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13 results for “condonation of delay”+ Section 144C(1)clear

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Key Topics

Section 143(3)16Section 153C15Section 153D12Section 25010Addition to Income8Section 2637Limitation/Time-bar7Section 1476Section 271(1)(c)

SONU DUSAD,JAIPUR vs. DCIT CENTRAL CIRCLE, 1, JAIPUR, JAIPUR

In the results, the appeal of the assessee in ITA no

ITA 507/JPR/2025[A.Y. 2018-19]Status: DisposedITAT Jaipur12 Nov 2025

Bench: This Tribunal Are As Under :

For Appellant: Sh. Mukesh Soni, AdvFor Respondent: Mrs. Anita Rinesh, JCIT-DR
Section 144CSection 153CSection 153DSection 250

1) arises as a consequence of the order of the Transfer Pricing Officer passed under sub-section (3) of section 92CA; and (ii) any non-resident not being a company, or any foreign company: 11. From the bare reading of the above-mentioned provisions of Section 144C, it is evident that the Assessing Officer must forward a draft

6
Section 144C5
Disallowance5
Deduction4

SONU DUSAD,JAIPUR vs. DCIT CENTRAL CIRCLE, 1, JAIPUR, JAIPUR

In the results, the appeal of the assessee in ITA no

ITA 505/JPR/2025[2015-16]Status: DisposedITAT Jaipur12 Nov 2025AY 2015-16

Bench: This Tribunal Are As Under :

For Appellant: Sh. Mukesh Soni, AdvFor Respondent: Mrs. Anita Rinesh, JCIT-DR
Section 144CSection 153CSection 153DSection 250

1) arises as a consequence of the order of the Transfer Pricing Officer passed under sub-section (3) of section 92CA; and (ii) any non-resident not being a company, or any foreign company: 11. From the bare reading of the above-mentioned provisions of Section 144C, it is evident that the Assessing Officer must forward a draft

SONU DUSAD,JAIPUR vs. DCIT CENTRAL CIRCLE, 1, JAIPUR, JAIPUR

In the results, the appeal of the assessee in ITA no

ITA 508/JPR/2025[2020-21]Status: DisposedITAT Jaipur12 Nov 2025AY 2020-21

Bench: This Tribunal Are As Under :

For Appellant: Sh. Mukesh Soni, AdvFor Respondent: Mrs. Anita Rinesh, JCIT-DR
Section 144CSection 153CSection 153DSection 250

1) arises as a consequence of the order of the Transfer Pricing Officer passed under sub-section (3) of section 92CA; and (ii) any non-resident not being a company, or any foreign company: 11. From the bare reading of the above-mentioned provisions of Section 144C, it is evident that the Assessing Officer must forward a draft

SONU DUSAD,JAIPUR vs. DCIT CENTRAL CIRCLE, 1, JAIPUR, JAIPUR

In the results, the appeal of the assessee in ITA no

ITA 506/JPR/2025[2016-17]Status: DisposedITAT Jaipur12 Nov 2025AY 2016-17

Bench: This Tribunal Are As Under :

For Appellant: Sh. Mukesh Soni, AdvFor Respondent: Mrs. Anita Rinesh, JCIT-DR
Section 144CSection 153CSection 153DSection 250

1) arises as a consequence of the order of the Transfer Pricing Officer passed under sub-section (3) of section 92CA; and (ii) any non-resident not being a company, or any foreign company: 11. From the bare reading of the above-mentioned provisions of Section 144C, it is evident that the Assessing Officer must forward a draft

SONU DUSAD,JAIPUR vs. DCIT CENTRAL CIRCLE, 1, JAIPUR, JAIPUR

In the results, the appeal of the assessee in ITA no

ITA 509/JPR/2025[2021-22]Status: DisposedITAT Jaipur12 Nov 2025AY 2021-22
For Appellant: Sh. Mukesh Soni, AdvFor Respondent: Mrs. Anita Rinesh, JCIT-DR
Section 144CSection 153CSection 153DSection 250

1) arises as a\nconsequence of the order of the Transfer Pricing Officer passed under sub-section (3)\nof section 92CA; and\n(ii) any non-resident not being a company, or any foreign company:\n11. From the bare reading of the above-mentioned provisions of Section\n144C, it is evident that the Assessing Officer must forward a draft

KOSHAL KISHOR SHARMA,JAIPUR vs. DCIT(INTL. TAX), JAIPUR, JAIPUR

In the result, appeals of the assessee are allowed

ITA 861/JPR/2025[2015-16]Status: DisposedITAT Jaipur15 Sept 2025AY 2015-16

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

For Appellant: Shri Shrawan Kumar Gupta, AdvFor Respondent: Shri Dharam Singh Meena, JCIT-DR
Section 147Section 148ASection 234ASection 250Section 271(1)(c)Section 69Section 69A

section 5 of Limitation act. Koshal Kishor Sharma, Jaipur. 8. That due to all this reason the appeal could not be filed within time. 9. That the contents or averment of application for condonation of delay are true and correct and may be treated as part of this affidavit. Place : Date : .05.2025. Deponent VERIFICATION I, Koshal Kishor Sharma S/o Bhanwar

KOSHAL KISHOR SHARMA,JAIPUR vs. DCIT(INTL. TAX.) JAIPUR, JAIPUR

In the result, appeals of the assessee are allowed

ITA 862/JPR/2025[2015-16]Status: DisposedITAT Jaipur15 Sept 2025AY 2015-16

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

For Appellant: Shri Shrawan Kumar Gupta, AdvFor Respondent: Shri Dharam Singh Meena, JCIT-DR
Section 147Section 148ASection 234ASection 250Section 271(1)(c)Section 69Section 69A

section 5 of Limitation act. Koshal Kishor Sharma, Jaipur. 8. That due to all this reason the appeal could not be filed within time. 9. That the contents or averment of application for condonation of delay are true and correct and may be treated as part of this affidavit. Place : Date : .05.2025. Deponent VERIFICATION I, Koshal Kishor Sharma S/o Bhanwar

