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18 results for “transfer pricing”+ Transfer Pricingclear

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Key Topics

Section 143(3)13Addition to Income12Section 37(1)9Disallowance9Section 201(1)8Section 405Section 148(1)5Section 2014Section 147

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)

transferred the property prior to the Asst. Year 2003-04. Hence, provision of section 50C of the Act was not applicable. In view of the above facts, the assessing officer is not justified in increasing the sale price

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

4
Section 693
Business Income3
Deduction3

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

price as defined in clause (ii) of section 92F, where the transfer of such goods or services is a specified

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

transfer of capital asset and sale price in accordance to the provision of Section 48 of the I.T Act. Adhoc

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

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

transferred to B & S portal to be sold later in future financial years. A statement of trading of crypto currency done by the assessee through Koinex Platform for the F.Y. 2017-18 through his SBI NRO A/c No. 3477740067 was 3 Anurodh Sahu A.Y. 2018-19 furnished. Ongoing through statement submitted by the assessee, the ld. AO noted that

INCOME TAX OFFICER, WARD-2 (3), JABALPUR vs. SHRI VINOD KUMAR CHATE, JABALPUR

ITA 134/JAB/2018[2012-13]Status: DisposedITAT Jabalpur30 Mar 2022AY 2012-13
Section 1Section 139Section 143(3)Section 147Section 148(1)

transfer of title that was completed in 1987, it is the fmv as on 1.4.1981 (Rs. 10.41 lacs) that shall apply, as against the cost of 1987 (Rs.16.09 lacs), for which no basis though has been shown by the assessee. This aspect, pointed out in revision, is not in dispute, with the assessee even conveying his consent

SHRI VINOD KUMAR CHATE,JABALPUR vs. COMMISSIONER OF INCOME TAX-2, JABALPUR

ITA 60/JAB/2017[2012-13]Status: DisposedITAT Jabalpur30 Mar 2022AY 2012-13
Section 1Section 139Section 143(3)Section 147Section 148(1)

transfer of title that was completed in 1987, it is the fmv as on 1.4.1981 (Rs. 10.41 lacs) that shall apply, as against the cost of 1987 (Rs.16.09 lacs), for which no basis though has been shown by the assessee. This aspect, pointed out in revision, is not in dispute, with the assessee even conveying his consent

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

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

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

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

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

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

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

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)

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

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

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

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