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35 results for “transfer pricing”+ Rectification u/s 154clear

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Key Topics

Section 143(3)27Section 26318Addition to Income18Limitation/Time-bar14Condonation of Delay14Section 80I10Section 1438Section 1488Section 132

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

price for the purpose of Section 80A(6) of the Act. 30.11. The ld. D/R in his submissions relied strongly on the order of TPO and the method adopted by TPO for determining market rate of power. According to ld. D/R, TPO has adopted the rate of power at which Distribution companies purchase power from the Generating companies. We find

Showing 1–20 of 35 · Page 1 of 2

8
Section 808
Section 1537
Search & Seizure7

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

price for the purpose of Section 80A(6) of the Act. 30.11. The ld. D/R in his submissions relied strongly on the order of TPO and the method adopted by TPO for determining market rate of power. According to ld. D/R, TPO has adopted the rate of power at which Distribution companies purchase power from the Generating companies. We find

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

Transfer Price of Power for the purpose of deduction u/s 80-1A of the Act and therefore, same was rightly rejected by the Ld. CIT(A). However, Hon'ble ITAT has allowed the same without giving an opportunity of being heard to the Assessing Officer. There is no reference to any remand report being sought on additional grounds

BHARATPUR ROYAL FAMILY RELIGIOUS & CEREMONIAL TRUST,BHARATPUR vs. CIT(E), JAIPUR

In the result, we upheld the order of the ld PCIT in exercise of his powers u/s 263 in setting aside the order so passed by the AO and the grounds of appeal taken by the assessee are hereby dismissed

ITA 290/JPR/2020[2011-12]Status: DisposedITAT Jaipur13 Jul 2021AY 2011-12
For Appellant: Sh. P. C. Parwal (CA)For Respondent: Sh. Rajendra Singh (CIT)
Section 10Section 12ASection 154Section 24Section 263Section 297

rectification u/s 154 of the Act. As per the assessee when the assessee was entitled for 15 Bharatpur Royal Family Religious & Ceremonial Trust Moti Mahal, Bharatpur Vs. CIT(E), Jaipur exemption and such exemption is not allowed in computation of total income, such Act is a mistake apparent from the record and can be rectified u/s 154

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

In the result, the appeal of the assessee is allowed

ITA 63/JPR/2021[2015-16]Status: DisposedITAT Jaipur07 Mar 2024AY 2015-16

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

For Appellant: Sh. Siddharth Ranka, Adv. &For Respondent: Sh. Ajey Malik, CIT
Section 10ASection 147Section 253(5)Section 263Section 5

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 to the ld. CIT and then the latter passing the order u/s

AJAY BAKLIWAL,KOTA vs. ACIT, CENTRAL CIRCLE, KOTA, KOTA

In the result, the appeal of the assessee is allowed

ITA 1279/JPR/2024[2017-18]Status: DisposedITAT Jaipur11 Apr 2025AY 2017-18

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

For Appellant: Sh. Rajendra Sisodia, AdvFor Respondent: Mrs. Anita Rinesh, JCIT-DR
Section 132(1)Section 139Section 143(3)Section 153ASection 154Section 270A

rectification of mistake on 24.10.2019. The application was disposed of by-passing order u/s. 154 of the Act. On 24.12.2019. 3 Ajay Bakliwal vs. ACIT 2.2 As there was difference of Rs. 3,00,00,000/- between ITR filed under section 153A and 139 of the IT. Act, 1961, the ld. AO considered the additional income so disclosed liable

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

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

ITA 770/JPR/2023[2013-14]Status: DisposedITAT Jaipur08 Feb 2024AY 2013-14

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

For Appellant: Shri Mayank Taparia (Adv.)For Respondent: Shri A.S. Nehra (Addl.CIT) a
Section 127Section 127(1)Section 132Section 147Section 148Section 148ASection 151Section 153C

154 Taxman 220 (All) 1.10. SAHARA HOSPITALITY LTD. Vs CIT [2012] 211 Taxman 15 (Bom) Prayer:- In view of the above submissions and judicial precedents cited supra, the appellant humbly requests your honour to accept the appellant’s ground regarding invalid jurisdiction and not following proper procedure u/s. 127 of the Act. Assessment order passed by Ld. AO (ACIT, Ajmer

