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

disallowance based on the evidence which were already presented before Id. DRP. The action of the Id. DRP is illegal, unjustified, and arbitrary, contrary to the legal position as set out in Section 144C of the Income Tax Act, 1961.” 3. Succinctly, the facts as culled out from the records related to the dispute carried in this appeal are that

MANIRATNAM GEMS PVT. LTD.,BEAWAR vs. ACIT,C-2, AJMER

In the result, the appeal filed by the assessee is allowed

section 92 or 92B with any specified associate concern nor had any transaction with specified person in domestic transactions, as such there was no requirement of any report being furnished in form 3CEB, u/s 92E of the Act. The provisions of Transfer Pricing were not applicable, and there was no requirement of any reference to TPO. The appellant also referred

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

sections": [ "143(3)", "144C(13)", "144C(5)", "92D", "10D", "92C(3)", "92B", "92C", "115JB", "270A", "36(1)(va)", "115QA", "69C", "115QB", "10B(2)", "10C", "92", "10A" ], "issues": "The key issues involve the appropriateness of the transfer pricing method and comparable companies used, the chargeability of interest on outstanding receivables, the disallowance