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

disallowances required to be \nmade only for purposes of computing income under normal provisions of the Act. \nAs per settled legal principles and provisions of Section 115JB, only certain \nspecified adjustments may be carried out for computing book profits, and hence \nthe above action of Ld.AO is contrary to the provisions of the Act.\n2. Under the facts and circumstances

SUNIL CHABLANI,AJMER, RAJASTHAN vs. CIRCLE (INTL TAX), JAIPUR, JAIPUR, RAJASTHAN

8) can confirm, reduce or enhance the variations\nproposed in the draft order so, however, that it shall not set aside any proposed\nvariation or issue any direction under sub-section (5) for further enquiry and\npassing of the assessment order. Since, the assessee has filed its objection\nunder section 144C of the Act read with Income Tax (Dispute Resolution

ASSISSTANT COMMISSIONER OF INCOME TAX, AJMER vs. SHREE CEMENT LTD, BEAWAR

section 80IA(8) of the Act.\n30.10. Considering that TPO has disputed the Grid rate not to be\nthe market value in terms of provisions of Section 80A(6) of the\nAct, we would like to state here that that unlike Section 80IA(8),\nthe word \"OR\" is missing in provisions of Section 80A(6) of the\nAct

SHREE CEMENT LIMITED,BEAWAR vs. DEPUTY COMMISSIONER OF INCOME TAX, AJMER

In the result, this appeal of the assessee is partly allowed and appeal of the Revenue is dismissed

Bench: HON’BLE SHRI SANDEEP GOSAIN, JM & HON’BLE SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

144C read with section 143(3) of the Act on 23.02.2018 by making various disallowances/additions to the returned income of the assessee as under :- - Reduction in claim u/s 80IA on power undertakings on account of transfer pricing adjustment of power (Rs. 2,89,07,63,321/-, - Reduction in claim u/s 80IA on Solid Waste Management System on account of transfer

INFOOBJECTS SOFTWARE INDIA PRIVATE LIMITED, JAIPUR,JAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 4, JAIPUR, JAIPUR

In the result, the appeal of the assessee is allowed

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, AM आयकर अपील सं. / ITA No. 1499/JP/2024 निर्धारण वर्ष / Assessment Year : 2021-22 Infoobjects Software India Vs. Deputy Commissioner of Private Ltd. Income Tax, 5-E Patrikayan, 3rd Floor Jhalana Circle-04, Jaipur Institutional Area, Jaipur स्थायी लेखा सं. / जीआईआर सं./PAN/GIR No.: AABCI8663B अपीलार्थी / Appellant प्रत्यर्थी / Respondent निर्धारिती की ओर से/ Assessee by : Sh. Naman Maloo, CA राजस्व की ओर से / Revenue by

144C read with section 144B of the Income Tax Act, 1961 dated 28.12.2023. The assessee filed an objection before the Hon'ble Dispute Resolution Panel [ for short DRP ] against the draft order. After considering the submission of the assessee, the Hon'ble DRP has passed order vide dated 27.09.2024 giving the following direction to the ld. AO; 10.2 The matter

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

144C dated 14.3.2014, the Assessing Officer has determined the total income at Rs.7,84,12,208/- as there was a disallowance under Section 32 (1) (iia) of Rs.3,53,65,893/- being additional depreciation and an addition of Rs.3,69,463/- due to transfer pricing adjustments. The Assessing Officer disallowed the same since the additional depreciation under Section

SHREE CEMENT LIMITED,BEAWAR vs. NATIONAL FACELESS ASSESSMENT ASSESSMENT CENTRE, DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2, AJMER, AJMER

144C passed by Ld. AO as invalid and void ab initio since it was not passed in accordance with the provisions of Section 144B(1)(xvi)(b) of the Act.\n6.1 In support of the ground so taken the ld. AR of the assessee submitted that the said ground being technical in nature is not being pressed in the interest

ASSISSTANT COMMISSIONER OF INCOME TAX, AJMER vs. SHREE CEMENT LTD, BEAWAR

Accordingly, the same is dismissed

144C as invalid and void ab initio which is liable to be quashed since not passed in accordance with the provisions of Section 144B(1)(xvi)(b) of the Act. 2. That on the facts and in the circumstances of the case, the Ld. CIT(Appeals) was not justified and erred in rejecting the appellant’s claim of allowing reliability

SHREE CEMENT LIMITED,BEAWAR vs. NATIONAL FACELESS ASSESSMENT CENTRE, DEPUTY COMMISSIONEROF INCOME TAX, CIRCLE -2, AJMER, AJMER

In the result, the appeal of the Revenue in ITA No

Bench: or at the time of hearing of this appeal.

Section 80IA(8), the word "OR" is missing in provisions of Section 80A(6) of the ACIT vs. Shree Cement Ltd. Act. It is noted that as per provisions of Section 80A(6), if any goods or services whether sold or acquired falls within the category specified domestic transactions of Section 92BA then in such case it is mandatory

SHREE CEMENT LIMITED,BEAWAR vs. NATIONAL FACELESS ASSESSMENT CENTRE, DELHI

In the result, the appeal of the Revenue in ITA No

Bench: or at the time of hearing of this appeal.

