SURESH MAL LODHA VS ACIT, CIRCLE-6, JAIPUR 1. Samson Maritime Ltd. v. CIT (Bombay High Court

258 ITR 593Supreme Court of India2013#11379 most cited
9

judgments rely on this decision, according to BharatTax’s citation analysis of 348,607 Indian tax judgments — from 2020 to 2025.

Sections most often in play

Section 10DSection 143(3)Section 271AASection 92CASection 92DSection 153ASection 271GSection 270A

Issues it is cited on

section 92d(3)section 92ca(2)section 271basection 271gsection 92fsection 92dtransfer pricing ordersection 92ca(1)specified domestic transactioncorporate guaranteearms length pricesection 271b

Judgments citing SURESH MAL LODHA VS ACIT, CIRCLE-6, JAIPUR 1. Samson Maritime Ltd. v. CIT (Bombay High Court

Deputy Commissioner of Income -Tax, Central Circle-1(1), Ahmedabad, Gujarat vs. Priya Blue Industries Pvt. Ltd., Gujarat

In the result the appeals filed by the Revenue in ITA No

ITA 324/AHD/2024[2019-20]Status: DisposedITAT Ahmedabad21 Jan 2025AY 2019-20

Bench: Shri T.R. SENTHIL KUMAR (Judicial Member), Shri Narendra Prasad Sinha (Accountant Member)

Section 132Section 143Section 143(3)Section 271ASection 92CSection 92D

…A.Y.2011-12, wherein it was held as under: 5. Before us. Learned DR look us the findings and observation of The AO and supported the order of AO Reliance was also placed on the decision of Hon'ble Apex Court in the case of Mak Data Pvt. Ltd reported in (2013)258 ITR 593 The Learned AR on the other hand submitted that penalty u/s 271AA was initiated and I.T.A Nos. 317 to 324/Ahd/2024 A.Ys. 2012-13 to 2019-20 Page No 8 Priya Blue Industries Pvt. Ltd. vs. DCIT levied on the total international transactions of Rs 26,41,92,634/-, comprising of loan advanced to AE amounting to Rs 25 crores and interest charged by the…

Deputy Commissioner of Income -Tax, Central Circle 1(1), Ahmedabad vs. Priya Blue Industries Pvt. Ltd, Gujarat

In the result the appeals filed by the Revenue in ITA No

ITA 323/AHD/2024[2018-19]Status: DisposedITAT Ahmedabad21 Jan 2025AY 2018-19

Bench: Shri T.R. SENTHIL KUMAR (Judicial Member), Shri Narendra Prasad Sinha (Accountant Member)

Section 132Section 143Section 143(3)Section 271ASection 92CSection 92D

…A.Y.2011-12, wherein it was held as under: 5. Before us. Learned DR look us the findings and observation of The AO and supported the order of AO Reliance was also placed on the decision of Hon'ble Apex Court in the case of Mak Data Pvt. Ltd reported in (2013)258 ITR 593 The Learned AR on the other hand submitted that penalty u/s 271AA was initiated and I.T.A Nos. 317 to 324/Ahd/2024 A.Ys. 2012-13 to 2019-20 Page No 8 Priya Blue Industries Pvt. Ltd. vs. DCIT levied on the total international transactions of Rs 26,41,92,634/-, comprising of loan advanced to AE amounting to Rs 25 crores and interest charged by the…

DCIT Central Circle 1(1), Ahmedabad, Gujarat vs. Priya Blue Industries Pvt. Ltd., Gujarat

In the result the appeals filed by the Revenue in ITA No

ITA 322/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad21 Jan 2025AY 2017-18

Bench: Shri T.R. SENTHIL KUMAR (Judicial Member), Shri Narendra Prasad Sinha (Accountant Member)

