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11 results for “transfer pricing”+ Disallowanceclear

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Key Topics

Addition to Income10Section 37(1)9Section 143(3)8Disallowance8Section 405Section 14A3Section 693Section 1443Business Income3Section 54B

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE -2(1), JABALPUR vs. M/S. MAHAKAUSHAL SUGAR & POWER INDUSTRIES LTD., NARSINGHPUR

In the result, the Revenue’s appeal is partly allowed for statistical purposes

ITA 44/JAB/2020[2017-18]Status: DisposedITAT Jabalpur29 Nov 2022AY 2017-18

Bench: Shri Sanjay Arora, Hon’Ble & Shri Manomohan Das, Hon'Ble

For Appellant: Shri Sanjay Kumar, CIT-DRFor Respondent: Shri Rahul Bardia, FCA
Section 143(3)Section 69Section 80

disallowance is the letter dated 29/4/2017 by the assessee to Madhya Pradesh Power Management Company Limited (MPPMCL)(PB pg. 72) seeking sanction for approval for commissioning and trial run the plant and machinery installed for power generation (at 12.8 MW). The same, as per the Revenue, by itself proves that no approval had been allowed till then, nor is there

RASHMEET SINGH MALHOTRA vs. INCOME TAX OFFICER WARD-1,

2
Section 142(1)2

In the result, the appeal of the assesse is allowed

ITA 226/JAB/2016[2009-10]Status: DisposedITAT Jabalpur30 Nov 2023AY 2009-10

Bench: Dr. B. R. R. Kumarsh. Yogesh Kumar Us

For Appellant: Sh. K.P Dewani, AdvFor Respondent: Sh. Ravi Mehrotra, JCIT-DR
Section 143(3)Section 14ASection 48

Disallowance of interest – Short term capital loss: 5. The issue pertains to computation of short term capital gain /loss incurred by the assessee. The AO is directed to re - compute the short term capital loss take into consideration the cost of acquisition, expenditure incurred wholly and exclusively in connection with transfer of capital asset and sale price

INCOME TAX OFFICER,WARD 1(1), JABALPUR vs. SHRI DEEPAK SINGH BANAFER, JABALPUR

In the result, the Revenue’s appeal is allowed on the aforesaid terms

ITA 92/JAB/2019[2014-15]Status: DisposedITAT Jabalpur11 Jan 2023AY 2014-15

Bench: Shri Sanjay Arora, Hon’Ble & Shri Manomohan Das, Hon'Ble

For Appellant: Sh. L.L. Sharma, AdvocateFor Respondent: Sh. Shiv Kumar, Sr. DR
Section 131Section 143(3)Section 147Section 148(1)Section 54B

transfer stands clearly defined by law. It would, given its nature, not even fetch the price applicable to an agricultural land. And, further, stands sold as an, urban, vacant piece of land, with, rather, no agriculture potential, which normally a piece of land, unless the soil quality is very poor, has. That is, was not an agricultural land

HAJARIMAL MISHRIMAL BAFANA vs. ADDITIONAL COMMISSIONER OF INCOME TAX RANGE,

In the result, the assessee’s appeal for AY 2004-05 is dismissed, and that of AY 2005-06 is partly allowed

ITA 176/JAB/2016[2005-06]Status: DisposedITAT Jabalpur29 Nov 2022AY 2005-06

Bench: Shri Sanjay Arora, Hon’Ble & Shri Manomohan Das, Hon'Ble

For Appellant: NoneFor Respondent: Shri Ravi Mehrotra Sr. DR
Section 142(1)Section 143(3)Section 254(2)Section 43B

transfer is within the same city. In our clear view though, this aspect, i.e., the jurisdiction of the authority to act as the AO in a given case cannot be questioned in the appellate proceedings under the Act in view of the clear mandate of law per sec. 124, requiring all such issues to be decided through the administrative route

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE KATNI, KATNI vs. J.P TOBACCO PRODUCTS PVT. LTD, DAMOH

In the result, both appeals of the Revenue are dismissed

ITA 94/JAB/2023[2017-18]Status: DisposedITAT Jabalpur22 Sept 2023AY 2017-18

Bench: Shri Om Prakash Kantshri Pavan Kumar Gadale

Section 143(3)Section 37(1)Section 40

disallowance following the binding precedents in the case of the assessee itself. For ready-reference, the finding of Tribunal in the case of the assessee in ITA No217/Jab/2015 and others for AY 2007-08 and others dated 27.04.2018 is reproduced as under:- 18. “We have heard the rival contentions and perused the record placed before us and have gone through

ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-KATNI, KATNI vs. J.P. TOBACCO PRODUCTS PVT. LTD, DAMOH

