M/S ETERNAL HEART CARE CENTRE & RESEARCH INSTITUTE PVT. LTD. ,3A, JAGATPURA ROAD, NEAR JAWAHAR CIRCLE, JAIPUR vs. PCIT, JAIPUR-2, JAIPUR

In the result, appeal filed by the assessee is allowed

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

section 14A of the IT Act, 1961. Hence, the Ground No. 1 of the assessee is allowed. 3.1 Apropos Ground NO. 2 of the assessee, it is noted that Ld. PCIT vide show cause notice dt. 28.02.2023 issued u/s 263 (PB 1-3) observed that assessee has made following international transactions with the associate enterprises which have not been reported

RAJASTHAN STATE INDUSTRIAL DEVELOPMENT & INVESTMENT CORP. LTD.,JAIPUR vs. ACIT, JAIPUR

In the result, both set of cross appeals for the respective assessment years are disposed off with above directions

14A of the Income-tax Act. 5. Whether on the facts and circumstances of the case and in law, the ld. CIT(A) was justified in allowing deduction u/s 80IA on interest income including penal interest income and on other income. 6. (a) Whether on the facts and circumstances of the case

SH. NAWAL KISHORE DANGAYACH,A-34-A, RAM NAGAR, SHASTRI NAGAR, JAIPUR vs. ACIT, CIRCLE-4, , JAIPUR

In the result, appeal of the assessee is partly allowed

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

Section 14A cannot be invoked when no exempt income was earned by the assesse in the relevant year. We also take reference of decision of Hon’ble Bombay High Court in the case of PCIT vs Worckhardt Hospitals Ltd (supra) wherein it is ordered that Assessee had not earned any exempt income during the assessment year under consideration

M/S RAJASTHAN STATE INDUSTRIAL DEVELOPMENT AND INVESTMENT CORPORATION LTD.,JAIPUR vs. DCIT, CIRCLE-6, JAIPUR, JAIPUR

In the result, both the appeals of the assessee are allowed as indicated hereinabove

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI GAGAN GOYAL (Accountant Member)

TDS 1,44,565 Nil Nil Thus after the order of ITAT dt.10.04.2018 (PB 18-83), following disallowance made by the AO stood confirmed:- RAJASTHAN STATE INDUSTRIAL DEVELOPMENT & INVESTMENT CORPORATION LTD VS DCIT, CIRCLE-6, JAIPUR Disallowance of CSR Expenses Rs.1,41,42,000/- Disallowance u/s 14A Rs. 71,75,575/- After the order of Hon’ble ITAT, AO again

M/S RAJASTHAN STATE INDUSTRIAL DEVELOPMENT & INVESTMENT CORPORATION LTD.,JAIPUR vs. DCIT, CIRCLE-6, JAIPUR, JAIPUR

In the result, both the appeals of the assessee are allowed as indicated\nhereinabove

TDS | 1,44,565 | Nil | Nil\n\nThus after the order of ITAT dt.10.04.2018 (PB 18-83), following disallowance\nmade by the AO stood confirmed:-\n\n5\nITA NO.309 & 310/JPR/2025\nRAJASTHAN STATE INDUSTRIAL DEVELOPMENT & INVESTMENT CORPORATION LTD VS DCIT, CIRCLE-6, JAIPUR\n\nDisallowance of CSR Expenses\nDisallowance u/s 14A\nRs.1,41,42,000/-\nRs.71,75,575/-\n\nAfter

DEREWALA INDUSTRIES LIMITED,JAIPUR vs. ACIT/DCIT CIR-6, JAIPUR

Appeal is partly allowed; while

Bench: SHRI GAGAN GOYAL (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

TDS; after disallowance a sum of Rs. 5,73,999/- worked out u/s. 14A of the Act; and after disallowance of a sum of Rs.75,000/-as per provisions of section

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-6, JAIPUR vs. M/S. ANAMIKA CONDUCTORS LTD., JAIPUR

In the result, appeal of the Revenue is dismissed and cross objection of the assessee is allowed

14A of IT Act. (4) Ld. CIT(A) was not justified in sustaining addition of Rs. 29,350/- for business exp. ignoring the fact that the assessee Company.” 2. Regarding ground no. 1 of the Revenue’s appeal and the ground no. 1 of the assessee’s cross objection, the ld. AR submitted that in appellant’s own case

JAIPUR TELECOM PRIVATE LIMITED,JAIPUR vs. DCIT CIRCLE 1, JPR, JAIPUR

In the result the appeal of the assessee in ITA no

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

14A -Held, yes -Whether this by no stretch of imagination could be held to be 'misreporting' - Held, yes - Whether further, in absence of details as to which limb of section 270A was attracted and how ingredient of sub-section (9) of section 270A was satisfied, mere reference to word 'misreporting' by revenue in penalty order to deny immunity from imposition