Section 132Section 143Section 143(3)Section 271ASection 92CSection 92D

…A.Y.2011-12, wherein it was held as under: 5. Before us. Learned DR look us the findings and observation of The AO and supported the order of AO Reliance was also placed on the decision of Hon'ble Apex Court in the case of Mak Data Pvt. Ltd reported in (2013)258 ITR 593 The Learned AR on the other hand submitted that penalty u/s 271AA was initiated and I.T.A Nos. 317 to 324/Ahd/2024 A.Ys. 2012-13 to 2019-20 Page No 8 Priya Blue Industries Pvt. Ltd. vs. DCIT levied on the total international transactions of Rs 26,41,92,634/-, comprising of loan advanced to AE amounting to Rs 25 crores and interest charged by the…

Deputy Commissioner of Income-Tax, Central Circle 1(1), Gujarat vs. Priya Blue Industries Pvt. Ltd., Gujarat

In the result the appeals filed by the Revenue in ITA No

ITA 321/AHD/2024[2016-17]Status: DisposedITAT Ahmedabad21 Jan 2025AY 2016-17

Bench: Shri T.R. SENTHIL KUMAR (Judicial Member), Shri Narendra Prasad Sinha (Accountant Member)

Section 132Section 143Section 143(3)Section 271ASection 92CSection 92D

…A.Y.2011-12, wherein it was held as under: 5. Before us. Learned DR look us the findings and observation of The AO and supported the order of AO Reliance was also placed on the decision of Hon'ble Apex Court in the case of Mak Data Pvt. Ltd reported in (2013)258 ITR 593 The Learned AR on the other hand submitted that penalty u/s 271AA was initiated and I.T.A Nos. 317 to 324/Ahd/2024 A.Ys. 2012-13 to 2019-20 Page No 8 Priya Blue Industries Pvt. Ltd. vs. DCIT levied on the total international transactions of Rs 26,41,92,634/-, comprising of loan advanced to AE amounting to Rs 25 crores and interest charged by the…

DCIT Central Circle 1(1), Ahmedabad, Gujarat vs. Priya Blue Industries Pvt. Ltd., Gujarat

In the result the appeals filed by the Revenue in ITA No

ITA 320/AHD/2024[2015-16]Status: DisposedITAT Ahmedabad21 Jan 2025AY 2015-16

Bench: Shri T.R. SENTHIL KUMAR, Judicial Member\nAnd Shri Narendra Prasad Sinha (Accountant Member)

Section 132Section 143Section 143(3)Section 271ASection 92CSection 92D

…A.Y.2011-12, wherein it was held as under: 5. Before us. Learned DR look us the findings and observation of The AO and supported the order of AO Reliance was also placed on the decision of Hon'ble Apex Court in the case of Mak Data Pvt. Ltd reported in (2013)258 ITR 593 The Learned AR on the other hand submitted that penalty u/s 271AA was initiated and levied on the total international transactions of Rs 26,41,92,634/-, comprising of loan advanced to AE amounting to Rs 25 crores and interest charged by the assessee amounting to Rs 1,41,92.634/- on such loans He submitted that TPO in its order had computed the AL…

Deputy Commissioner of Income -Tax, Central Circle-1(1), Ahmedabad vs. Priya Blue Industries Pvt. Ltd., Gujarat

In the result the appeals filed by the Revenue in ITA No

ITA 319/AHD/2024[2014-15]Status: DisposedITAT Ahmedabad21 Jan 2025AY 2014-15

Bench: Shri T.R. SENTHIL KUMAR (Judicial Member), Shri Narendra Prasad Sinha (Accountant Member)

Section 132Section 143Section 143(3)Section 271ASection 92CSection 92D

…A.Y.2011-12, wherein it was held as under: 5. Before us. Learned DR look us the findings and observation of The AO and supported the order of AO Reliance was also placed on the decision of Hon'ble Apex Court in the case of Mak Data Pvt. Ltd reported in (2013)258 ITR 593 The Learned AR on the other hand submitted that penalty u/s 271AA was initiated and I.T.A Nos. 317 to 324/Ahd/2024 A.Ys. 2012-13 to 2019-20 Page No 8 Priya Blue Industries Pvt. Ltd. vs. DCIT levied on the total international transactions of Rs 26,41,92,634/-, comprising of loan advanced to AE amounting to Rs 25 crores and interest charged by the…

