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11 results for “transfer pricing”+ Section 5(2)clear

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Key Topics

Section 37(1)9Section 201(1)8Addition to Income8Disallowance7Section 405Section 143(3)4Section 2014Section 14A3Section 153A3

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 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)

5 read with section 9 of the Act. Before the Ld. CIT(A), the assessee filed detailed copy of the Contract Agreement and submitted that the Agreement only provides for supervision services for installations of plant and machinery in India by the Italian 6 | P a g e ITA Nos.34 & 35/Jab/2014 DCIT vs Orient Paper Mills company, that too, free

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

Business Income3
Section 1952
Deduction2
ITA 35/JAB/2014[2009-10]Status: Disposed
ITAT Jabalpur
20 Sept 2023
AY 2009-10

Bench: Shri Om Prakash Kantshri Pavan Kumar Gadale

Section 195Section 201Section 201(1)

5 read with section 9 of the Act. Before the Ld. CIT(A), the assessee filed detailed copy of the Contract Agreement and submitted that the Agreement only provides for supervision services for installations of plant and machinery in India by the Italian 6 | P a g e ITA Nos.34 & 35/Jab/2014 DCIT vs Orient Paper Mills company, that too, free

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

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

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

2 Rashmeet Singh Malhotara 3. On the facts and in the circumstances of the case, the Ld.CIT (A) erred and is not justified In confirming the addition/disallowance of Rs.3,79,043/- made by the Assessing Officer under section 14A read with Rule 8D of the Income Tax Rules, 1962. The same may be deleted in toto in the interest

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

5. That the direction given by DRP has not appreciated the replies, proofs and documents submitted by the assessee and ignored it without any justification solely based on information provided by the Assessing Officer having no justified source and never presented before the assessee. 6. That the Kionex App from which the transaction was done has been closed

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

2)(b) of the Act. Further, the appellant has also submitted the judgements in the case of 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 the Honourable Gujarat High court, took into consideration the Commercial Expediency of the Borrowing and belon

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

2)(b) of the Act. Further, the appellant has also submitted the judgements in the case of 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 the Honourable Gujarat High court, took into consideration the Commercial Expediency of the Borrowing and belon

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

2)(b) of the Act. Further, the appellant has also submitted the judgements in the case of 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 the Honourable Gujarat High court, took into consideration the Commercial Expediency of the Borrowing and belon

JILA SAHKARI KENDRIYA BANK MAYDT vs. ASST. COMMISSIONER OF INCOME TAX CIRCLE SAGAR, SAGAR

In the result, the appeal filed by the Revenue is dismissed

ITA 12/JAB/2017[2006-07]Status: DisposedITAT Jabalpur22 Sept 2023AY 2006-07

Bench: Shri Om Prakash Kantshri Pavan Kumar Gadaleasst. Commissioner Of Vs Shri Sarabjeet Singh Income Tax, Circle-2(1), Mokha, 1112, Jabalpur. Pachpedi, South Civil Lines, Jabalpur (Appellant) (Respondent) Pan No. Afxpm8245F Revenue By Shri Shravan Kumar Gotru, Cit Dr Assessee By Shri Rahul Bardia, Ca Date Of Hearing 15/09/2023 Date Of Pronouncement 22/09/2023

Section 10Section 132Section 153A

transfer found in the paper seized during the course of search, total valuation was noted as Rs.6.25 crores. The AO accordingly, made addition in the hands of the assessee in proportion to 37.5% of the shares out of Rs. 6.25 crores which was worked out to Rs.2.34 crores. Before Ld.CIT(A), the assessee contested that addition for the entire amount

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