTICS QUOTIENT SERVICE INDIA PRIVATE LIMITED),MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE 1(3)(1), MUMBAI

In the result the appeal filed by the assessee stands allowed

ITA 4733/MUM/2024[2020-21]Status: DisposedITAT Mumbai24 Nov 2025AY 2020-21
Section 143(3)Section 153Section 270ASection 92CSection 92C(1)

investment or to facilitate compliance with\nreporting, legal, or regulatory requirements of the ultimate parent or;\nb) May be duplicative in nature or otherwise do not constitute a benefit\n7.4\nAllocation methodology\nThe service fee is arrived at based on AQ India's share of total net sales achieved relative to\nworldwide net sales in that calendar year.\nMark

ASSISSTANT COMMISSIONER OF INCOME TAX, AJMER vs. SHREE CEMENT LTD, BEAWAR

ITA 489/JPR/2023[2015-16]Status: DisposedITAT Jaipur21 Feb 2024AY 2015-16
For Appellant: Sh. Dilip B Desai(C.A.)For Respondent: Sh. Alka Gautam (CIT) (V.H) &
Section 115JSection 143Section 143(3)Section 144B(1)(xvi)Section 80Section 80I

price for the\npurpose of Section 80A(6) of the Act.\n30.11. The ld. D/R in his submissions relied strongly on the order\nof TPO and the method adopted by TPO for determining market\nrate of power. According to ld. D/R, TPO has adopted the rate of\npower at which Distribution companies purchase power from the\nGenerating companies. We find

JATIN GARG,CHANDIGARH vs. ASSTT. COMMISSIONER OF INCOME TAX, CC-2,, CHANDIGARH

In the result, the appeal of the assessee is allowed

ITA 1019/CHANDI/2024[2018-19]Status: DisposedITAT Chandigarh12 Feb 2025AY 2018-19

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 132(1)Section 139(1)Section 142(1)Section 143(2)Section 69

transferred to Sh. Sahil Singla. During assessment proceedings and search operation in the cases of Sh. Sanjit Singh Randhawa and Sh. Sahil Singla, it was held that Sh. Sanjit Singh Randhawa and Sh. Sahil Singla invested the money taken from different person, into Sand Mining business. The entire modus operandi was designed in a such away so that Sh. Sahil

DEPUTY COMMISSIONER OF INCOME-TAX,CENTRAL CIRCLE-1, SURAT, AAYAKAR BHAWAN, MAJURA GATE, SURAT vs. ROYAL DEVELOPERS, NR. IP MISSION SCHOOL, MUGLISA

In the result, the appeal of the Revenue is allowed for statistical purposes

ITA 860/SRT/2024[2018-19]Status: DisposedITAT Surat23 Dec 2025AY 2018-19
For Appellant: Mr. Suresh K KabraFor Respondent: Shri Ajay Uke, Sr. DR
Section 143(3)Section 56(2)(x)Section 69Section 69A

unexplained investment in the land in excess of the price mentioned in the purchase documents and, therefore, there no reason to interfere with the order of the CIT(A). The copy of the Order is enclosed herewith at Pg # 147-154 of PB. Considering the above facts of the matter, the addition made u/s 69 considering the payment of Land

DCIT CC 3(4) CEN RG 3, MUMBAI vs. PATEL ENGINEERING LTD, MUMBAI

In the result, appeal filed by the assessee is dismissed

ITA 2485/MUM/2017[2006-07]Status: DisposedITAT Mumbai07 Jul 2023AY 2006-07

Bench: Shri Aby T. Varkey, Hon'Ble & Shri S. Rifaur Rahman, Hon’Ble

Section 14ASection 154Section 199(2)Section 80I

price and the book value of share, this ground is similar to Ground No. 4 of grounds of appeal raised by the revenue for the A.Y. 2006-07 and the decision taken therein shall apply mutatis-mutandis to the appeal for the A.Y. 2007-08. We order accordingly. 42. With regard to Ground No. 8 which is in respect

DCIT CC 3(4) CEN RG 3, MUMBAI vs. PATEL ENGINEERING LTD, MUMBAI

In the result, appeal filed by the assessee is dismissed

ITA 2486/MUM/2017[2007-08]Status: DisposedITAT Mumbai07 Jul 2023AY 2007-08

Bench: Shri Aby T. Varkey, Hon'Ble & Shri S. Rifaur Rahman, Hon’Ble

Section 14ASection 154Section 199(2)Section 80I

price and the book value of share, this ground is similar to Ground No. 4 of grounds of appeal raised by the revenue for the A.Y. 2006-07 and the decision taken therein shall apply mutatis-mutandis to the appeal for the A.Y. 2007-08. We order accordingly. 42. With regard to Ground No. 8 which is in respect

ASSISTANT COMMISSIONER OF INCOME TAX, NUNGAMBAKKAM vs. R K M POWERGEN PRIVATE LIMITED, T NAGAR

In the result the appeal of the revenue for the both the

ITA 800/CHNY/2023[2013-14]Status: DisposedITAT Chennai06 Nov 2024AY 2013-14
Section 56(1)

Investments, the shares should be issued to foreign investors only at a price equal to or higher of the value determined under the DCF method. The year wise details of the shares issued are given in the below table:\nName FY AY No.of Share Share\nof Party shares capital premium\nissued (Rs. in (Rs.in\ncrores) crores)\nMJC