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38 results for “transfer pricing”+ Section 133Aclear

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Key Topics

Section 10(38)41Section 8035Addition to Income35Section 143(3)29Survey u/s 133A28Section 133A25Section 14722Section 69B16Disallowance16Section 12A

SANJEEV AGRAWAL ,BHOPAL vs. ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL-2, BHOPAL

Appeal is allowed

ITA 38/IND/2024[2017-18]Status: DisposedITAT Indore21 Feb 2025AY 2017-18
Section 131Section 133ASection 139(1)Section 143(3)Section 147Section 148Section 69C

Price Waterhouse & Co Vs. Deputy Commissioner of Income\nTax, Circle-22, ITA No. 1985/Kol2018 Order dated 5/2/2020, it\nwas observed:-\n“11. Therefore, in the light of the aforesaid judicial precedents and other case\nlaws, we note that to initiate reopening of the assessment, the Ld. AO must\nhave 'reason to believe that income chargeable to tax has escaped assessment

M/S SHREE JAIRAM EDUCATION SOCIETY,BHOPAL vs. ACIT CENTRAL-II, BHOPAL

Showing 1–20 of 38 · Page 1 of 2

14
Section 14813
Long Term Capital Gains9

In the result, appeal of the assessee in ITANo

ITA 548/IND/2019[2010-11]Status: DisposedITAT Indore13 Oct 2021AY 2010-11

Bench: Hon’Ble Rajpal Yadav & Shri Manish Boradvirtual Hearing

Section 12ASection 132Section 143(2)Section 148Section 37

133A of the Act in the case of assessee. The assessment has been completed u/s 148/143(3) of the act vide order dated 19.12.2018………….” 5. In the instant case, no notice u/s 153A or 153C were issued. Assessment proceedings u/s 147 rws 143(3) were completed for AY 2010-11 on 29.12.2017. These proceedings for AY 2010-11 were centralized

M/S SHREE JAIRAM EDUCATION SOCIETY,BHOPAL vs. PR. CIT (CENTRAL), BHOPAL

In the result, appeal of the assessee in ITANo

ITA 90/IND/2019[-]Status: DisposedITAT Indore13 Oct 2021

Bench: Hon’Ble Rajpal Yadav & Shri Manish Boradvirtual Hearing

Section 12ASection 132Section 143(2)Section 148Section 37

133A of the Act in the case of assessee. The assessment has been completed u/s 148/143(3) of the act vide order dated 19.12.2018………….” 5. In the instant case, no notice u/s 153A or 153C were issued. Assessment proceedings u/s 147 rws 143(3) were completed for AY 2010-11 on 29.12.2017. These proceedings for AY 2010-11 were centralized

THE ACIT, CENTRAL-1, INDORE vs. M/S. MANISH AGRO TECH PVT. LTD., INDORE

In the result grounds of revenue for A

ITA 219/IND/2021[2015-16]Status: DisposedITAT Indore30 Jan 2023AY 2015-16

Bench: Shri Chandra Mohan Garg & Shri Bhagirath Mal Biyani

For Appellant: Shri Ruchira SinghalFor Respondent: Shri P.K Mishra, CIT (DR)

section 65A and 65B of the Indian Evidence Act 1872 providing for admissibility of electronic records as evidence have not been followed. The appellant has also placed reliance on certain decisions wherein, on identical facts, similar addition made have been deleted. 4.2.2 After considering the observation made in the assessment order and also taking into consideration the written submissions

THE ACIT, CENTRAL-1, INDORE vs. M/S. MANISH AGRO TECH PVT. LTD., INDORE

In the result grounds of revenue for A

ITA 218/IND/2021[2012-13]Status: DisposedITAT Indore30 Jan 2023AY 2012-13

Bench: Shri Chandra Mohan Garg & Shri Bhagirath Mal Biyani

For Appellant: Shri Ruchira SinghalFor Respondent: Shri P.K Mishra, CIT (DR)

section 65A and 65B of the Indian Evidence Act 1872 providing for admissibility of electronic records as evidence have not been followed. The appellant has also placed reliance on certain decisions wherein, on identical facts, similar addition made have been deleted. 4.2.2 After considering the observation made in the assessment order and also taking into consideration the written submissions