RAM KISHAN VERMA,KOTA vs. PCIT (CENTRAL), JAIPUR

In the result appeal of the assessee in the ITA No

ITA 221/JPR/2022[2016/17]Status: DisposedITAT Jaipur25 Nov 2022
For Appellant: ShriMahendraGargieya (Adv.)&For Respondent: ShriJames Kurian (CIT)
Section 143(3)Section 263

rectification of mistake being a mistake than an error and invoking of S.263 was not permissible.The remedial provisions u/s 147,154,263 operate into different fields and cannot be used interchangeably. CIT V Amitabh Bachchan(2016) 286 CTR 113 (SC)wherein it was held as under: “9. Under the Act different shades of power have been conferred on different authorities

HARISH JAIN,KOTA vs. PCIT (CENTRAL), JAIPUR

In the result appeal of the assessee in the ITA No

ITA 216/JPR/2022[2016-17]Status: DisposedITAT Jaipur25 Nov 2022AY 2016-17
For Appellant: ShriMahendraGargieya (Adv.)&For Respondent: ShriJames Kurian (CIT)
Section 143(3)Section 263

rectification of mistake being a mistake than an error and invoking of S.263 was not permissible.The remedial provisions u/s 147,154,263 operate into different fields and cannot be used interchangeably. CIT V Amitabh Bachchan(2016) 286 CTR 113 (SC)wherein it was held as under: “9. Under the Act different shades of power have been conferred on different authorities

RAM KISHAN VERMA,KOTA vs. PCIT (CIRCLE), JAIPUR

In the result appeal of the assessee in the ITA No

ITA 219/JPR/2022[2014-15]Status: DisposedITAT Jaipur25 Nov 2022AY 2014-15
For Appellant: ShriMahendraGargieya (Adv.)&For Respondent: ShriJames Kurian (CIT)
Section 143(3)Section 263

rectification of mistake being a mistake than an error and invoking of S.263 was not permissible.The remedial provisions u/s 147,154,263 operate into different fields and cannot be used interchangeably. CIT V Amitabh Bachchan(2016) 286 CTR 113 (SC)wherein it was held as under: “9. Under the Act different shades of power have been conferred on different authorities

RAM KISHAN VERMA,KOTA vs. PCIT (CENTRAL), JAIPUR

In the result appeal of the assessee in the ITA No

ITA 223/JPR/2022[2018-19]Status: DisposedITAT Jaipur25 Nov 2022AY 2018-19
For Appellant: ShriMahendraGargieya (Adv.)&For Respondent: ShriJames Kurian (CIT)
Section 143(3)Section 263

rectification of mistake being a mistake than an error and invoking of S.263 was not permissible.The remedial provisions u/s 147,154,263 operate into different fields and cannot be used interchangeably. CIT V Amitabh Bachchan(2016) 286 CTR 113 (SC)wherein it was held as under: “9. Under the Act different shades of power have been conferred on different authorities

HARISH JAIN,JAIPUR vs. PCIT (CENTRAL), JAIPUR

In the result appeal of the assessee in the ITA No

ITA 215/JPR/2022[2015-16]Status: DisposedITAT Jaipur25 Nov 2022AY 2015-16
For Appellant: ShriMahendraGargieya (Adv.)&For Respondent: ShriJames Kurian (CIT)
Section 143(3)Section 263

rectification of mistake being a mistake than an error and invoking of S.263 was not permissible.The remedial provisions u/s 147,154,263 operate into different fields and cannot be used interchangeably. CIT V Amitabh Bachchan(2016) 286 CTR 113 (SC)wherein it was held as under: “9. Under the Act different shades of power have been conferred on different authorities

RAM KISHAN VERMA,KOTA vs. PCIT (CENTRAL), JAIPUR

In the result appeal of the assessee in the ITA No

ITA 218/JPR/2022[2013-14]Status: DisposedITAT Jaipur25 Nov 2022AY 2013-14
For Appellant: ShriMahendraGargieya (Adv.)&For Respondent: ShriJames Kurian (CIT)
Section 143(3)Section 263

rectification of mistake being a mistake than an error and invoking of S.263 was not permissible.The remedial provisions u/s 147,154,263 operate into different fields and cannot be used interchangeably. CIT V Amitabh Bachchan(2016) 286 CTR 113 (SC)wherein it was held as under: “9. Under the Act different shades of power have been conferred on different authorities

RAM KISHAN VERMA,KOTA vs. PCIT (CENTRAL), JAIPUR

In the result appeal of the assessee in the ITA No

ITA 222/JPR/2022[2017-18]Status: DisposedITAT Jaipur25 Nov 2022AY 2017-18
For Appellant: ShriMahendraGargieya (Adv.)&For Respondent: ShriJames Kurian (CIT)
Section 143(3)Section 263

rectification of mistake being a mistake than an error and invoking of S.263 was not permissible.The remedial provisions u/s 147,154,263 operate into different fields and cannot be used interchangeably. CIT V Amitabh Bachchan(2016) 286 CTR 113 (SC)wherein it was held as under: “9. Under the Act different shades of power have been conferred on different authorities

