“specified domestic transaction”

Transfer PricingSection 92BASection 92BA588 judgments

The decision most relied on for specified domestic transaction is CIT v. ITC Ltd. (236 Taxmann 612), cited in 108 judgments on BharatTax.

Leading authorities on specified domestic transaction

CIT v. ITC Ltd.

236 Taxmann 612 · 2016 · High Court

108

citing judgments

When computing deduction under Section 80IA, specifically for inter-unit transfer of power, the benefit cannot be claimed based on rates chargeable by distribution licensees to consumers. The deduction must be computed based on the rate fixed by the Tariff Regulation Commission for sale by electricity generating companies.

CIT v. Godawari Power & Ispat Ltd.

42 Taxmann.com 551 · 2014 · High Court

104

citing judgments

Inter-unit transfer of power by an industrial undertaking eligible for Section 80IA deduction constitutes a specified domestic transaction under Section 92BA, requiring valuation at arm's length. This decision clarifies the application of Section 80IA(8) and transfer pricing regulations for such transactions.

CIT v. Jindal Steel & Power Ltd.

157 Taxmann.com 207 · 2023 · Supreme Court

citing judgments

For Section 80IA deductions, the market value of electricity supplied by a captive power plant (eligible unit) to its industrial unit (non-eligible unit) must be computed by comparing prices in the open market and those charged by State Electricity Boards to industrial consumers.

CIT v. Shatrunjay Diamonds

261 ITR 258 · 2003 · High Court

citing judgments

The assessee bears the initial burden to maintain and produce authentic documentation under Section 92D and Rule 10D to justify transactions with related parties, especially concerning the arm's length price for such transactions under Section 40A(2)(b). The discharge of this statutory obligation to maintain accurate data is a mandatory requirement of law.

Commissioner of Income Tax v. Gujarat Alkalies Chemicals Limited

395 ITR 247 · 2017 · High Court

citing judgments

Deduction under Section 80IA is allowable for captive power generation. The price for calculating this deduction is the rate at which the electricity board supplies power to its consumers, rather than the rate at which power generating companies supply to the electricity board.

Skoda Auto India (P) Ltd. v. ACIT, Aurangabad

30 SOT 319 · 2009 · ITAT

citing judgments

The Tribunal may allow adjustments for differences between the tested party and comparable companies to eliminate material differences, provided accurate and credible evidence is furnished.

M/s. Shree Bhagwati Steel Rolling Mills v. C.I.T. Excise & Others

62 Taxmann.com 135 · 2015 · Supreme Court

citing judgments

Judgments in M/s. Shree Bhagwati Steel Rolling Mills and M/s. Fibre Boards have overruled earlier decisions, preventing assessees from relying on those overruled precedents.

CIT v. Star Paper Mills Ltd.

172 Taxmann.com 391 · 2025 · High Court

citing judgments

The transfer price for intra-group services, specifically the sale of power from a captive power plant to a manufacturing unit, can be benchmarked based on the price at which the manufacturing unit procures power from the State Electricity Board, especially when it reflects a reasonable and arm's length price.

Judgments citing specified domestic transaction

My Home Industries Private Limited, Hyderabad vs. DCIT., Circle-5(1), Hyderabad

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

ITA 289/HYD/2024[2018-2019]Status: DisposedITAT Hyderabad14 Nov 2025AY 2018-2019

Bench: Shri Ravish Sooda N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.289/Hyd/2024 (िनधा"रण वष"/Assessment Year: 2018-19) My Home Industries Vs. Dy.Cit Private Limited, Hyderabad Circle 5(1) Pan: Aabcm9480C Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Advocate A.V. Raghuram राज" व "ारा/Revenue By:: Dr. Narendra Kumar Naik, Cit (Dr) सुनवाई की तारीख/Date Of Hearing: 28/10/2025 घोषणा की तारीख/Pronouncement: 14/11/2025 आदेश/Order Per Madhusudan Sawdia, A.M.: This Appeal Is Filed By My Home Industries Private Limited, (“The Assessee”), Feeling Aggrieved By The Assessment Order Passed By The Learned Commissioner Of Income Tax (Appeals)-10, Hyderabad (“Ld. Cit(A)”) Dated 29.01.2024 For The A.Y 2018-19. 2. The Assessee Has Raised The Following Grounds Of Appeal:

