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7 results for “transfer pricing”+ Set Off of Lossesclear

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Key Topics

Section 37(1)9Addition to Income7Disallowance6Section 405Section 143(3)3Section 1443Business Income3Section 142(1)2Section 143(2)

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

set of two appeals by the Assessee, agitating the adjudication by the Commissioner of Income Tax (Appeals)-1, Jabalpur (‘CIT(A)’, for short), partly allowing it’s appeals contesting it’s assessments under section 143(3) of the Income Tax Act, 1961 (‘the Act’ hereinafter) dated 26/12/2006 and 24/12/2007 for Assessment Years (AYs.) 2004-05 & 2005-06 respectively, vide

2
Section 145(3)2

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

price fluctuate erratically and hence the need of fund is uncertain and needs to carry huge funds is essential in the interest of business. In the same manner Tendu Patta is another major raw material which is being auctioned by the Government only. Government has introduced Tender system and the payment policy are subject to sudden changes which also supports

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

price fluctuate erratically and hence the need of fund is uncertain and needs to carry huge funds is essential in the interest of business. In the same manner Tendu Patta is another major raw material which is being auctioned by the Government only. Government has introduced Tender system and the payment policy are subject to sudden changes which also supports

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

price fluctuate erratically and hence the need of fund is uncertain and needs to carry huge funds is essential in the interest of business. In the same manner Tendu Patta is another major raw material which is being auctioned by the Government only. Government has introduced Tender system and the payment policy are subject to sudden changes which also supports

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

price fluctuate erratically and hence the need of fund is uncertain and needs to carry huge funds is essential in the interest of business. In the same manner Tendu Patta is another major raw material which is being auctioned by the Government only. Government has introduced Tender system and the payment policy are subject to sudden changes which also supports

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

price fluctuate erratically and hence the need of fund is uncertain and needs to carry huge funds is essential in the interest of business. In the same manner Tendu Patta is another major raw material which is being auctioned by the Government only. Government has introduced Tender system and the payment policy are subject to sudden changes which also supports

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)

loss, is thus Rs.9,79,868, or about 3% of sales, the quantum of which approximates that by the assessee for the relevant year. It is this profit rate that is therefore relevant and comparable. The said case, which is thus comparable, favours the Revenue’s estimation rather than being supportive of the assessee’s case. Rather, normal market conditions