AG-8 VENTURES LTD.,BHOPAL vs. ACIT, CENTRAL-1, BHOPAL

ITA 922/IND/2019[2013-14]Status: DisposedITAT Indore16 Feb 2021AY 2013-14

Bench: Hon'Ble Kul Bharat & Hon'Ble Manish Borad

Section 132Section 133ASection 143(3)Section 14ASection 153ASection 271(1)(c)Section 271ASection 40A(3)Section 80I

133A was carried out at the premises and Buidling Projects run by the assessee-company. Subsequently, a search u/s. 132 was also IT(SS)A No.83,84,86,87,90,91,109,110 & ITA, No.922 &923/Ind/2019 AG8 Ventures Ltd. carried on 29-31 January 2014 at the business place of assessee company and residential premises of Directors. Various books

AG-8 VENTURES LTD.,BHOPAL vs. ACIT, CENTRAL-1, BHOPAL

ITA 923/IND/2019[2014-15]Status: DisposedITAT Indore16 Feb 2021AY 2014-15

Bench: Hon'Ble Kul Bharat & Hon'Ble Manish Borad

Section 132Section 133ASection 143(3)Section 14ASection 153ASection 271(1)(c)Section 271ASection 40A(3)Section 80I

133A was carried out at the premises and Buidling Projects run by the assessee-company. Subsequently, a search u/s. 132 was also IT(SS)A No.83,84,86,87,90,91,109,110 & ITA, No.922 &923/Ind/2019 AG8 Ventures Ltd. carried on 29-31 January 2014 at the business place of assessee company and residential premises of Directors. Various books

PRITESH JAIN HUF,INDORE vs. ITO 4 (2), INDORE

In the result Ground No.2 of the assessee’s

ITA 293/IND/2020[2014-15]Status: DisposedITAT Indore30 Apr 2021AY 2014-15

Bench: Hon’Ble Manish Borad & Hon’Ble Madhumita Royassessment Year 2014-15

Section 10(38)Section 143(3)Section 68

transferred through Dmat account thereby fulfilling the condition of Section 10(38) of the Act. However, the Ld. A.O was not convinced and observed that the figures available from the Annual Report shows that the market value of the equity share of the company on the stock exchange is unrealistic and not at par with the financials of the company

SHRI NILESH JAIN HUF,INDORE vs. ITO 4(2), INDORE

In the result Ground No.2 of the assessee’s

ITA 294/IND/2020[2014-15]Status: DisposedITAT Indore30 Apr 2021AY 2014-15

Bench: Hon’Ble Manish Borad & Hon’Ble Madhumita Royassessment Year 2014-15

Section 10(38)Section 143(3)Section 68

transferred through Dmat account thereby fulfilling the condition of Section 10(38) of the Act. However, the Ld. A.O was not convinced and observed that the figures available from the Annual Report shows that the market value of the equity share of the company on the stock exchange is unrealistic and not at par with the financials of the company

MANISH KUMAR RADHESHYAM NYATI ,DHAR vs. ITO, DHAR

In the result appeals of the assessee(s) namely Kumari

ITA 705/IND/2018[14-15]Status: DisposedITAT Indore25 May 2021

Bench: Hon'Ble Manish Borad & Hon'Ble Madhumita Royassessment Year:2014-15 Kumari Ayushi Nyati Ito, 5(5) 10, Balaji Vihar, 1-2, Maa Durg Indore बनाम/ Nagar, Navlakha Main Road 1 To Vs. 7, Indore (Appellant) (Revenue ) P.A. No.Ajppn2679C Assessment Year:2014-15 Smt. Vijaya Nyati, Ito, Dhar 5 Nyati House, Mandi Road बनाम/ Dhammod, Dist: Dhar M.P. Vs. (Appellant) (Revenue ) P.A. No.Aappn8302B Assessment Year:2014-15 Shri Vijay Kumar Radheshyam Ito, Dhar Nyati, Huf बनाम/ 5 Nyati House, Mandi Road Vs. Dhammod, Dist: Dhar M.P. (Appellant) (Revenue ) P.A. No.Aachv4415Q