For Appellant: Advocate A.V. RaghuramFor Respondent: : Dr. Narendra Kumar Naik, CIT (DR)

Section 143(2)Section 143(3)Section 144CSection 14ASection 92C

Income Tax Act, 1961 (“the Act”) was issued by the Learned Assessing Officer (“Ld. AO”). Since the case involved specified domestic transactions, the Ld. AO referred Page 2 of 22 ITA No 289 of 2024 My Home Industries P Ltd the matter to the Learned Transfer Pricing Officer ... draft assessment order under section 144C of the Act on 27.09.2021, proposing an addition of Rs.37,12,33,185/- on account of specified domestic transactions as suggested by the Ld. TPO, and a further disallowance under section 14A of the Act amounting to Rs.37,33,334/-. Accordingly

Ecoenergy Insights Ltd ( Formerly Known As Chubb Alba Control Systems P.Ltd), New Delhi vs. DCIT, Circle-4(2), New Delhi

In the result, the appeal filed by the assessee is partly allowed as indicated above

ITA 2321/DEL/2022[2018-19]Status: DisposedITAT Delhi10 Nov 2025AY 2018-19

Bench: Shri S. Rifaur Rahman & Shri Anubhav Sharmaecoenergy Insights Ltd., Vs. Dcit, (Formerly Known As Chubb Alba Control Circle 4 (2), Systems P. Ltd.), New Delhi. Ground Floor, 18, Netaji Subhash Marg, Daryaganj, New Delhi – 110 002. (Pan :Aaaca0031C) (Appellant) (Respondent) Assessee By : Shri Nageshwar Rao, Advocate Shri Parth, Advocate Shri Pratik Rath, Advocate Revenue By : Shri S.K. Jadhav, Cit Dr Date Of Hearing : 12.08.2025 Date Of Order : 10.11.2025 O R D E R Per S. Rifaur Rahman: 1. This Appeal Preferred By The Assessees Is Directed Against The Assessment Order Dated 25.07.2022Passed By The Assessment Unit, Income Tax Department Under Section 147 Read With Section 144C(13) R.W.S. 144B Of The Income-Tax Act, 1961 (For Short ‘The Act”) For Ay 2018-19 Pursuant To The Directions Of The Dispute Resolution Panel U/S 144C(5) Of The Act.

For Appellant: Shri Nageshwar Rao, AdvocateFor Respondent: Shri S.K. Jadhav, CIT DR

Section 143(2)Section 144C(13)Section 144C(5)Section 147Section 92C

turn, must request the TPO to determine the ALP in case of international transactions (as per Section 92B) or specified domestic transactions (as per Section 92BA) between associated enterprises, following the extant instructions. This procedure demonstrates that the reference made ... under: 92CA. Reference to Transfer Pricing Officer (1) Where any person, being the assessee, has entered into an international transaction or specified domestic transaction in any previous year, and the Assessing Officer considers it necessary or expedient so to do, he may, with the previous approval of the Principal Commissioner

Krunal Sanghvi, Ahmedabad vs. Income Tax Officer, Ward-5(3)(1), Ahmedabad

In the result, appeal filed by the assessee is allowed

ITA 1285/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad30 Oct 2025AY 2018-19

Bench: SMT. ANNAPURNA GUPTA (Accountant Member), SHRI SIDDHARTHA NAUTIYAL (Judicial Member)

For Appellant: Shri Chintan Shah, ARFor Respondent: Shri Abhijit, Sr.DR

Section 253Section 270A(9)Section 5

bearing on total income; and (f) failure to report any international transaction or any transaction deemed to be an international transaction or any specified domestic transaction, to which the provisions of Chapter X apply.” 8. Clause (a) to (f) thereon are specific instances of mis- reporting of income which attracts

Tejas Shivaji Adsul, Kolhapur vs. Income Tax Officer Ward 1(1), Kolhapur

In the result, appeal of the assessee is allowed

ITA 59/PUN/2025[2018-19]Status: DisposedITAT Pune30 Oct 2025AY 2018-19

Bench: Shri R.K. Panda & Ms. Astha Chandra

For Appellant: Shri A.R. Naik (Virtual)For Respondent: Shri Akhilesh Srivastva

Section 115JSection 143Section 147Section 148Section 270ASection 270A(6)

bearing on total income; and 6. Failure to report any international transaction or any transaction deemed to be an international transaction or any specified domestic transaction, to which the provisions of Chapter X apply." 7.8 Clause (a) of section 270A (9) states that if there is 'misrepresentation or suppression