MANOJ KUMAR SHARMA,JAIPUR vs. PCIT(CENTRAL), JAIPUR

In the result appeal of the assessee in the ITA No

ITA 283/JPR/2022[2015-16]Status: DisposedITAT Jaipur25 Nov 2022AY 2015-16
For Appellant: ShriMahendraGargieya (Adv.)&For Respondent: ShriJames Kurian (CIT)
Section 143(3)Section 263

rectification of mistake being a mistake than an error and invoking of S.263 was not permissible.The remedial provisions u/s 147,154,263 operate into different fields and cannot be used interchangeably. CIT V Amitabh Bachchan(2016) 286 CTR 113 (SC)wherein it was held as under: “9. Under the Act different shades of power have been conferred on different authorities

RAM KISHAN VERMA,KOTA vs. PCIT (CENTRAL), JAIPUR

In the result appeal of the assessee in the ITA No

ITA 217/JPR/2022[2012-13]Status: DisposedITAT Jaipur25 Nov 2022AY 2012-13
For Appellant: ShriMahendraGargieya (Adv.)&For Respondent: ShriJames Kurian (CIT)
Section 143(3)Section 263

rectification of mistake being a mistake than an error and invoking of S.263 was not permissible.The remedial provisions u/s 147,154,263 operate into different fields and cannot be used interchangeably. CIT V Amitabh Bachchan(2016) 286 CTR 113 (SC)wherein it was held as under: “9. Under the Act different shades of power have been conferred on different authorities

RAM KISHAN VERMA,KOTA vs. PCIT (CENTRAL), JAIPUR

In the result appeal of the assessee in the ITA No

ITA 220/JPR/2022[2015-16]Status: DisposedITAT Jaipur25 Nov 2022AY 2015-16
For Appellant: ShriMahendraGargieya (Adv.)&For Respondent: ShriJames Kurian (CIT)
Section 143(3)Section 263

rectification of mistake being a mistake than an error and invoking of S.263 was not permissible.The remedial provisions u/s 147,154,263 operate into different fields and cannot be used interchangeably. CIT V Amitabh Bachchan(2016) 286 CTR 113 (SC)wherein it was held as under: “9. Under the Act different shades of power have been conferred on different authorities

MANOJ KUMAR SHARMA,JAIPUR vs. PCIT (CENTRAL), JAIPUR

In the result appeal of the assessee in the ITA No

ITA 281/JPR/2022[2013-14]Status: DisposedITAT Jaipur25 Nov 2022AY 2013-14
For Appellant: ShriMahendraGargieya (Adv.)&For Respondent: ShriJames Kurian (CIT)
Section 143(3)Section 263

rectification of mistake being a mistake than an error and invoking of S.263 was not permissible.The remedial provisions u/s 147,154,263 operate into different fields and cannot be used interchangeably. CIT V Amitabh Bachchan(2016) 286 CTR 113 (SC)wherein it was held as under: “9. Under the Act different shades of power have been conferred on different authorities

MANOJ KUMAR SHARMA,JAIPUR vs. PCIT(CENTRAL), JAIPUR

In the result appeal of the assessee in the ITA No

ITA 282/JPR/2022[2014-15]Status: DisposedITAT Jaipur25 Nov 2022AY 2014-15
For Appellant: ShriMahendraGargieya (Adv.)&For Respondent: ShriJames Kurian (CIT)
Section 143(3)Section 263

rectification of mistake being a mistake than an error and invoking of S.263 was not permissible.The remedial provisions u/s 147,154,263 operate into different fields and cannot be used interchangeably. CIT V Amitabh Bachchan(2016) 286 CTR 113 (SC)wherein it was held as under: “9. Under the Act different shades of power have been conferred on different authorities

HARISH JAIN,KOTA vs. PCIT (CENTRAL), JAIPUR

In the result appeal of the assessee in the ITA No

ITA 214/JPR/2022[2012-13]Status: DisposedITAT Jaipur25 Nov 2022AY 2012-13
For Appellant: ShriMahendraGargieya (Adv.)&For Respondent: ShriJames Kurian (CIT)
Section 143(3)Section 263

rectification of mistake being a mistake than an error and invoking of S.263 was not permissible.The remedial provisions u/s 147,154,263 operate into different fields and cannot be used interchangeably. CIT V Amitabh Bachchan(2016) 286 CTR 113 (SC)wherein it was held as under: “9. Under the Act different shades of power have been conferred on different authorities