RESONANCE EDUVENTURES LIMITED, KOTA,KOTA vs. ACIT DCIT, CENTRAL CIRCLE, KOTA, KOTA

In the result, all the appeals of the assessee are allowed

ITA 669/JPR/2024[2015-16]Status: DisposedITAT Jaipur10 Mar 2025AY 2015-16

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

For Appellant: Shri Mahendra Gargieya, Adv. (Thr. V.C)&For Respondent: Smt. Alka Gautam, CIT-DR
Section 143(3)Section 14ASection 153DSection 234DSection 250

144C (5), when noticed that no DIN was mentioned therein, held as under: “21. Respectfully following the above order of the Tribunal, since the DIN was not mentioned in DRP order dated 30.12.2021 which was mandatory as per Resonance Eduventures Ltd., Kota. CBDT Circular No.19 (supra) & in view of the facts noted above in regard to communications done with

RESONANCE EDUVENTURES LIMITED,KOTA vs. ACIT DCIT, CENTRAL CIRCLE,, KOTA

In the result, all the appeals of the assessee are allowed

ITA 672/JPR/2024[2018-19]Status: DisposedITAT Jaipur10 Mar 2025AY 2018-19

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

For Appellant: Shri Mahendra Gargieya, Adv. (Thr. V.C)&For Respondent: Smt. Alka Gautam, CIT-DR
Section 143(3)Section 14ASection 153DSection 234DSection 250

144C (5), when noticed that no DIN was mentioned therein, held as under: “21. Respectfully following the above order of the Tribunal, since the DIN was not mentioned in DRP order dated 30.12.2021 which was mandatory as per Resonance Eduventures Ltd., Kota. CBDT Circular No.19 (supra) & in view of the facts noted above in regard to communications done with

RESONANCE EDUVENTURES LIMITED,,KOTA vs. ACIT DCIT, CENTRAL CIRCLE, , KOTA

In the result, all the appeals of the assessee are allowed

ITA 671/JPR/2024[2017-18]Status: DisposedITAT Jaipur10 Mar 2025AY 2017-18

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

For Appellant: Shri Mahendra Gargieya, Adv. (Thr. V.C)&For Respondent: Smt. Alka Gautam, CIT-DR
Section 143(3)Section 14ASection 153DSection 234DSection 250

144C (5), when noticed that no DIN was mentioned therein, held as under: “21. Respectfully following the above order of the Tribunal, since the DIN was not mentioned in DRP order dated 30.12.2021 which was mandatory as per Resonance Eduventures Ltd., Kota. CBDT Circular No.19 (supra) & in view of the facts noted above in regard to communications done with

RESONANCE EDUVENTURES LIMITED,KOTA,KOTA vs. ACIT DCIT, CENTRAL CIRCLE, KOTA, KOTA

In the result, all the appeals of the assessee are allowed

ITA 670/JPR/2024[2016-17]Status: DisposedITAT Jaipur10 Mar 2025AY 2016-17
For Appellant: Shri Mahendra Gargieya, Adv. (Thr. V.C)&For Respondent: Smt. Alka Gautam, CIT-DR
Section 143(3)Section 14ASection 153DSection 234D

144C (5), when noticed that no DIN was mentioned therein, held as\nunder:\n“21. Respectfully following the above order of the Tribunal, since the DIN was\nnot mentioned in DRP order dated 30.12.2021 which was mandatory as per\n9\nITA Nos.669 to 672/JPR/2024\nResonance Eduventures Ltd., Kota.\nCBDT Circular No.19 (supra) & in view of the facts noted above

PRADEEP KUMAR ROCHWANI, JODHPUR,JODHPUR vs. CIRCLE (INTL TAX), JAIPUR, JAIPUR

In the result, appeal of the assessee is allowed

ITA 567/JPR/2025[2018-19]Status: DisposedITAT Jaipur15 Sept 2025AY 2018-19

Bench: DR. MITHA LAL MEENA (Accountant Member), DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Shri Rajendra Jain, Adv. (throughFor Respondent: Shri Rajesh Ojha, CIT-DR a
Section 143(3)Section 144C(1)Section 263

144C(1) of the Act issued with reference to 263 order which was passed on 28.03.2024. 6. Further the legal counsel had advised to the authorized representative that order passed u/s 263 of the Act is contrary to provision of law and also to be challenged before the Hon’ble ITAT Bench as such facts had been communicated

VAIBHAV GLOBAL LIMITED,JAIPUR vs. DCIT, CC-4, JAIPUR

In the result, the appeal of the assessee in ITA no

ITA 1144/JPR/2024[2020-21]Status: DisposedITAT Jaipur30 Jun 2025AY 2020-21
For Appellant: Shri Vinod Kumar Gupta, AdvFor Respondent: Shri Rajesh Ojha, CIT-DR
Section 115JSection 115QSection 143(3)Section 144C(5)Section 36(1)(va)

144C(13) of the Income Tax Act, 1961. - 3. The Ld. TPO and Hon'ble DRP has erred on facts and in law in proposing an adjustment of amount of Rs. 136,31,75,249/- to the income of the appellant on account of alleged difference in Arm's Length Price (ALP) of the international transaction of sale and purchase