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10 results for “transfer pricing”+ Section 2(14)clear

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Key Topics

Section 201(1)8Section 143(3)7Section 37(1)6Addition to Income6Section 2014Section 2633Section 1443Disallowance3Section 402

RITA MANCHHANI ,JABALPUR vs. PR. CIT-1 JABALPUR, JABALPUR

In the result, the assessee‘s appeal is dismissed on the afore-said terms

ITA 19/JAB/2021[2015-16]Status: DisposedITAT Jabalpur29 Nov 2022AY 2015-16

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

For Appellant: Shri Rahul Bardia, FCAFor Respondent: Shri Sanjay Kumar, CIT-DR
Section 143(3)Section 263Section 56(2)(vii)

14, items A to E. (2) In particular, and without prejudice to the generality of the provisions of sub- section (1), the following incomes, shall be chargeable to income-tax under the head "Income from other sources", namely :— (i) to (vi) xxxxxxxxxxx (vii) where an individual or a Hindu undivided family receives, in any previous year, from any person

DEPUTY COMMISSIONER OF INCOME TAX, JABALPUR vs. ORIENT PAPER MILLS PROP. M/S ORIENT PAPERS &,

Section 1952
Deduction2
TDS2

In the result, both the appeals filed by the Revenue are dismissed

ITA 34/JAB/2014[2008-09]Status: DisposedITAT Jabalpur20 Sept 2023AY 2008-09

Bench: Shri Om Prakash Kantshri Pavan Kumar Gadale

Section 195Section 201Section 201(1)

price for supply of the plant was paid outside India. It was on firm CIF basis. The plant was handed over to the shipper on the strength of bill of lading. Therefore, the entire contract has attained culmination outside India and the appellant did not pay anything in India against the subsequent services. As a corollary, no income or profit

DEPUTY COMMISSIONER OF INCOME TAX, JABALPUR vs. ORIENT PAPER MILLS PROP. M/S ORIENT PAPERS &,

In the result, both the appeals filed by the Revenue are dismissed

ITA 35/JAB/2014[2009-10]Status: DisposedITAT Jabalpur20 Sept 2023AY 2009-10

Bench: Shri Om Prakash Kantshri Pavan Kumar Gadale

Section 195Section 201Section 201(1)

price for supply of the plant was paid outside India. It was on firm CIF basis. The plant was handed over to the shipper on the strength of bill of lading. Therefore, the entire contract has attained culmination outside India and the appellant did not pay anything in India against the subsequent services. As a corollary, no income or profit

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

section 45 as the income of the previous year in which the period of two years from the date of the transfer of the original asset expires; and (ii) the assessee shall be entitled to withdraw such amount in accordance with the scheme aforesaid. 4.2 We may begin by delineating the case of either side before us. The Revenue

ANURODH SAHU,JABALPUR vs. ITO (IT AND TP), BHOPAL

In the result, the appeal is allowed for statistical purposes

ITA 11/JAB/2024[2018-19]Status: DisposedITAT Jabalpur28 Nov 2025AY 2018-19

Bench: Sh. Kul Bharat & Sh. Nikhil Choudharya.Y. 2018-19 Anurodh Sahu, Vs. Ito (Ft & Tp), 3173, Tulsi Nagar Ranjhi, Jabalpur, Bhopal Madhya Pradesh Pan: Bktps9371L (Appellant) (Respondent) Assessee By: Sh. Anil Agrawal, C.A. Revenue By: Sh. Alok Bhura, Sr. Dr Date Of Hearing: 17.09.2025 Date Of Pronouncement: 28.11.2025 O R D E R Per Nikhil Choudhary, A.M.: This Is An Appeal Filed By The Assessee Against The Orders Of The Income Tax Officer (It & Tp), Bhopal At Jabalpur Dated 16.01.2024 Under Section 147 R.W.S. 144C(13) Of The Income Tax Act For The A.Y. 2018-19. The Grounds Of Appeal Are As Under: - “1. That The Assessment Order Issued By The Learned Assessing Officer On The Basis Of Directions Of Drp Is Unjustified & Base Less On The Basis Of Information & Documents Submitted. 2. That The Learned Assessing Officer Has Never Countered Or Produced Before The Assessee The Source Of Information/ Documents On Basis Of Which The Said Addition Appealed Against Is Made During Whole Assessment Proceedings. 3. That The Learned Assessing Officer Never Questioned The Relevant Sources Of Income Produced & Submitted By The Assessee During The Assessment Proceedings & Brought Nothing On Record To Prove Or Justify The Assessee Having Some Other Source Or Hidden Source Of Income. 4. That The Learned Assessing Officer Has Made The Additions On The Basis Of Incomplete Information Having No Evidence & Based On Surmises On The Directions Given By Drp.

For Appellant: Sh. Anil Agrawal, C.AFor Respondent: Sh. Alok Bhura, Sr. DR
Section 147Section 148Section 271

14,750/- on 31.03.2018 whereas it had been ascertained from the historical price of crypto currencies that the average price of those coins were Rs. 4,56,046/- and Rs. 7,832/-. The AO also wondered how the assessee had calculated profit of Rs. 1963/- without quantity wise details of purchase and sale. Thus, in view of the same

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)

section 144 of the Income Tax Act, 1961 (‘the Act’ hereinafter) for the Assessment Year (AY) 2005-06 vide Order dated 24/11/2010. 2. The appeal raises two grounds, as under, which shall be taken up in seriatim: ‘1. That the assessee had filed ITR declaring loss of Rs. 26,130 and the AO has estimated profit

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

section 143(3) of the Income Tax Act, 1961 (‘the Act’ hereinafter) for the Assessment Year (AY) 2012-13 vide order dated 13/2/2015. 2.1 The appeal raises two issues, which shall be taken up in seriatim. The first issue is in respect of two additions for Rs.4.00 lacs and Rs.1.50 lacs, i.e., at an aggregate of Rs.5.50 lacs

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 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

2)(b) of the Act. Further, the appellant has also submitted the judgements in the case of 3 | P a g e ITA No.93 & 94-Jab-2023 ACIT vs J.P.Tobacco Products Pvt.L td. group concerns of the appellant, wherein the Hon'ble Gujarat High Court has justified the deletion of addition on these grounds by the Hon'ble ITATS. Thus

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

2)(b) of the Act. Further, the appellant has also submitted the judgements in the case of 3 | P a g e ITA No.93 & 94-Jab-2023 ACIT vs J.P.Tobacco Products Pvt.L td. group concerns of the appellant, wherein the Hon'ble Gujarat High Court has justified the deletion of addition on these grounds by the Hon'ble ITATS. Thus