JAIPUR TELECOM PVT. LTD,JAIPUR vs. DCIT CIRCLE 1, JPR, JAIPUR

In the result the appeal of the assessee in ITA no

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

14A -Held, yes -Whether this by no stretch of imagination could be held to be 'misreporting' - Held, yes - Whether further, in absence of details as to which limb of section 270A was attracted and how ingredient of sub-section (9) of section 270A was satisfied, mere reference to word 'misreporting' by revenue in penalty order to deny immunity from imposition

M/S MITTAL PHARMA PVT. LTD.,JAIPUR vs. INCOME TAX OFFICER, WARD-1-2, JAIPUR

In the result, the appeal of the assessee is partly allowed for

TDS on payments made to residents as specified in section 40(a)(ia) of the Act, the disallowance shall be restricted to 30% of the amount of expenditure claimed. ” ITA 734/JP/2017_ 8 M/s Mittal Pharma P. Ltd. Vs ITO The Finance Minister while introducing the amendment in para 207 of the Budget Speech has stated as under: - “207. Currently, where

M/S. MAHARAJA SHREE UMAID MILLS LTD. JAIPUR,JAIPUR vs. DCIT CIRCLE-6, JAIPUR, CIRCLE-6, JAIPUR

In the result, the ground of appeal is allowed for statistical purposes

14A exceeds the dividend income claimed as exempt by the assessee. The Therefore, disallowance on account of administrative expenses under Rule 8D(iii) is hereby restricted to the extent of exempt income so claimed by the assessee. In the result, the ground of appeal is partly allowed. 10. In ground no. 2, the assessee has challenged the disallowance of depreciation

ASSOCIATED SOAPSTONE DISTRIBUTING CO PRIVATE LIMITED,JAIPUR vs. PRINCIPAL COMMISSIONER OF INCOME TAX -2, JAIPUR, JAIPUR

Section 14A, read with Rule 8D, of Rs. 23,31,312 ["Issue No. 1”]. • Interest of Rs. 55,810 on delayed payment of TDS

AU SMALL FINANCE BANK LIMITED,JAIPUR vs. PRINCIPAL COMMISSIONER OF INCOME TAX, JAIPUR-1

In the result both the appeals filed by the assessee in ITA

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

Section 115JB of the Act. 6. Under the facts and the circumstances of the case and in law the Ld.PCIT, Jaipur-1 has grossly erred in directing the AO for fresh assessment even after appreciating the certificate u/s 35AC(2) of the Act, as submitted during the proceedings u/s 263 of the Act. 7. Under the facts and the circumstances

M/S GVK JAIPUR EXPRESSWAY PRIVATE LIMITED,TELANGANA vs. PCIT 2, JAIPUR

In the result, the appeal of the assessee is allowed

14A of the Act, while directing that the said\ndisallowance be made u/s 36(1)(iii) of the Act and further holding that the said\ndisallowance cannot be added back to the assessee's income computed under\nthe provisions of section 115JB of the Act.\"\n30. Similar is the position in the Hon'ble High Court in relation to\nother

ITO, KOTA vs. BABU LAL SOMANI, KOTA

14A. One has to read entire letter together and from this letter one cannot infer that the A.O. referred the matter for special audit for getting the books of accounts prepared. The facts in the instant case are distinguishable from the facts of CIT vs. Bajrang Textiles (supra) in which the audit was referred just one day prior

GEETANJALI HOTELS & PROMOTERS PVT LTD,JAIPUR vs. ACIT, JAIPUR

In the result, the appeals of the assessee in ITA No

14A.(AO Pg 5-6 ) 3 Investment in AOPs (PB 3,82,10,700/- The investment in the AOP is 41) made to obtain the liquor contract in Rajasthan. The AOP was obtaining liquor [Initial investment contract in earlier years and in as such, was commercial F.Y 2012-13 investment only. (A.Y 2013-14)] Total

GEETANJALI HOTELS & PROMOTERS PVT LTD,JAIPUR vs. ACIT, JAIPUR

In the result, the appeals of the assessee in ITA No

14A.(AO Pg 5-6 ) 3 Investment in AOPs (PB 3,82,10,700/- The investment in the AOP is 41) made to obtain the liquor contract in Rajasthan. The AOP was obtaining liquor [Initial investment contract in earlier years and in as such, was commercial F.Y 2012-13 investment only. (A.Y 2013-14)] Total

JCIT, RANG-2, KOTA vs. CHAMBAL FERTILISERS AND CHEMICALS LIMITED, KOTA

In the result, respective grounds of appeal are allowed for statistical purposes

14A on estimated basis in respect of expenses attributable to making of investment in M/s Chambal Fertilizers & Chemicals Ltd. Vs. ACIT mutual funds and the L'd CIT(Appeals) erred in confirming the same without proving any nexus between investments and expenditure. Hence the addition made on this account deserves to be deleted. 4. That the L'd Joint Commissioner