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172 results for “transfer pricing”+ Disallowanceclear

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Key Topics

Section 143(3)77Addition to Income76Section 6849Section 80I40Disallowance40Section 14732Section 14828Section 153A23Section 10(38)23Deduction

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

Accordingly, the same is dismissed

ITA 490/JPR/2023[2016-17]Status: DisposedITAT Jaipur21 Feb 2024AY 2016-17
Section 115JSection 143Section 143(3)Section 144B(1)(xvi)Section 80Section 80I

Transfer Price of Power for the purpose of Deduction u/s 80-IA in respect to its eligible power undertakings. 3. That on the facts and in the circumstances of the case, the Ld. CIT(Appeals) was not justified and erred in confirming the disallowance

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

Showing 1–20 of 172 · Page 1 of 9

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20
Section 234A19
Exemption15
ITA 497/JPR/2023[2017-18]Status: Disposed
ITAT Jaipur
21 Feb 2024
AY 2017-18
Section 115JSection 143Section 143(3)Section 144B(1)(xvi)Section 80Section 80I

Transfer Price of Power for the purpose of Deduction u/s 80-IA in respect to its eligible power undertakings.\n3. That on the facts and in the circumstances of the case, the Ld. CIT(Appeals) was not justified and erred in confirming the disallowance

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

Transfer Price of Power for the purpose of Deduction u/s 80-IA in respect to its eligible power undertakings. ACIT vs. Shree Cement Ltd. 3. That on the facts and in the circumstances of the case, the Ld. CIT(Appeals) was not justified and erred in confirming the 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

Transfer Price of Power for the purpose of Deduction u/s 80-IA in respect to its eligible power undertakings. ACIT vs. Shree Cement Ltd. 3. That on the facts and in the circumstances of the case, the Ld. CIT(Appeals) was not justified and erred in confirming the disallowance

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

ITA 489/JPR/2023[2015-16]Status: DisposedITAT Jaipur21 Feb 2024AY 2015-16
For Appellant: Sh. Dilip B Desai(C.A.)For Respondent: Sh. Alka Gautam (CIT) (V.H) &
Section 115JSection 143Section 143(3)Section 144B(1)(xvi)Section 80Section 80I

disallowance of Rs. 19,34,58,626/- out of the\nclaim u/s. 80-IA on water treatment system on account of transfer\npricing adjustment of water, the relevant fact is that the assessee\nhas computed transfer price

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

Transfer Pricing ("TP") Report) and accordingly made adjustment by computing the retention profit @ 4.5% of the contract value thereby making an addition of Rs. 3,18,71,174/- disallowing

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

Transfer Pricing ("TP") Report) and accordingly made adjustment by computing the retention profit @ 4.5% of the contract value thereby making an addition of Rs. 3,18,71,174/- disallowing

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

ITA 498/JPR/2023[2018-19]Status: DisposedITAT Jaipur21 Feb 2024AY 2018-19
For Appellant: Sh. Dilip B Desai(C.A.)For Respondent: Sh. Alka Gautam (CIT) (V.H) &
Section 115JSection 143Section 143(3)Section 144B(1)(xvi)Section 80Section 80I

disallowance of Rs. 19,34,58,626/- out of the \nclaim u/s. 80-IA on water treatment system on account of transfer \npricing adjustment of water, the relevant fact is that the assessee \nhas computed transfer price

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

Transfer Price of Power for the purpose of Deduction u/s 80-IA in respect to its eligible power undertakings merely on the contention that such claim has not been made vide the return of income. 2. That on the facts and in the circumstances of the case, the ld. CIT (Appeals) was not justified and erred in confirming the disallowance

SHREE CEMENT LIMITED,BANGUR NAGAR vs. ACIT, CENTRAL CIRCLE, AJMER

In the result, the appeal of the assessee - appellant in ITA No

ITA 1517/JPR/2024[2019-2020]Status: DisposedITAT Jaipur24 Jun 2025AY 2019-2020

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Shri Dilip B. Desai, FCAFor Respondent: Shri Arvind Kumar, CIT-DR
Section 115JSection 143(1)Section 254Section 36(1)(va)Section 80Section 801A

disallowance u/s 36(1)(va) on account of delayed contribution to provident fund. Apart from this, the assessee also raised additional grounds, mentioned as below: a) Inclusion of Reliability Charge while computing Transfer Price

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

ITA 1144/JPR/2024[2020-21]Status: DisposedITAT Jaipur30 Jun 2025AY 2020-21
For Appellant: Shri Vinod Kumar Gupta, AdvFor Respondent: Shri Rajesh Ojha, CIT-DR
Section 115JSection 115QSection 143(3)Section 144C(13)Section 36(1)(va)

transfer pricing, notional interest on receivables, and disallowance of PF contribution.", "held": "The Tribunal noted that the assessee's gross

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)

transfer pricing guidelines. \nIn doing so, the ld. TPO, Ld. AO and the Hon’ble DRP also failed to appreciate that \nBerry ratio is applied only in specific circumstances i.e. low risk procurement and \ndistributors. Additionally, the ld. AO has erred in applying 'Berry Ratio' even when \nin appellant’s own case. Berry Ratio was rejected

RAJESH CHOUDHARY,GURGAON vs. ACIT CENTRAL CIRCLE, ALWAR, ALWAR

In the result, the appeal of the assessee is allowed

ITA 597/JPR/2024[2019-20]Status: DisposedITAT Jaipur01 Jan 2025AY 2019-20

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

For Appellant: Shri R.S. Poonia, CAFor Respondent: Ms. Alka Gautam, CIT-DR
Section 127Section 133ASection 139Section 142(1)Section 143(2)Section 143(3)Section 263