DCIT Circle-1, Nashik vs. Jyoti Paper Udyog Limited, Nashik

In the result, appeal of the Revenue is dismissed

ITA 552/PUN/2025[2013-14]Status: DisposedITAT Pune30 Oct 2025AY 2013-14

Section 143(3)Section 250Section 40(2)(a)Section 92Section 92BSection 92B(1)

justified in overlooking the saving clause in Section 40(2)(a), which preserves the applicability of Section 92B(1) for specified domestic transactions up to A.Y. 2016-17. 3. Whether on the facts and circumstances of the case, the Ld. CIT(A) is correct in relying on judicial precedents that ... that the payments made by the appellant to the four related parties u/s 40A(2), exceeding Rs.5 crore fell within the scope of Specified Domestic Transactions (SDT") as defined under clause (i) of section 92BA as existing on the Statute Books during/for the relevant period. The transactions entered with

Janta Land Promoters Pvt Ltd, Mohali vs. The Prinicipal Commissioner of Income Tax, Chandigarh-1, Chandigarh

In the result, appeal of the Assessee is allowed

ITA 618/CHANDI/2025[2020-2021]Status: DisposedITAT Chandigarh29 Oct 2025AY 2020-2021

For Appellant: Shri Pankaj Bhalla, C.AFor Respondent: Shri Manav Bansal, CIT, DR

Section 143(3)Section 194Section 263Section 68

submitted that the Ld. PCIT alleges non-review in general terms; no specific international transaction is shown; assessee pointed to non-applicability of specified domestic transactions. (as urged before PCIT). Further , the Ld. AR submitted that the issue raised in the said para pertains to transfer pricing adjustment. From perusal ... financial statements, it is evident that there is neither an international transaction nor specified domestic transactions under Section 92BA apply to the assessee. The Ld. AR had further submitted that the Ld. PCIT has not pointed out, either in the show cause notice or in the impugned order, that

Knr Constructions Limited, Hyderabad vs. ACIT, Central Circle-2(2), Hyderabad

In the result, appeal filed by the assessee is dismissed

ITA 500/HYD/2022[2018-19]Status: DisposedITAT Hyderabad29 Oct 2025AY 2018-19

For Appellant: Shri A.V.Raghuram, AdvocateFor Respondent: : Smt. U Mini Chandran, CIT(DR)

Section 143(2)Section 143(3)Section 144CSection 144C(13)Section 144C(5)Section 80Section 92C

under section 143(2) of the Act was issued by the Ld. AO on 22.09.2019. During the year, the assessee had entered into specified domestic transactions with its Associated Enterprises ("AEs"), and therefore, the matter was referred to the Learned Transfer Pricing Officer ("Ld. TPO") for determination ... solitary issue involved in the present appeal pertains to the Transfer Pricing adjustment of Rs.36,77,04,171/- made on account of specified domestic transactions relating to the assessee's infrastructure projects. It was submitted that during the year, the assessee had undertaken 23 projects eligible for deduction under section

Assistant Commissioner of Income Tax, Circle-5(1), Hyderabad vs. Mytrah Vayu (Gujarat) Private Limited, Hyderabad

In the result, appeal filed by the Revenue is dismissed

ITA 690/AHD/2025[2014-15]Status: DisposedITAT Ahmedabad28 Oct 2025AY 2014-15

Bench: SMT. ANNAPURNA GUPTA (Accountant Member), Ms. SUCHITRA KAMBLE (Judicial Member)

For Appellant: Shri Prathvi Raj Meena, CIT.DRFor Respondent: Shri Ravi Bharadwaj V & Shri

Section 250Section 56(2)Section 56(2)(vii)

above ground relates to deletion of addition made to the income of the assessee on account of transfer pricing adjustment made to Specified Domestic Transaction (‘SDT’) entered into by the assessee with its Associate Enterprise. The quantum of adjustment so made being Rs.2.38 Crores and the nature of transaction with ... MEIPL was not covered under 80IA(10) of the Act. The contention, therefore, was that the assessee did not qualify as a specified domestic transaction in terms of 92BA of the Act. The AO, however, noted that the assessee itself had disclosed the impugned transaction in Form 3CEB under

