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11 results for “disallowance”+ Section 92C(3)clear

Sorted by relevance

Mumbai697Delhi576Bangalore313Pune191Kolkata143Ahmedabad107Chennai69Hyderabad55Indore15Visakhapatnam11Jaipur11Karnataka7Cochin6Surat5Raipur3Jodhpur2Amritsar2Guwahati2Calcutta2Panaji2Jabalpur1Nagpur1Telangana1

Key Topics

Section 80I16Section 143(3)9Section 92C9Addition to Income8Transfer Pricing7Disallowance7Section 115J6Section 805Comparables/TP5TP Method

VAIBHAV GLOBAL LIMITED,JAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-5, JAIPUR

In the result, the penalty is directed to be deleted and appeal of the assessee is allowed

ITA 731/JPR/2018[2010-11]Status: DisposedITAT Jaipur19 Dec 2018AY 2010-11
For Appellant: Shri Vijay Mehta (C.A.) &For Respondent: Smt. Roli Agarwal (CIT)
Section 143(3)Section 271(1)(c)Section 92C

3 of the assessment order, the assessing officer, AO observed as under: - Vaibhav Global Ltd. vs. ACIT “As the assessee has concealed/furnished the inaccurate particulars of income therefore, penalty u/s 271 (1) (c) is also initiated.” 3.3 As per section 271 (1) (c), the assessing officer is empowered to impose penalty if in the course of any proceedings under this

VAIBHAV GLOBAL LIMITED,JAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-5, JAIPUR

4
Section 1433
Section 36(1)(va)3

In the result, the penalty is directed to be deleted and appeal of the assessee is allowed

ITA 730/JPR/2018[2009-10]Status: DisposedITAT Jaipur19 Dec 2018AY 2009-10
For Appellant: Shri Vijay Mehta (C.A.) &For Respondent: Smt. Roli Agarwal (CIT)
Section 143(3)Section 271(1)(c)Section 92C

3 of the assessment order, the assessing officer, AO observed as under: - Vaibhav Global Ltd. vs. ACIT “As the assessee has concealed/furnished the inaccurate particulars of income therefore, penalty u/s 271 (1) (c) is also initiated.” 3.3 As per section 271 (1) (c), the assessing officer is empowered to impose penalty if in the course of any proceedings under this

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

ITA 152/JPR/2023[2014-15]Status: DisposedITAT Jaipur07 Aug 2023AY 2014-15

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

For Appellant: Shri Vijay Shah, CAFor Respondent: Shri Arvind Kumar, CIT
Section 115JSection 250Section 32(1)(ii)Section 80Section 80I

section (6) to provide that, with effect from 1-4-2012, the provisions of sub-section shall cease to have effect. Accordingly, a SEZ developer or any entrepreneur carrying on business in an SEZ unit (being a company) would be liable to pay MAT on the profits arising from the development of SEZ or the business carried

M/S CENTURY INFRA POWER P. LTD.,JAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2, JAIPUR

In the result, appeal of the assessee is allowed

ITA 169/JPR/2019[2014-15]Status: DisposedITAT Jaipur02 Oct 2019AY 2014-15
For Appellant: Shri Manish Agarwal (CA)For Respondent: Sh. Bhanwar Singh (JCIT)
Section 143Section 143(2)Section 32(1)Section 92CSection 92C(3)

92C(3) of the Act. 2.2 That the Id. CIT(A) has further erred in not considering the fact that the assessee had paid interest @ 13% on funds borrowed from banks, and thus a payment of interest @15%, which is 2% plus bank- rate, was an acceptable parameter to establish arm's-length rate being considered by the assessee

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

ITA 1485/JPR/2024[2021-22]Status: DisposedITAT Jaipur30 Jun 2025AY 2021-22
For Appellant: Shri Vinod Kumar Gupta, AdvFor Respondent: Shri Rajesh Ojha, CIT-DR
Section 115JSection 115QSection 143(3)Section 36(1)(va)