Section 10(38)Section 131Section 133A

133A in the case of Shipra Fabrics 13 Kumari Ayushi Nyati & others ITA Nos.203/Ind/2019,703 to 705/Ind/2018, & 488/Ind/2019 Pvt. Ltd. Mumbai wherein Shri Vipul Vidur Bhatt categorically accepted that he has rigged the price of shares of M/s Sunrise Asian Ltd. Reference to Q. 20 has been made. Your Honour’s kind attention is drawn to the decision

VIJAY RADHESHYAM NYATI HUF,DHAR vs. ITO, DHAR

In the result appeals of the assessee(s) namely Kumari

ITA 704/IND/2018[14-15]Status: DisposedITAT Indore25 May 2021

Bench: Hon'Ble Manish Borad & Hon'Ble Madhumita Royassessment Year:2014-15 Kumari Ayushi Nyati Ito, 5(5) 10, Balaji Vihar, 1-2, Maa Durg Indore बनाम/ Nagar, Navlakha Main Road 1 To Vs. 7, Indore (Appellant) (Revenue ) P.A. No.Ajppn2679C Assessment Year:2014-15 Smt. Vijaya Nyati, Ito, Dhar 5 Nyati House, Mandi Road बनाम/ Dhammod, Dist: Dhar M.P. Vs. (Appellant) (Revenue ) P.A. No.Aappn8302B Assessment Year:2014-15 Shri Vijay Kumar Radheshyam Ito, Dhar Nyati, Huf बनाम/ 5 Nyati House, Mandi Road Vs. Dhammod, Dist: Dhar M.P. (Appellant) (Revenue ) P.A. No.Aachv4415Q

Section 10(38)Section 131Section 133A

133A in the case of Shipra Fabrics 13 Kumari Ayushi Nyati & others ITA Nos.203/Ind/2019,703 to 705/Ind/2018, & 488/Ind/2019 Pvt. Ltd. Mumbai wherein Shri Vipul Vidur Bhatt categorically accepted that he has rigged the price of shares of M/s Sunrise Asian Ltd. Reference to Q. 20 has been made. Your Honour’s kind attention is drawn to the decision

SMT. MAMTA NYATI DHAMNOD DISTT. DHAR,DHAMNOD vs. ITO DHAR, DHAR

In the result appeals of the assessee(s) namely Kumari

ITA 488/IND/2019[2014-15]Status: DisposedITAT Indore25 May 2021AY 2014-15

Bench: Hon'Ble Manish Borad & Hon'Ble Madhumita Royassessment Year:2014-15 Kumari Ayushi Nyati Ito, 5(5) 10, Balaji Vihar, 1-2, Maa Durg Indore बनाम/ Nagar, Navlakha Main Road 1 To Vs. 7, Indore (Appellant) (Revenue ) P.A. No.Ajppn2679C Assessment Year:2014-15 Smt. Vijaya Nyati, Ito, Dhar 5 Nyati House, Mandi Road बनाम/ Dhammod, Dist: Dhar M.P. Vs. (Appellant) (Revenue ) P.A. No.Aappn8302B Assessment Year:2014-15 Shri Vijay Kumar Radheshyam Ito, Dhar Nyati, Huf बनाम/ 5 Nyati House, Mandi Road Vs. Dhammod, Dist: Dhar M.P. (Appellant) (Revenue ) P.A. No.Aachv4415Q