Section 80IA(8), the word "OR" is missing in provisions of Section 80A(6) of the ACIT vs. Shree Cement Ltd. Act. It is noted that as per provisions of Section 80A(6), if any goods or services whether sold or acquired falls within the category specified domestic transactions of Section 92BA then in such case it is mandatory

GILLETTE INDIA LIMITED,SPA-65A, INDUSTRIAL AREA, BHIWADI, DISTRICT- ALWAR vs. PCIT, JAIPUR-1, JAIPUR

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

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

8,05,089/- u/s 1941A and Rs 5,45,66.086/- u/s 1941B. Thus balance amount of Rs 3,20,28,825/- of rent was paid without TDS and 30% of this amount i.e. Rs. 96,08,647/- should have been disallowed u/s. 40(a)(ia) of the Act. (v) On going through ITR it is seen that as per clause

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

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

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

Disallowance u/s 14A Rs. 2,05,361/- Total Benefit Rs. 25,07,454/- 4. The ld. CIT (A) further erred in law as well as on the facts of the case in confirming the interest charged u/s 234D of the Act. The appellant totally denies its liability of charging of any such interest. The interest so charged, being contrary

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

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

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

Disallowance u/s 14A Rs. 2,05,361/- Total Benefit Rs. 25,07,454/- 4. The ld. CIT (A) further erred in law as well as on the facts of the case in confirming the interest charged u/s 234D of the Act. The appellant totally denies its liability of charging of any such interest. The interest so charged, being contrary

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

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

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

Disallowance u/s 14A Rs. 2,05,361/- Total Benefit Rs. 25,07,454/- 4. The ld. CIT (A) further erred in law as well as on the facts of the case in confirming the interest charged u/s 234D of the Act. The appellant totally denies its liability of charging of any such interest. The interest so charged, being contrary

SHREE CEMENT LIMITED,BEAWAR vs. PR.CIT, , UDAIPUR

In the result, the appeal of the assessee is allowed

Bench: Shri Sandeep Gosain, Jm & Shri Vikram Singh Yadav, Am Vk;Dj Vihy La-@Ita No. 04/Jp/2021 Assessment Year: 2014-15 Shree Cement Limited, Cuke Pr.Cit, Vs. Bangur Nagar, Post Box No. 33, Udaipur. Beawar. Pan No.: Aaccs 8796 G Vihykfkhz@Appellant Izr;Fkhz@Respondent Fu/Kzkfjrh Dh Vksj Ls@ Assessee By: Shri Dilip Desai (Ca) Shri Vijay Shah (Ca) Shri Mohit Choudhary (Ca) Jktlo Dh Vksj Ls@ Revenue By : Shri B.K. Gupta (Cit-Dr) Lquokbz Dh Rkjh[K@ Date Of Hearing : 01/04/2021 Mn?Kks"K.Kk Dh Rkjh[K@ Date Of Pronouncement : 23/06/2021 Vkns'K@ Order Per: Sandeep Gosain, J.M. The Present Appeal Has Been Filed By The Assessee Against The Order Of Ld. Pcit, Udaipur Dated 03.02.2021 Passed U/S 263 Of The Income Tax Act, 1961 (In Short The Act) For The Assessment Year 2014-15. The Grounds Of Appeal Taken By The Assessee Are As Under: “1. That On The Facts & In The Circumstances Of The Case, The Learned Principal Commissioner Of Income Tax – Udaipur, (Here- In- After Referred To As Ld. Pr. Cit) Was Not Justified In Initiating Proceedings U/S 263 Of The Income Tax Act, 1961 Since The Order Passed By The Assessing Officer (A.O.) Was Neither Erroneous Nor Prejudicial To The Interest Of The Revenue.

144C dated 28-12-2017 was forwarded by the A.O. to the Ld. PCIT. Total disallowances made in the order aggregates to Rs. 699 Crs. (Rs. 553 Crs. under normal provisions and Rs. 146 Crs. under the provisions of Section 115JB of the Act). As a result the refund claim of 7 ITA 04/JP/2021_ Shree Cement Ltd. Vs Pr.CIT

AJAY AGARWAL,JAIPUR vs. CIT (IT), DELHI-1, CIT(IT) DELHI

In the result, the appeal of the assessee is allowed

Bench: SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

144C(3) of the Act on 21.06.2021. 4. On culmination of the assessment proceeding the ld. PCIT called for the assessment records in exercise of the powers vested upon and upon verification of the assessment record the ld. PCIT noted that the assessment in the case of assessee for the A.Y 2018-19 passed by the AO is erroneous

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

disallowances required to be \nmade only for purposes of computing income under normal provisions of the Act. \nAs per settled legal principles and provisions of Section 115JB, only certain \nspecified adjustments may be carried out for computing book profits, and hence \nthe above action of Ld.AO is contrary to the provisions of the Act. \n\n2. Under the facts

SHREE CEMENT LIMITED,BEAWAR vs. NATIONAL FACELESS ASSESSMENT CENTRE, DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE -2, AJMER, AJMER

144C passed by Ld. AO as \ninvalid and void ab initio since it was not passed in \naccordance with the provisions of Section 144B(1)(xvi)(b) of \nthe Act.\n6.1 In support of the ground so taken the ld. AR of the assessee \nsubmitted that the said ground being technical in nature is not \nbeing pressed in the interest