ZARI SILK (INDIA) PRIVATE LIMITED,JAIPUR vs. PRINCIPAL COMMISSIONER OF INCOME TAX (CENTRAL), JAIPUR , JAIPUR

The appeal of the assessee is allowed

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

Transfer Pricing Officer, as the case may be,] shall be deemed to be erroneous in so far as it is prejudicial to the interests of the revenue, if, in the opinion of the Principal [Chief Commissioner or Chief Commissioner or Principal] Commissioner or Commissioner,— (a) the order is passed without making inquiries or verification which should have been made

ARUN PALAWAT,JAIPUR vs. PRINCIPAL COMMISSIONER OF INCOME TAX, (CENTRAL),, JAIPUR

The appeal of the assessee is allowed

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

Transfer Pricing Officer, as the case may be,] shall be deemed to be erroneous in so far as it is prejudicial to the interests of the revenue, if, in the opinion of the Principal [Chief Commissioner or Chief Commissioner or Principal] Commissioner or Commissioner,— (a) the order is passed without making inquiries or verification which should have been made

LOVELY PROMOTERS PRIVATE LIMITED,KOLKATA vs. ACIT, CENTRAL CIRCLE, AJMER, AJMER

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

Bench: him regarding non mentioning of Document Identification Number (DIN) in the body of the order u/s. 127 of the Act dated 08-09-2021 and various other technical pleas raised in grounds of appeal regarding validity of notice u/s. 148 of the Act, thereby appellate order passed by the CIT(A) is non-speaking order and deserves to be quashed. 4. On the facts and in circumstances of the case and in law, the AO erred in issuing notice u/s. 148 of the Act as it was a search related case u/s. 132 r/w

transfer of jurisdiction from Kolkata to ACIT, central Circle, Ajmer (Rajsthan) was duly passed by the PCIT-5, Kolkata and the current AO was having jurisdiction on the date of passing the reassessment order. Thus the grounds in which the appellant had raised the objection of jurisdiction is duly dismissed. 9 Lovely promoters Pvt. Ltd. vs. ACIT Further, the appellant

GUNMALA JAIN,AJMER vs. INCOME TAX OFFICER, WD-2(2), AJMER, AJMER

Appeal of the assessee is dismissed

Bench: SMT. ANNAPURNA GUPTA, AM आयकर अपील सं. / ITA No.1262/JPR/2025 निर्धारणवर्ष / AssessmentYears :2019-20 Gunmala Jain, बनाम 28 Abhi Lash Nikunj, Kalyan Vs. Income Tax Officer, Ward-2(2) Colony, Ajmer Road Kekri, Ajmer स्थायीलेखा सं. / जीआईआर सं./ PAN/GIR No.: ABRPJ 4764E Ajmer अपीलार्थी / Appellant प्रत्यर्थी / Respondent निर्धारिती की ओर से/Assesseeby :Sh. Sunil Porwal, CA (Thr.V.C.) राजस्व की ओर से / Revenue by : Sh. Gautam Singh Choudhary (Addl. CIT) सुनवाई की तारीख / Date of Hearing : 18/1

Transfer Pricing Officer, where the assessee had maintained information and documents as prescribed under section 92D, declared the international transaction under Chapter X, and, disclosed all the material facts relating to the transaction; and (e) the amount of undisclosed income referred to in section 271AAB. ……………………………………………. Sub-Section (7) prescribes levy of penalty at the rate of 50% of the amount

ANJU MEEL,JAIPUR vs. I.T.O. WARD 3(4), JAIPUR, JAIPUR

In the result, the appeal is partly allowed

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

transferred to jurisdictional AO {I.T.O. Ward 3(4), Jaipur} who, after issuing notice under sec. 142(1) of Act on 18.01.2016 reassessed the income of assessee, reopened by non-jurisdiction AO. The addition made under section 50C of Act by AO for both the Agricultural lands were deleted by ld. CIT(A) by accepting fair market value of both

JUHI BHANDARI, JAIPUR,JAIPUR vs. DCIT CIRCLE (INTL TAX), JAIPUR, JAIPUR

In the result, both appeals of the assessee are allowed

transfer\npricing orders wherein downward adjustments were made to the price\npaid for the equipment imported by the AE. The Assessee had filed an\nappeal to this Tribunal against the appellate order for Assessment Year\n2013-14 (arising from the assessment under Section 143(3) and the TPO\norder). This appeal was disposed in RKM POWERGEN PRIVATE\nLIMITED

ARYA SAMAJ MANDIR ,BHILWARA vs. CIT(E), JAIPUR

Bench: The Date Of Hearing.”