Deputy Commissioner of Income -Tax, Central Circle-1(1), Ahmedabad vs. Priya Blue Industries Pvt. Ltd, Gujarat

In the result the appeals filed by the Revenue in ITA No

ITA 318/AHD/2024[2013-14]Status: DisposedITAT Ahmedabad21 Jan 2025AY 2013-14

Bench: Shri T.R. SENTHIL KUMAR, Judicial Member\nAnd Shri Narendra Prasad Sinha (Accountant Member)

Section 132Section 143Section 143(3)Section 271ASection 92CSection 92D

…A.Y.2011-12, wherein it was held as under: 5. Before us. Learned DR look us the findings and observation of The AO and supported the order of AO Reliance was also placed on the decision of Hon'ble Apex Court in the case of Mak Data Pvt. Ltd reported in (2013)258 ITR 593 The Learned AR on the other hand submitted that penalty u/s 271AA was initiated and levied on the total international transactions of Rs 26,41,92,634/-, comprising of loan advanced to AE amounting to Rs 25 crores and interest charged by the assessee amounting to Rs 1,41,92.634/- on such loans He submitted that TPO in its order had computed the A…

Shri Suresh Mal Lodha, 537-38, Mahima Trinity, New Sanganer Road, Swej Farm, Jaipur vs. ACIT Jaipur, Jaipur

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

ITA 968/JPR/2019[2009-10]Status: DisposedITAT Jaipur12 Jan 2023AY 2009-10

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Mahenda Gargieya, AdvocateFor Respondent: Shri A.S. Nehra, Addl. CIT-DR
Section 139(1)Section 143(2)Section 143(3)Section 24Section 271(1)Section 271(1)(c)Section 274

…e escaped. Thus the assessee’s plea that he did not conceal the income is not acceptable for which the AO relied upon various case laws. SURESH MAL LODHA VS ACIT, CIRCLE-6, JAIPUR 1. Samson Maritime Ltd. vs CIT (Bombay High Court dated 7-03-2017) 2. Mak Data 258 ITR 593 (SC) 3. Dharmendra Textiles Processors (2007) 295 ITR 244 4. CIT vs Vidyagauri Natwar Lal, 238 ITR 91 (Guj) Taking all these facts into consideration, the AO was satisfied that the assessee had concealed income of Rs.23,33,440/- and the assessee is liable for penalty u/s 271(1)© of the Act. Thus the AO computed the penalty amount of Rs.7,93,130…

ACIT, New Delhi vs. M/S. Micromax Informatics Ltd., Gurgaon

In the result, the appeal of the Revenue is dismissed

ITA 4632/DEL/2016[2011-12]Status: DisposedITAT Delhi15 Oct 2020AY 2011-12

Bench: Sh. Anil Chaturvedi & Ms Suchitra Kamble(Through Video Conferencing)

Section 132Section 144CSection 271ASection 92Section 92D

…(A), Revenue is now in appeal before us. 5. Before us, Learned DR took us the findings and observation of the AO and supported the order of AO. Reliance was also placed on the decision of Hon’ble Apex Court in the case of Mak Data Pvt. Ltd. reported in (2013)258 ITR 593. The Learned AR on the other hand submitted that penalty u/s 271AA was initiated and levied on the total international transactions of Rs.26,41,92,634/-, comprising of loan advanced to AE amounting to Rs.25 crores and interest charged by the assessee amounting to Rs.1,41,92,634/- on such loans. He submitted that TPO in its order had computed the…

SURESH MAL LODHA VS ACIT, CIRCLE-6, JAIPUR 1. Samson Maritime Ltd. v. CIT (Bombay High Court (258 ITR 593) — Cited in 9 Judgments | BharatTax