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3,231 results for “transfer pricing”+ Unexplained Investmentclear

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Mumbai753Delhi751Jaipur214Chennai173Kolkata166Hyderabad163Bangalore155Indore120Ahmedabad119Chandigarh99Cochin94Rajkot56Surat49Pune48Nagpur45Calcutta36Visakhapatnam28Amritsar27Cuttack25Agra24Guwahati23Jodhpur17Raipur14Lucknow11Patna5Karnataka4Allahabad3Jabalpur3Telangana2SC2Varanasi1Ranchi1

Key Topics

Section 143(3)107Addition to Income72Section 6838Section 143(2)32Section 69A29Section 14825Section 14720Section 10(38)20Section 153A18Survey u/s 133A

DCIT, CIRCLE - 11(1), KOLKATA, KOLKATA vs. M/S. J. J. EXPORTERS LTD., KOLKATA

ITA 1371/KOL/2017[2008-09]Status: DisposedITAT Kolkata19 Sept 2018AY 2008-09

Bench: Shri A. T. Varkey, Jm & Dr. A. L. Saini, Am]

Section 92C

unexplained investment deleted by the ld. CIT(A) admitting additional evidence. 4. We shall first take-up additions challenged on account of Transfer Pricing

DCIT, CIRCLE - 11(1), KOLKATA, KOLKATA vs. M/S. J. J. EXPORTERS LTD., KOLKATA

ITA 1372/KOL/2017[2009-10]Status: DisposedITAT Kolkata19 Sept 2018AY 2009-10

Bench: Shri A. T. Varkey, Jm & Dr. A. L. Saini, Am]

Section 92C

unexplained investment deleted by the ld. CIT(A) admitting additional evidence. 4. We shall first take-up additions challenged on account of Transfer Pricing

Showing 1–20 of 3,231 · Page 1 of 162

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16
Long Term Capital Gains16
Search & Seizure13

M/S INSTRUMENTARIUM CORPORATION LTD.,KOLKATA vs. DDIT (IT)-1(1), KOLKATA, KOLKATA

ITA 1549/KOL/2009[2004-05]Status: DisposedITAT Kolkata15 Jul 2016AY 2004-05

Bench: The Special Bench:

investment of the renderer. Moving on from the shareholder activity argument, learned counsel submits that it is not open to the Assessing Officer to question the commercial I.T.A. Nos.1548 and 1549/Kol/2009 Assessment years: 2003-04 and 2004-05 Page 35 of 41 expediency of a transaction. When in his wisdom the assessee has advanced an interest free loan, according

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 Jaipur14 Feb 2025AY 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 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

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

ABOTT HEALTHCARE P. LTD,MUMBAI vs. ITO WD 3(2)(1), MUMBAI

Accordingly, Ground No.2 raised by the Revenue is dismissed

ITA 535/MUM/2012[2007-08]Status: DisposedITAT Mumbai30 Jan 2019AY 2007-08

Bench: Shric.N.Prasad, Jm & Shrim.Balaganesh, Am

For Appellant: Shri Dhanesh Bafna / Ms.Chandini Shah / Shri Madhur AgrawalFor Respondent: Shri RakeshRanjan (DR)
Section 144C(5)Section 92C(2)

Transfer Pricing Adjustment in respect of these Central Services Charges are allowed for all the assessment years. CORPORATE TAX ISSUES ITA No.7595/Mum/2012 : Asst. Year 2008-2009 26. The Ground No.1 raised by the assessee is with regard to the action of the ld. DRP in upholding the disallowance made u/s 14A of the I.T.Act r.w.r.8D of I.T.Rules in the total

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 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

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

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 made u/s 92C of the Act, towards interest on loan to subsidiaries. The Ld. CIT(A) after considering the relevant facts has rightly deleted penalty levied by the A.O, and hence, we are inclined to uphold the findings of the Ld. CIT(A) and reject ground taken by the Revenue. 11. In the result, the appeal filed

R.SRINIVASAN,CHENNAI vs. DCIT CENTRAL CIRCLE 1, COIMBATORE

In the result, appeal filed by assessee is partly allowed

ITA 1466/CHNY/2018[1996-97]Status: DisposedITAT Chennai25 Feb 2021AY 1996-97

Bench: Shri V.Durga Rao & Shri G. Manjunathaआयकर अपीलसं./I.T.A.No.1466/Chny/2018 ("नधा"रणवष" / Assessment Year: 1996-97) Mr.R.Srinivasan Vs The Deputy Commissioner Of 103, Ashok Nagar Main Road Income Tax, Kodambakkam, Corporate Circle-I(2) Chennai-600 024. Chennai. Pan : Aaips 8386H (अपीलाथ"/Appellant) (""यथ"/Respondent)

Section 132

unexplained investment being the credits appearing in various benami accounts assessed in the hands of the appellant for the relevant previous year on protective basis. As explained earlier, TNIC was the agency through which the Tamilnadu Government was implementing a 24 welfare scheme for free distribution of sarees, dothis and school uniform to the poor and needy. The appellant

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

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 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

VAIBHAV GLOBAL LIMITED,JAIPUR vs. DCIT, CC-4, JAIPUR

In the result, the appeal of the assessee in ITA no

ITA 1144/JPR/2024[2020-21]Status: DisposedITAT Jaipur30 Jun 2025AY 2020-21
For Appellant: Shri Vinod Kumar Gupta, AdvFor Respondent: Shri Rajesh Ojha, CIT-DR
Section 115JSection 115QSection 143(3)Section 144C(5)Section 36(1)(va)

pricing, discounts, credit worthiness, number of years of relationship. Etc. and accordingly, it would not be feasible to consider a uniform credit period without taking into consideration the specific factors for the particular trade. - 2. In the instant case, the appellant has granted a credit period of up to 180 days to both AEs as well as third parties

M/S. UNITED SPIRITS LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, BANGALORE

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

ITA 489/BANG/2017[2012-13]Status: DisposedITAT Bangalore29 May 2020AY 2012-13

Bench: Shri B.R. Baskaran & Shri Pavan Kumar Gadaleit(Tp)A No.489/Bang/2017 (Assessment Year: 2012-13) M/S. United Spirits Limited, Ub Towers, No.24, Vittal Mallya Road, Bangalore-560 001 ….Appellant Vs. Dy. Commissioner Of Income Tax, Circle 7(1)(1), Bangalore. ……Respondent. Assessee By: Shri Perci Pardiwala, Senior Advocate & Shri Ketan Ved, C.A. Revenue By: Shri Bipin C.N, Jcit (D.R) Date Of Hearing : 06.03.2020. Date Of Pronouncement : 29.05.2020. O R D E R Per Shri B.R. Baskaran, A.M. : The Assessee Has Filed This Appeal Challenging The Assessment Order Dated 31-01-2017 Passed By The Assessing Officer For Assessment Year 2012-13 Passed U/S 143(3) R.W.S 144C(13) Of The Act.

For Appellant: Shri Perci Pardiwala, Senior Advocate and Shri Ketan Ved, C.AFor Respondent: Shri Bipin C.N, JCIT (D.R)
Section 143(3)Section 144C(10)Section 144C(13)Section 14ASection 154Section 36(1)(iii)Section 92C

unexplained reasons, the assessee has stopped charging interest in the assessment year 2003-04. The commercial bonafides of the present transactions are not established. As regards the assessee's claim that the revenue authorities have re- characterized the transaction, and that they do not have the powers to do so, we find that the claim of the assessee