SANJAY KUMAR KARNANI,JAIPUR vs. ACIT, CENTRAL CIRCLE-3, JAIPUR, JAIPUR

In the result, all appeals of the assessee are disposed off in terms of

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

Income-tax Act, 1961 1.1 As per the explicit and mandatory provisions enshrined under Section 153D of the Income-tax Act, 1961 (“the Act”), any Assessing Officer (“AO”) who is below Shri Ambika Garments vs. ACIT the rank of the Joint Commissioner of Income Tax (“JCIT”) is required to obtain prior approval u/s 153D by forwarding the draft assessment order

SANJAY KUMAR KARNANI,JAIPUR vs. ACIT, CENTRAL CIRCLE-3, JAIPUR, JAIPUR

In the result, all appeals of the assessee are disposed off in terms of

Bench: AO on 12-04-2021 18. Reply filed before AO on 15-07-2021 19. Additional Written Submissions filed before CIT(A) for AY 2014-15 on 11-11-2024 20. Written Submissions filed before CIT(A) for AY 2014-15 21. Written Submissions filed before CIT(A) for AY 2015-16 on 10-10-2024 22. Written Submissions filed before CIT(A) for AY 2016-17 on 10-10-2024 23. Written Submissions filed before CIT(A) for AY 2017-18 on 15-10-2024 24. Written Submissions filed before CIT(A) for AY 2018-19 on 15-10-2024 25.

Income-tax Act, 1961 1.1 As per the explicit and mandatory provisions enshrined under Section 153D of the Income-tax Act, 1961 (“the Act”), any Assessing Officer (“AO”) who is below Shri Ambika Garments vs. ACIT the rank of the Joint Commissioner of Income Tax (“JCIT”) is required to obtain prior approval u/s 153D by forwarding the draft assessment order

SHRI AMBICA GARMENTS, JODHPUR,JODHPUR vs. ACIT, CENTAL CIRCLE-3, JAIPUR, JAIPUR

In the result, all appeals of the assessee are disposed off in terms of

Income-tax Act, 1961 1.1 As per the explicit and mandatory provisions enshrined under Section 153D of the Income-tax Act, 1961 (“the Act”), any Assessing Officer (“AO”) who is below Shri Ambika Garments vs. ACIT the rank of the Joint Commissioner of Income Tax (“JCIT”) is required to obtain prior approval u/s 153D by forwarding the draft assessment order

SHRI AMBICA GARMENTS, JODHPUR,JODHPUR vs. ACIT, CENTRAL CIRCLE-3, JAIPUR, JAIPUR

In the result, all appeals of the assessee are disposed off in terms of

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

Income-tax Act, 1961 1.1 As per the explicit and mandatory provisions enshrined under Section 153D of the Income-tax Act, 1961 (“the Act”), any Assessing Officer (“AO”) who is below Shri Ambika Garments vs. ACIT the rank of the Joint Commissioner of Income Tax (“JCIT”) is required to obtain prior approval u/s 153D by forwarding the draft assessment order

SHRI AMBICA GARMENTS, JODHPUR,JODHPUR vs. ACIT, CENTAL CIRCLE-3, JAIPUR, JODHPUR

In the result, all appeals of the assessee are disposed off in terms of

Income-tax Act, 1961 1.1 As per the explicit and mandatory provisions enshrined under Section 153D of the Income-tax Act, 1961 (“the Act”), any Assessing Officer (“AO”) who is below Shri Ambika Garments vs. ACIT the rank of the Joint Commissioner of Income Tax (“JCIT”) is required to obtain prior approval u/s 153D by forwarding the draft assessment order

KIRAN FINE JEWELLERS PRIVATE LIMITED,JAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2,, JAIPUR

In the result ground no 2 raised by the assessee is allowed

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

business premises of the appellant assessee company on dated 02.08.2017 which was subsequently converted into search and seizure action u/s 132(1) of the Income Tax Act, 1961 ("the Act") on 03-08-2017. It will be worthwhile to mention here that the appellant assessee has been non compliant to the statutory notices issued to him on various dates during