Rakesh Kumar Gupta, Delhi vs. Ld. ITO, Ward 35(1), Delhi

In the result, the appeal of the assessee is allowed

ITA 3447/DEL/2025[2021-22]Status: DisposedITAT Delhi27 Oct 2025AY 2021-22

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla, Accountnat Member [Assessment Year: 2021-22] Rakesh Kumar Gupta, Income Tax Officer, Ward-35(1), B-2/38, Ground Floor, E-2, Civic Centre, Delhi-110002 Ashok Vihar, Phase-Ii, Vs Delhi-110052 Pan-Aafhr8657H Appellant Respondent

Section 115JSection 143Section 143(3)Section 148Section 250Section 270A

bearing on total income; and (f) failure to report any international transaction or any transaction deemed to be an international transaction or any specified domestic transaction, to which the provisions of Chapter X apply. (10) The tax payable in respect of the under-reported income shall be— (a) where ... bearing on total income; and (f) failure to report any international transaction or any transaction deemed to be an international transaction or any specified domestic transaction, to which the provisions of Chapter X apply. (10) The tax payable in respect of the under-reported income shall be— (a) where

N. Vijay Kumar, ACIT, Chennai vs. Rajah Muthiah Chettiar Charitable and Educational Trust, Chennai

In the result, appeals filed by the Revenue & CO of assessee are

ITA 2097/CHNY/2025[2019-20]Status: DisposedITAT Chennai24 Oct 2025AY 2019-20

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

For Appellant: Mr. Arjunraj, AdvocateFor Respondent: Mr. Saujanya Ranjan, IRS

Section 270ASection 270A(9)Section 9

Assistant Commissioner of Income Tax, Tirupur vs. Sri Shanmugavel Mills Private Limited, Tirupur

In the result, appeal filed by the Revenue is dismissed

ITA 1048/CHNY/2025[2017]Status: DisposedITAT Chennai24 Oct 2025

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

For Appellant: Mr.Suraj Nahar, CAFor Respondent: Mr.Saddik Ahmed, Sr.AR

Section 143(3)Section 80ISection 92C

length price as defined in clause (ii) of section 92F, where the transfer of such goods or services is a specified domestic transaction referred to in section 92BA.” 18. As regards the above, the Ld.AR submitted that the explanation to section 80-IA(8) provides that for the purposes ... length price as defined in clause (ii) of section 92F, where the transfer of such goods or services is a specified domestic transaction referred to in section 92BA. It may be noticed that section 80-IA(8) in its explanation defines market value to be either as per clause

Assistant Commissioner of Income Tax, Jhandewalan Extension, New Delhi vs. Tvarur and Fats Private Limited, New Delhi

In the result, Appeal of the Revenue in ITA No

ITA 3006/DEL/2024[2016-17]Status: DisposedITAT Delhi24 Oct 2025AY 2016-17

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.Assistant Commissioner Vs. Tvarur & Fats Pvt. Ltd. Of Income Tax, Unit No. 101, 102A, First Floor, Room No. 332, 3Rd Floor, Plot No. 9, Realtech Copia, Ara Centre, Jhandewalan Corporate Suits, Jasola District Extension, New Delhi Centre, New Delhi Pan: Aaect7561Q Appellant Respondent C.O. No. 83/Del/2024 (In Ita No. 3006/Del/2024) Tvarur & Fats Pvt. Ltd. Vs. Assistant Commissioner Of Unit No. 101, 102A, First Income Tax, Floor, Plot No. 9, Room No. 332, 3Rd Floor, Ara Realtechcopia, Corporate Centre, Jhandewalan Suits, Jasola District Extension, New Delhi Centre, New Delhi Pan: Aaect7561Q Appellant Respondent Assessee By Sh. Ashwani Kumar, Ca & Sh. Aditya Kumar, Ca Revenue By Sh. S. K. Jadhav, Cit(Dr) Date Of Hearing 05/08/2025 Date Of Pronouncement 24/10/2025

Section 92C

Information and documents to be kept and maintained under section 92D: "(1) Every person who has entered into an international transaction [or a specified domestic transaction] shall keep and maintain the following information and documents, namely:- (g) a record of uncontrolled transactions taken into account for analysing their comparability with ... conditions relating to any uncontrolled transaction with third parties which may be of relevance to the pricing of the international transactions [or specified domestic transactions, as the case may be]; (h) a record of the analysis performed to evaluate comparability of uncontrolled transactions with the relevant international transaction [or specified