Section 10(38)Section 131Section 133A

133A in the case of Shipra Fabrics 13 Kumari Ayushi Nyati & others ITA Nos.203/Ind/2019,703 to 705/Ind/2018, & 488/Ind/2019 Pvt. Ltd. Mumbai wherein Shri Vipul Vidur Bhatt categorically accepted that he has rigged the price of shares of M/s Sunrise Asian Ltd. Reference to Q. 20 has been made. Your Honour’s kind attention is drawn to the decision

KUMARI AYUSHI NYATI,INDORE vs. ITO-5(5), INDORE

In the result appeals of the assessee(s) namely Kumari

ITA 203/IND/2019[2014-15]Status: DisposedITAT Indore25 May 2021AY 2014-15

Bench: Hon'Ble Manish Borad & Hon'Ble Madhumita Royassessment Year:2014-15 Kumari Ayushi Nyati Ito, 5(5) 10, Balaji Vihar, 1-2, Maa Durg Indore बनाम/ Nagar, Navlakha Main Road 1 To Vs. 7, Indore (Appellant) (Revenue ) P.A. No.Ajppn2679C Assessment Year:2014-15 Smt. Vijaya Nyati, Ito, Dhar 5 Nyati House, Mandi Road बनाम/ Dhammod, Dist: Dhar M.P. Vs. (Appellant) (Revenue ) P.A. No.Aappn8302B Assessment Year:2014-15 Shri Vijay Kumar Radheshyam Ito, Dhar Nyati, Huf बनाम/ 5 Nyati House, Mandi Road Vs. Dhammod, Dist: Dhar M.P. (Appellant) (Revenue ) P.A. No.Aachv4415Q

Section 10(38)Section 131Section 133A

133A in the case of Shipra Fabrics 13 Kumari Ayushi Nyati & others ITA Nos.203/Ind/2019,703 to 705/Ind/2018, & 488/Ind/2019 Pvt. Ltd. Mumbai wherein Shri Vipul Vidur Bhatt categorically accepted that he has rigged the price of shares of M/s Sunrise Asian Ltd. Reference to Q. 20 has been made. Your Honour’s kind attention is drawn to the decision

SMT VIJAYA NYATI, DHAR vs. ITO, DHAR

In the result appeals of the assessee(s) namely Kumari

ITA 703/IND/2018[14-15]Status: DisposedITAT Indore25 May 2021

Bench: Hon'Ble Manish Borad & Hon'Ble Madhumita Royassessment Year:2014-15 Kumari Ayushi Nyati Ito, 5(5) 10, Balaji Vihar, 1-2, Maa Durg Indore बनाम/ Nagar, Navlakha Main Road 1 To Vs. 7, Indore (Appellant) (Revenue ) P.A. No.Ajppn2679C Assessment Year:2014-15 Smt. Vijaya Nyati, Ito, Dhar 5 Nyati House, Mandi Road बनाम/ Dhammod, Dist: Dhar M.P. Vs. (Appellant) (Revenue ) P.A. No.Aappn8302B Assessment Year:2014-15 Shri Vijay Kumar Radheshyam Ito, Dhar Nyati, Huf बनाम/ 5 Nyati House, Mandi Road Vs. Dhammod, Dist: Dhar M.P. (Appellant) (Revenue ) P.A. No.Aachv4415Q

Section 10(38)Section 131Section 133A

133A in the case of Shipra Fabrics 13 Kumari Ayushi Nyati & others ITA Nos.203/Ind/2019,703 to 705/Ind/2018, & 488/Ind/2019 Pvt. Ltd. Mumbai wherein Shri Vipul Vidur Bhatt categorically accepted that he has rigged the price of shares of M/s Sunrise Asian Ltd. Reference to Q. 20 has been made. Your Honour’s kind attention is drawn to the decision