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

transfer power directly to the ultimate industrial consumer i.e. the manufacturing units of assessee.\n30.13. Further, the aspect as to why rate at which power is sold to 3rd parties including Power distribution companies should not be considered as internal CUP and hence considered for computing arm's length price under the Transfer Pricing regulations, needs to be dealt with

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

Accordingly, the same is dismissed

transfer pricing adjustment u/s 80IA. 4. That the appellant craves to add, amend, alter, delete or modify any or all the above grounds of appeal before or at the time of hearing. As it is evident that four years are under dispute by the assessee and by revenue and we start from the assessment year 2015-16 first

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.

transfer pricing adjustment u/s 80IA. 4. That the appellant craves to add, amend, alter, delete or modify any or all the above grounds of appeal before or at the time of hearing. As it is evident that four years are under dispute by the assessee and by revenue and we start from the assessment year 2015-16 first

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.

transfer pricing adjustment u/s 80IA. 4. That the appellant craves to add, amend, alter, delete or modify any or all the above grounds of appeal before or at the time of hearing. As it is evident that four years are under dispute by the assessee and by revenue and we start from the assessment year 2015-16 first

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)

business income at all as adjudged by AO. This makes the action of the AO is the league of being plausible. The power of review cannot be exercised to collect more taxes merely owing to the reason that the law now provides for penal and steep rate of taxation by bringing such income within the ambit

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)

business income at all as adjudged by AO. This makes the action of the AO is the league of being plausible. The power of review cannot be exercised to collect more taxes merely owing to the reason that the law now provides for penal and steep rate of taxation by bringing such income within the ambit

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

business expenditure under section 37(1)\nof the I.T Act.\n63. The brief facts of the case are that the assessee during the\n assessment year under appeal had paid interest of Rs. 1,10,980/-\non late deposit of TDS, which has been added back in the\ncomputation of income while computing total income under Normal\nprovisions

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

In the result of the appeal of the assessee is allowed

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

business of construction of infrastructure projects on turnkey basis as a special purpose vehicle (SPV) with the understanding that on allotment of contract, respective company will undertake the work on back- to-back basis. 2.1. During the year under consideration, it was engaged in irrigation project of Kalisindh Dam in Distt-Jhalawar (Raj.), the company transferred the work

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

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

business of construction of infrastructure projects on turnkey basis as a special purpose vehicle (SPV) with the understanding that on allotment of contract, respective company will undertake the work on back- to-back basis. 2.1. During the year under consideration, it was engaged in irrigation project of Kalisindh Dam in Distt-Jhalawar (Raj.), the company transferred the work

M/S SHRIRAM GENERAL INSURANCE COMPANY LTD.,E-8, EPIP RIICO INDUSTRIAL AREA, SITAPURA, JAIPUR vs. PCIT, JAIPUR-2, JAIPUR

In the result, this appeal of the assessee is allowed

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

income of insurance business is to be computed in accordance with specific provisions of First Schedule irrespective of anything mentioned in any other provisions contained in the Act. Thus section 14A is not applicable to general insurance company. 15 Shriram General Insurance Co. Ltd., Jaipur. 5.1 Before proceeding further, we would like to analyze the provisions of section

MUJMMEEL ,KOTA vs. ACIT-CENTRAL CIRCLE , KOTA

In the result, appeal of the assessee is allowed

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

business. The Ld. PCIT has failed to discharge the burden of proof to substantiate the claim that the transactions represented unexplained investments by the assessee-appellant. On the contrary, the ld. AO’s findings are supported by evidences, such as agreements of sale and power of attorney documents. 41. That the term 'prejudicial to Revenue' cannot be invoked arbitrarily

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)

business income nor was the same been disallowed by the AO. 6. It was noted that in the ITR, the assessee had disclosed income from sale of scrap at Rs 49,00,000/-, whereas, in clause 34(a) of form 3CD, the amount of scrap sale, on which TCS has been made u/s 206C, has been reported