Gujarat Energy Development Agency, Gandhinagar vs. The Dy.CIT, Circle-1, Exemp, Ahmedabad

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

ITA 1180/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad16 Oct 2025AY 2017-18

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinha

Section 11Section 12ASection 143(3)Section 263Section 270A

bearing on total income; and (f) failure to report any international transaction or any transaction deemed to be an international transaction or any specified domestic transaction, to which the provisions of Chapter X apply. 18. In view of the above specific provision, the Assessing Officer, while imposing the penalty under

Gujarat Energy Development Agency, Gandhinagar vs. The Dy.CIT, Circle-1, Exemp, Ahmedabad

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

ITA 1179/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad16 Oct 2025AY 2017-18

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinha

Section 11Section 12ASection 143(3)Section 263Section 270A

bearing on total income; and (f) failure to report any international transaction or any transaction deemed to be an international transaction or any specified domestic transaction, to which the provisions of Chapter X apply. 18. In view of the above specific provision, the Assessing Officer, while imposing the penalty under

Michael Page International Recruitment Pvt Ltd, Mumbai vs. DCIT Circle 14(1)(1), Mumbai

ITA 6748/MUM/2024[2021-22]Status: DisposedITAT Mumbai16 Oct 2025AY 2021-22

Section 143(3)Section 144BSection 144C(13)Section 144C(5)Section 153Section 37Section 41Section 92D

IN THE INCOME TAX APPELLATE TRIBUNAL “J” BENCH, MUMBAI SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SHRI PRABHASH SHANKAR, ACCOUNTANT MEMBER ITA

Assimilate Solutions India Pvt. Ltd., Delhi vs. DCIT Circle, 1(1), Delhi

In the result, the ground raised by the assessee in this regard is dismissed

ITA 5357/DEL/2024[2021-22]Status: DisposedITAT Delhi15 Oct 2025AY 2021-22

Bench: Shris.Rifaur Rahman & Shri Vimal Kumarassimilate Solutions India Private Limited, Vs. Dcit/Acit, C/O Sanjiv Sapra & Associates Llp, Circle 1 (1), Chartered Accountants, New Delhi. C – 763, New Friends Colony, New Delhi – 110 025. (Pan :Aakca4501H) (Appellant) (Respondent) Assessee By : Shri Sanjiv Sapra, Ar Revenue By : Shri Dharam Veer Singh, Cit Dr Date Of Hearing : 30.07.2025 Date Of Order : 15.10.2025 Order Per S. Rifaur Rahman: 1. The Assessee Has Filed Appeal Against Assessment Order Dated 31.12.2015 Passed By The Assessment Unit, Income Tax Department Under Section 143(3) Read With Section 144C(13)R.W.S. 144B Of The Income-Tax Act, 1961 (For Short ‘The Act”) For Assessment Year 2021-22 Pursuant To The Directions Of The Dispute Resolution Panel U/S 144C(5) Of The Act. 2. M/S. Assimilate Solutions India Private Limited, The Assessee Was Incorporated On 19.04,2012 & Is Engaged In The Business Of Providing

For Appellant: Shri Sanjiv Sapra, ARFor Respondent: Shri Dharam Veer Singh, CIT DR

Section 143(2)Section 143(3)Section 144C(13)Section 144C(5)

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘I’: NEW DELHI BEFORE SHRIS.RIFAUR RAHMAN, ACCOUNTANT MEMBER and SHRI VIMAL KUMAR

Bharat Kumar Jaishinh Soni, Mumbai vs. ITO, Ward 42(2)(1), Mumbai

In the result, appeal of the assessee is allowed

ITA 4261/MUM/2025[2020-21]Status: DisposedITAT Mumbai13 Oct 2025AY 2020-21

Bench: SHRI AMIT SHUKLA (Judicial Member), MS PADMAVATHY S (Accountant Member)

Section 10Section 270ASection 270A(9)

false entry in the books; (e) failure to record any receipt having a bearing on income; and (f) failure to report international or specified domestic transactions. 9. A careful reading of the statutory scheme reveals that misreporting is predicated on mens rea a conscious act of 5 Bharat Kumar Jaishinh