Section 92C(3) of the Act has not been satisfied. \n\n2. Under the facts and circumstances of the case and in law, the Ld. TPO, Ld. AO \nand the Hon'ble DRP erred in rejecting the Transactional Net Margin Method \n(TNMM) considered by the appellant as the Most Appropriate Method ('MAM') with \nOperating profit margin/ Operating Expenses (OP/OE

WORSHIP INFRAPROJECTS PRIVATE LIMITED,JAIPUR vs. DCIT, CEIRCLE-2, JAIPUR

In the result of the appeal of the assessee is allowed

ITA 394/JPR/2022[2014-15]Status: DisposedITAT Jaipur22 May 2023AY 2014-15

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Vijay Goyal, CA &For Respondent: Shri A.K. Bhardwaj, CIT &
Section 92C

3,18,71,174 1,62,42,947 Difference in 3.22% 1.64% percentage Since the difference in between the Arm's length price and actual price is within the limit prescribed in the second proviso to section 92C(2) of Income Tax Act, the difference should be ignored. 4.2 No disallowance

DEPUTY COMMISSIONER OF INCOME TAX, JAIPUR vs. M/S WORSHIP INFRAPROJECTS PVT LTD(PREVIOUSLY KNOWN AS OM METALS SPML INFRAPROJECTS PVT LTD), JAIPUR

In the result of the appeal of the assessee is allowed

ITA 431/JPR/2022[2014-15]Status: DisposedITAT Jaipur22 May 2023AY 2014-15

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Vijay Goyal, CA &For Respondent: Shri A.K. Bhardwaj, CIT &
Section 92C

3,18,71,174 1,62,42,947 Difference in 3.22% 1.64% percentage Since the difference in between the Arm's length price and actual price is within the limit prescribed in the second proviso to section 92C(2) of Income Tax Act, the difference should be ignored. 4.2 No disallowance

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

ITA 496/JPR/2023[2016-17]Status: DisposedITAT Jaipur21 Feb 2024AY 2016-17

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

For Appellant: Sh. Dilip B Desai(C.A.)For Respondent: Sh. Alka Gautam (CIT) (V.H) &
Section 115JSection 143Section 143(3)Section 144BSection 144B(1)(xvi)Section 80Section 80I

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

ITA 500/JPR/2023[215-16]Status: DisposedITAT Jaipur21 Feb 2024

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

For Appellant: Sh. Dilip B Desai(C.A.)For Respondent: Sh. Alka Gautam (CIT) (V.H) &
Section 115JSection 143Section 143(3)Section 144BSection 144B(1)(xvi)Section 80Section 80I

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

ACIT, ALWAR vs. VIJAY SOLVEX LIMITED, ALWAR

In the result, revenue’s appeal as well as the C

ITA 292/JPR/2014[2008-09]Status: DisposedITAT Jaipur24 Aug 2018AY 2008-09
For Appellant: Shri P.C. Parwal (CA)For Respondent: Mrs. Roshanta Meena (JCIT) fu/kZkfjrh dh vksj ls@
Section 14ASection 92C

disallowance of Rs. 5,00,000/- made by the A.O. on account of Packaging Material expenses. 7. That the CIT(A)-II, Jaipur has erred in law as well as on the facts and circumstances of the case in deleting the addition of Rs. 1,14,47,501/- made by the A.O. on account of TPO adjustment. The appellant craves

UTTAM BHARAT ELECTRICALS PVT. LTD.,JAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-4, JAIPUR

In the result, appeal of the assessee is allowed

ITA 710/JPR/2019[2014-15]Status: DisposedITAT Jaipur04 Sept 2019AY 2014-15
For Appellant: Shri Rohan Sogani (CA) and Shri Rajeev Sogani (CA)For Respondent: Shri Jai Singh (JCIT)
Section 143(3)Section 144CSection 2(24)(x)Section 36(1)(va)Section 92C

section 92C(2) is also applicable in the case of the assessee and, therefore, in any case the Specified Domestic Transactions price falls in the tolerance range of (+)(-) 3%. Accordingly, the addition sustained by the ld. CIT (A) is deleted. Ground No. 2 is regarding disallowance