Transfer Pricing Officer" shall have the same meaning as assigned to it in the Explanation to section 92CA.] (2) No order shall be made under sub-section (1) after the expiry of two years from the end of the financial year in which the order sought to be revised was passed. (3) Notwithstanding anything contained in sub-section

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

ITA 260/JPR/2023[2018-19]Status: DisposedITAT Jaipur28 Jun 2023AY 2018-19

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

For Appellant: Shri P.C. Parwal, CAFor Respondent: Shri Ajey Malik, CIT
Section 142(1)Section 143(2)Section 143(3)Section 14ASection 263Section 30Section 44

Transfer Pricing Officer" shall have the same meaning as assigned to it in the Explanation to section 92CA.] (2) No order shall be made under sub-section (1) after the expiry of two years from the end of the financial year in which the order sought to be revised was passed. (3) Notwithstanding anything contained in sub-section

BARMER LIGNITE MINING CO. LTD.,C-SCHEME, JAIPUR vs. DCIT, CIRCLE-6, JAIPUR, JAIPUR

Appeals of the assessee are allowed for statistical purposes in view of our detailed order (supra)

ITA 462/JPR/2023[2018-19]Status: DisposedITAT Jaipur16 Dec 2024AY 2018-19

Bench: Dr. S. Seethalakshmi & Shri Gagan Goyal

For Appellant: Mr. P. C. Parwal, CA, Ld. ARFor Respondent: MS. Alka Gautam, CIT, Ld. DR
Section 234ASection 250Section 94E

disallowance will lead to double taxation as mine closure charges forms part of selling price of lignite is not acceptable as by simply filing the petition with RERC for determination of Transfer

DCIT, CIRCLE 6, JAIPUR, NCRB, JPR vs. BARMER LIGNITE MINING COMPANY LIMITED, UDYOG BHAWAN JAIPUR

Appeals of the assessee are allowed for statistical purposes in view of our detailed order (supra)

ITA 453/JPR/2023[2017-18]Status: DisposedITAT Jaipur16 Dec 2024AY 2017-18

Bench: Dr. S. Seethalakshmi & Shri Gagan Goyal

For Appellant: Mr. P. C. Parwal, CA, Ld. ARFor Respondent: MS. Alka Gautam, CIT, Ld. DR
Section 234ASection 250Section 94E

disallowance will lead to double taxation as mine closure charges forms part of selling price of lignite is not acceptable as by simply filing the petition with RERC for determination of Transfer

DCIT, CIRCLE-6 JAIPUR, NCRB, JAIPUR vs. BARMER LIGNITE MINING COMPANY LIMITED, UDYOG BHAWAN, TILAK NAGAR JPR

Appeals of the assessee are allowed for statistical purposes in view of our detailed order (supra)

ITA 452/JPR/2023[2016-17]Status: DisposedITAT Jaipur16 Dec 2024AY 2016-17

Bench: Dr. S. Seethalakshmi & Shri Gagan Goyal

For Appellant: Mr. P. C. Parwal, CA, Ld. ARFor Respondent: MS. Alka Gautam, CIT, Ld. DR
Section 234ASection 250Section 94E

disallowance will lead to double taxation as mine closure charges forms part of selling price of lignite is not acceptable as by simply filing the petition with RERC for determination of Transfer

BARMER LIGNITE MINING CO. LTD.,C-SCHEME, JAIPUR vs. DCIT, CIRCLE-6, JAIPUR, JAIPUR

Appeals of the assessee are allowed for statistical purposes in view of our detailed order (supra)

ITA 463/JPR/2023[2020-21]Status: DisposedITAT Jaipur16 Dec 2024AY 2020-21

Bench: Dr. S. Seethalakshmi & Shri Gagan Goyal

For Appellant: Mr. P. C. Parwal, CA, Ld. ARFor Respondent: MS. Alka Gautam, CIT, Ld. DR
Section 234ASection 250Section 94E

disallowance will lead to double taxation as mine closure charges forms part of selling price of lignite is not acceptable as by simply filing the petition with RERC for determination of Transfer

DCIT, CIRCLE-6, JAIPUR, NCRB, JAIPUR vs. BARMER LIGNITE MINING COMPANY LIMITED, UDYOG BHAWAN, JAIPUR

Appeals of the assessee are allowed for statistical purposes in view of our detailed order (supra)

ITA 454/JPR/2023[2018-19]Status: DisposedITAT Jaipur16 Dec 2024AY 2018-19

Bench: Dr. S. Seethalakshmi & Shri Gagan Goyal

For Appellant: Mr. P. C. Parwal, CA, Ld. ARFor Respondent: MS. Alka Gautam, CIT, Ld. DR
Section 234ASection 250Section 94E

disallowance will lead to double taxation as mine closure charges forms part of selling price of lignite is not acceptable as by simply filing the petition with RERC for determination of Transfer

DCIT, CIRCLE-6, JAIPUR, NCRB, JAIPUR vs. BARMER LIGNITE MINING COMPANY LIMITED, UDYOG BHAWAN, JAIPUR

Appeals of the assessee are allowed for statistical purposes in view of our detailed order (supra)

ITA 455/JPR/2023[2020-21]Status: DisposedITAT Jaipur16 Dec 2024AY 2020-21

Bench: Dr. S. Seethalakshmi & Shri Gagan Goyal

For Appellant: Mr. P. C. Parwal, CA, Ld. ARFor Respondent: MS. Alka Gautam, CIT, Ld. DR
Section 234ASection 250Section 94E

disallowance will lead to double taxation as mine closure charges forms part of selling price of lignite is not acceptable as by simply filing the petition with RERC for determination of Transfer