Transfer Pricing Officer, as the case may be,] wholly or partly, otherwise than by making a fresh assessment or reassessment

ASSISTANT COMMISSIONER OF INCOME TAX,EXEMPTIONS,CIRCLE,JAIPUR, JAIPUR vs. GLOBAL INSTITUTE OF TECHNOLOGY SOCIETY, JAIPUR RAJASTHAN

In the results the appeal of the revenue stands dismissed

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

transfer pricing proceedings that no one would have lent money to the subsidiary unless there was an implied guarantee by the parent company. (The loan agreement did have a clause for a corporate guarantee to be provided if required by the lenders but, on facts, no such guarantee was called for.) However, the TPO made an addition

INCOME TAX OFFICER, WARD-1(2), JAIPUR, JAIPUR vs. MUKESH KUMAR SONI, JAIPUR

In the result appeal of the revenue is dismissed and the cross

Bench: Moving Towards The Facts Of The Case We Would Like To Mention

transfer pricing, data analytics, management or any other technical matter under this Act or an agreement entered into under section 90 or 90A, which may be required in a particular case or a class of cases, under this section and the term "technical unit", wherever used in this section, shall refer to an Assessing Officer having powers so assigned

HARI NARAYAN MEENA,JAIPUR vs. INCOME-TAX OFFICER WARD 2(5), JAIPUR

reassessment\neven though fully aware of the related facts. On the facts and in the\ncircumstances of the appellant, the learned AO has legally and factually\nerred in making in repeating the disallowances for computing the\ncapital gains.\n3. The AO erred in not following principal of the natural justice, by\nfailing to allow personal hearing as requested and failing

VIPUL KUMAR MODI ,JAIPUR vs. PRINCIPAL COMMISSIONER OF INCOME TAX, JAIPUR -I

In the result, appeal of the assessee is allowed

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

reassessment order passed by the Id. Assessing Officer u/s. 147 r.w.s. 144B of the Act is found to be erroneous in so far as it is prejudicial to the interest of the revenue. 2 2. That the Id. Principal Commissioner of Income- tax grossly erred in treating the exempt Long-Term Capital Gain earned by the assessee appellant as bogus

SOURABH AGROTECH PRIVATE LIMITED ,ALWAR vs. DCIT, CENTRAL CIRCLE, ALWAR

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

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

price of goods, such payment is not made in consideration of the transfer of goods. Such payment is meant for charity and is received and held in trust by the seller. If such amounts are meant to be credited to charity and do not form part of the income of the assessee they cannot be included in the transaction value

SAURABH AGROTECH PRIVATE LIMITED,ALWAR vs. DCIT, CENTRAL CIRCLE, ALWAR

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

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

price of goods, such payment is not made in consideration of the transfer of goods. Such payment is meant for charity and is received and held in trust by the seller. If such amounts are meant to be credited to charity and do not form part of the income of the assessee they cannot be included in the transaction value

PINCITY JEWLHOUSE PVT. LTD.,JAIPUR vs. PCIT, CC, JAIPUR, JAIPUR

In the result, the appeal of the assessee is allowed

Bench: the date of hearing." 3. At the outset of hearing, the Bench observed that there is delay of 58 days in filing of the present appeal by the assessee for which the Id. AR of 3

reassess the earlier assessment in terms of section 147 or carry out rectification u/s 154 of the Act. He can’t usurp the power of the CIT and recommend a revision. No overlapping of powers of the authorities under the Act can be permitted. As the revision proceedings in this case have triggered with the AO sending a proposal

PINK CITY JEWEL HOUSE PRIVATE LIMITED ,JAIPUR vs. PRINCIPAL COMMISSIONER OF INCOME TAX (CENTRAL), JAIPUR

reassessment proceedings u/s. 148 of the Act were initiated and\n37\nITA No. 598/JP/2024\nPinkcity Jewelhouse Pvt. Ltd. vs. PCIT\npassed for the Assessment Years 2012-2013 to 2015-2016 and scrutiny\nassessments u/s. 143(3) of the Act for Assessment Years 2016-2017 to 2018-\n2019 were also initiated and passed.\n6.1. That for ready reference, summary chart

SPECTRUM FOODS LIMITED,JAIPUR vs. INCOME TAX OFFICER, JAIPUR

In the result, the appeal of the assessee is allowed

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

reassessment proceedings were unwarranted and notice issued under s. 148 was liable to be quashed. viii) BAKULBHAI RAMANLAL PATEL vs. INCOME TAX OFFICER (HIGH COURT OF GUJARAT)(2011) 56 DTR (Guj) 212 AO has reason to suspect and not reason to believe that income chargeable to tax has escaped assessment and this is not a valid ground for reopening under

M/S DEEPS SPECIAL STEELS LIMITED,LUDHIANA vs. DCIT, CIRCLE-1, ALWAR

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

transfer of funds which is attached. (Annexure -6) The payment for purchase of shares and receipt of amount for sale of shares has been mode through banking channel only. We are submitting herewith the copies of bank statement of Axis Bank and PNB highlighting the receipt and payment in regard to purchase and sale of shares. (Annexure -7 and Annexure

SH. MAHENDRA KUMAR GOYAL,SIKAR vs. ACIT, CENTRAL CIRCLE-3, JAIPUR, JAIPUR

In the result of the appeal of the assessee are disposed off as under

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

reassessment for the assessment years 1968-69 to 1971-72 and for the year 1982-83 on the ground that the proposed reassessment for those assessment years had already become barred by time under section 149 of the Act, for which in the relevant periods maximum period of four years or seven years limitation was prescribed depending upon the quantum

SH. MAHENDRA KUMAR GOYAL,SIKAR vs. ACIT, CENTRAL CIRCLE-3, JAIPUR, JAIPUR

In the result of the appeal of the assessee are disposed off as under

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

reassessment for the assessment years 1968-69 to 1971-72 and for the year 1982-83 on the ground that the proposed reassessment for those assessment years had already become barred by time under section 149 of the Act, for which in the relevant periods maximum period of four years or seven years limitation was prescribed depending upon the quantum