In the result, both appeals of the Revenue are dismissed

ITA 93/JAB/2023[2016-17]Status: DisposedITAT Jabalpur22 Sept 2023AY 2016-17

Bench: Shri Om Prakash Kantshri Pavan Kumar Gadale

Section 143(3)Section 37(1)Section 40

disallowance following the binding precedents in the case of the assessee itself. For ready-reference, the finding of Tribunal in the case of the assessee in ITA No217/Jab/2015 and others for AY 2007-08 and others dated 27.04.2018 is reproduced as under:- 18. “We have heard the rival contentions and perused the record placed before us and have gone through

J.P TOBACO PRODUCTA PVT. LTD.,DAMOH vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE - SAGAR, SAGASR

In the result, both the appeals of the Revenue are dismissed

ITA 128/JAB/2018[2014-15]Status: DisposedITAT Jabalpur21 Nov 2023AY 2014-15

Bench: Dr. B.R.R. Kumar & Shri Yogesh Kumar U.S.

Section 37(1)Section 40

disallowance following the binding precedents in the case of the assessee itself. For ready-reference, the finding of Tribunal in the case of the assessee in ITA I.T.A. No.263/Jab/2016 Assessment Year:2012-13 3 No217/Jab/2015 and others for AY 2007-08 and others dated 27.04.2018 is reproduced as under:- 18. “We have heard the rival contentions and perused the record

J.P TOBACCO PRODUCT PVT. LTD.,DAMOH vs. INCOME TAX OFFICER WARD-3, SAGAR

In the result, both the appeals of the Revenue are dismissed

ITA 127/JAB/2018[2013-14]Status: DisposedITAT Jabalpur21 Nov 2023AY 2013-14

Bench: Dr. B.R.R. Kumar & Shri Yogesh Kumar U.S.

Section 37(1)Section 40

disallowance following the binding precedents in the case of the assessee itself. For ready-reference, the finding of Tribunal in the case of the assessee in ITA I.T.A. No.263/Jab/2016 Assessment Year:2012-13 3 No217/Jab/2015 and others for AY 2007-08 and others dated 27.04.2018 is reproduced as under:- 18. “We have heard the rival contentions and perused the record

J.P TOBACCO PRODUCT PVT. LTD. vs. DEPUTY COMMISSIONER OF INCOME TAX,,

In the result, both the appeals of the Revenue are dismissed

ITA 263/JAB/2016[2012-13]Status: DisposedITAT Jabalpur21 Nov 2023AY 2012-13

Bench: Dr. B.R.R. Kumar & Shri Yogesh Kumar U.S.

Section 37(1)Section 40

disallowance following the binding precedents in the case of the assessee itself. For ready-reference, the finding of Tribunal in the case of the assessee in ITA I.T.A. No.263/Jab/2016 Assessment Year:2012-13 3 No217/Jab/2015 and others for AY 2007-08 and others dated 27.04.2018 is reproduced as under:- 18. “We have heard the rival contentions and perused the record

SHRI GOVIND RATHI, PROP. GOVIND DALL MILL,HOSHANGABAD vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE ITARSI, ITARSI

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

ITA 4/JAB/2019[2012-13]Status: DisposedITAT Jabalpur22 Oct 2021AY 2012-13

Bench: Sh. Sanjay Arora, Hon'Bleassessment Year: 2012-13 Govind Rathi, Dy. Cit, Vs. Circle – Itarsi, Prop: Govind Dall Mill

Section 143(3)Section 68

transferred to the assessee; the basis of the opening cash-in- hand inasmuch as it is this that stands ostensibly deposited in bank, etc.), it does (and it is in fact only this document that so does) indicate, even as argued by Sh. Modh, the ld. counsel for the assessee, of the cash with the creditor being accounted/disclosed

M/S.ASIT DIXIT,JABALPUR vs. INCOME TAX OFFICER WARD2(2), JABALPUR

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

ITA 19/JAB/2020[2005-06]Status: DisposedITAT Jabalpur07 Oct 2021AY 2005-06

Bench: Sh. Sanjay Arora, Hon'Bleassessment Year : 2005-06 Asit Dixit, Income Tax Officer, Vs. Ward-2(2), Jabalpur (M.P.) Jabalpur [Pan: Aanfm 5798A] (Appellant) (Respondent) Appellant By Sh. Sanjay Seth, Ca Respondent By Sh. S.K. Halder, Sr. Dr Date Of Hearing 16/09/2021 Date Of Pronouncement 07/10/2021

Section 142(1)Section 143(2)Section 144Section 145(3)

price levels, cannot be equated with the same amount today. There is no bank account or otherwise anything to demonstrate the savings over a period of time. Why, even the name of the concern where he was working, or the period of his service, both relevant from the standpoint of the truth of the explanation, have not been stated, much