ACIT (Cir.) - 6(1)(2), Mumbai vs. Bhandar Power Ltd., Mumbai

In the result, appeal of the Revenue is dismissed

ITA 1908/MUM/2018[2013-14]Status: DisposedITAT Mumbai13 Oct 2025AY 2013-14

Bench: Shri Amit Shukla & Shri Girish Agrawalassessment Year: 2013-14 Assistant Commissioner Of Bhandar Power Ltd. Income Tax, 14Th Floor, Essar House, Circle 6(1)(2), 11, K. K. Marg, Mahalaxmi, Vs. Mumbai Mumbai - 400034 (Pan: Aaacb6693B) (Appellant) (Respondent) Present For: Assessee : Shri Vijay Mehta, Fca & Shri Tarang Mehta, Advocate Revenue : Shri Satyaprakash R. Singh, Cit Dr Date Of Hearing : 29.07.2025 Date Of Pronouncement : 13.10.2025 O R D E R Per Girish Agrawal: This Appeal Filed By The Revenue Is Against The Order Of Ld. Cit(A), Delhi, Vide Order Dated 25.01.2018 Passed Against The Assessment Order By Ito 6(1)(4), Mumbai, U/S. 143(3) Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”), Dated 20.12.2016, For Assessment Year 2013-14. 2. Grounds Taken By The Revenue Are Reproduced As Under: 1. On The Facts & In The Circumstances Of The Case & In Law, The Cit(A) Is Not Justified In Deleting The Disallowance Of Deduction U/S 80Ia Of The Income Tax Act Of Rs. 203,13,43,740/-Without Considering The Fact That The Provisions Of Section 801A(10) Is Clearly Attracted In This Case Hence The Assessee Is Not Eligible For Claiming Deduction U/S 801A Of The Income Tax Act.

For Appellant: Shri Vijay Mehta, FCA and Shri Tarang Mehta, AdvocateFor Respondent: Shri Satyaprakash R. Singh, CIT DR

Section 143(3)Section 801ASection 801A(10)Section 80I

years (supra). The only difference in the present year as compared to the preceding years is applicability of provisions of section 92BA whereby Specified Domestic Transactions (SDT) having subjected to transfer pricing Regulations and the claim of deduction made by the assessee u/s.80IA falls withing the meaning of SDT subjected ... Officer made the reference u/s.92CA(1) to the Transfer Pricing Officer (TPO) for computation of Arms’ Length Price (ALP) in relation to the Specified Domestic Transaction (SDT). Assessee had furnished Form No.3CEB as prescribed u/r. 10E of the Income-tax Rules, 1962 (the Rules). In clause 25 of this Form

Sincere Architects Engineers Pvt. Ltd., Jaipur vs. ACIT, Cirlce-7, Jaipur

In the result the appeal no

ITA 974/JPR/2024[2017-18]Status: DisposedITAT Jaipur10 Oct 2025AY 2017-18

For Appellant: Shri Ashish Sharma, AdvFor Respondent: Shri Gaurav Awasthi, JCIT

Section 139Section 142(1)Section 147Section 148Section 154Section 194A

bearing on total income; and failure to report any international transaction or any transaction deemed to be an international transaction or any specified domestic transaction, to which the provisions of Chapter X apply. (10) The tax payable in respect of the under-reported income shall be- where no return ... bearing on total income; and failure to report any international transaction or any transaction deemed to be an international transaction or any specified domestic transaction, to which the provisions of Chapter X apply. Thus, we note that there is no reason as per provision of section 270A(9) to make

Sincere Architects Engineers Pvt. Ltd., Jaipur vs. ACIT, Circle-7, Jaipur

In the result the appeal no

ITA 973/JPR/2024[2017-18]Status: DisposedITAT Jaipur10 Oct 2025AY 2017-18

For Appellant: Shri Ashish Sharma, AdvFor Respondent: Shri Gaurav Awasthi, JCIT

Section 139Section 142(1)Section 147Section 148Section 154Section 194A

bearing on tota income; and failure to report any international transaction or any transaction deemed to be an international transaction or any specified domestic transaction, to which the provisions of Chapter X apply. (10) The tax payable in respect of the under-reported income shall be- where no return ... bearing on total income; and 6. failure to report any international transaction or any transaction deemed to be an international transaction or any specified domestic transaction, to which the provisions of Chapter X apply. Thus, we note that there is no reason as per provision of section 270A