M/S. BHOMIYAJI LAND & FINANCE CO.,DEWAS vs. THE ITO, DEWAS

In the result ground No.3& 4 are dismissed

ITA 490/IND/2013[2007-08]Status: DisposedITAT Indore31 Jan 2018AY 2007-08

Bench: Shri Kul Bharat & Shri Manish Boradassessment Year: 2006-07

Section 133ASection 143(2)

133A that registry was made on lesser amount than the actual price of the plot. On that account he had surrendered Rs. 5,00,000/- during the survey, although later on he has retracted from his statement and explained that the entries recorded in the diaries were only estimates. But, it does not change the facts of the case that

THE DCIT, 1(1), UJJAIN vs. M/S. BHOOMIYAJI LAND & FINANCE CO.,, DEWAS

In the result ground No.3& 4 are dismissed

ITA 411/IND/2013[2006-07]Status: DisposedITAT Indore31 Jan 2018AY 2006-07

Bench: Shri Kul Bharat & Shri Manish Boradassessment Year: 2006-07

Section 133ASection 143(2)

133A that registry was made on lesser amount than the actual price of the plot. On that account he had surrendered Rs. 5,00,000/- during the survey, although later on he has retracted from his statement and explained that the entries recorded in the diaries were only estimates. But, it does not change the facts of the case that

THE DCIT, 1(1), UJJAIN vs. M/S. BHOOMIYAJI LAND & FINANCE CO.,, DEWAS

In the result ground No.3& 4 are dismissed

ITA 412/IND/2013[2007-08]Status: DisposedITAT Indore31 Jan 2018AY 2007-08

Bench: Shri Kul Bharat & Shri Manish Boradassessment Year: 2006-07

Section 133ASection 143(2)

133A that registry was made on lesser amount than the actual price of the plot. On that account he had surrendered Rs. 5,00,000/- during the survey, although later on he has retracted from his statement and explained that the entries recorded in the diaries were only estimates. But, it does not change the facts of the case that

THE DCIT, 1(1), UJJAIN vs. M/S. BHOOMIYAJI LAND & FINANCE LTD., DEWAS

In the result ground No.3& 4 are dismissed

ITA 634/IND/2014[2010-11]Status: DisposedITAT Indore31 Jan 2018AY 2010-11

Bench: Shri Kul Bharat & Shri Manish Boradassessment Year: 2006-07

Section 133ASection 143(2)

133A that registry was made on lesser amount than the actual price of the plot. On that account he had surrendered Rs. 5,00,000/- during the survey, although later on he has retracted from his statement and explained that the entries recorded in the diaries were only estimates. But, it does not change the facts of the case that

THE DCIT, 1(1), UJJAIN vs. M/S BHOOMIYAJI LAND & FINANCE CO.,, DEWAS

In the result ground No.3& 4 are dismissed

ITA 137/IND/2013[2008-09]Status: DisposedITAT Indore31 Jan 2018AY 2008-09

Bench: Shri Kul Bharat & Shri Manish Boradassessment Year: 2006-07

Section 133ASection 143(2)

133A that registry was made on lesser amount than the actual price of the plot. On that account he had surrendered Rs. 5,00,000/- during the survey, although later on he has retracted from his statement and explained that the entries recorded in the diaries were only estimates. But, it does not change the facts of the case that

M/S BHOOMIYAJI LAND & FINANCE CO.,DEWAS vs. THE ITO, DEWAS

In the result ground No.3& 4 are dismissed

ITA 142/IND/2013[2008-09]Status: DisposedITAT Indore31 Jan 2018AY 2008-09

Bench: Shri Kul Bharat & Shri Manish Boradassessment Year: 2006-07

Section 133ASection 143(2)

133A that registry was made on lesser amount than the actual price of the plot. On that account he had surrendered Rs. 5,00,000/- during the survey, although later on he has retracted from his statement and explained that the entries recorded in the diaries were only estimates. But, it does not change the facts of the case that