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31 results for “transfer pricing”+ Revision u/s 263clear

Sorted by relevance

Mumbai219Delhi173Chennai79Bangalore54Kolkata38Ahmedabad35Rajkot34Hyderabad31Jaipur31Pune27Chandigarh23Visakhapatnam21Raipur20Surat20Agra19Indore17Lucknow12Nagpur11Cuttack9Cochin7Jodhpur4Amritsar3Dehradun2Patna1Panaji1

Key Topics

Section 26370Section 143(3)31Addition to Income17Section 80I16Section 14A13Section 13(3)12Section 1111Section 1479Section 142(1)9

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

REVISION U/S. 263 7. CIT v. Manna Trust 42 44 {2022 (01) TMI 693} Rajasthan High Court 27 Pinkcity Jewelhouse Pvt. Ltd. vs. PCIT 8. Gayatri Devi v. PCIT 45 78 {2023 (10) TMI 23} ITAT - Jaipur PAPER BOOK-II SNo. Particulars Page No. From To 1. Copy of Order dated 18.12.2017 passed u/s 147 r.w.s

Showing 1–20 of 31 · Page 1 of 2

Deduction9
Disallowance8
Exemption7

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

ITA 598/JPR/2024[2018-2019]Status: DisposedITAT Jaipur26 Dec 2024AY 2018-2019
For Appellant: Sh. Siddharth Ranka, AdvFor Respondent: \nSh. Saurav Harsh, Adv.&
Section 142(1)Section 143(2)Section 144oSection 14ASection 263Section 69

u/s. 263 by the Id. PCIT is bad in law and\ndeserves to be quashed and set-aside.\nGround No. 5:\nDeduction under section 10AA of the Act:\n6. That as submitted hereinabove subsequent to survey conducted on 17-\n18.08.2017, reassessment proceedings u/s. 148 of the Act were initiated and\n37\nITA No. 598/JP/2024\nPinkcity Jewelhouse Pvt. Ltd. vs. PCIT

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

In the result, appeal of the assessee is allowed

ITA 310/JPR/2024[2016-2017]Status: DisposedITAT Jaipur03 Jun 2024AY 2016-2017

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

For Appellant: Shri Sidharth Ranka &For Respondent: Shri Anil Dhaka (CIT) a
Section 142(1)Section 143(1)Section 147Section 263

revision under the explanation (2) clause (b) and clause (a) of section 263 of the Act. The assessment order is set aside to be made afresh in the light of the observation made in this order. The AO is required to make necessary verification in respect of the observations made in this order after allowing reasonable opportunity to the assessee

SHREE CEMENT LIMITED,BEAWAR vs. PR.CIT, , UDAIPUR

In the result, the appeal of the assessee is allowed

ITA 4/JPR/2021[2014-15]Status: DisposedITAT Jaipur23 Jun 2021AY 2014-15

Bench: Shri Sandeep Gosain, Jm & Shri Vikram Singh Yadav, Am Vk;Dj Vihy La-@Ita No. 04/Jp/2021 Assessment Year: 2014-15 Shree Cement Limited, Cuke Pr.Cit, Vs. Bangur Nagar, Post Box No. 33, Udaipur. Beawar. Pan No.: Aaccs 8796 G Vihykfkhz@Appellant Izr;Fkhz@Respondent Fu/Kzkfjrh Dh Vksj Ls@ Assessee By: Shri Dilip Desai (Ca) Shri Vijay Shah (Ca) Shri Mohit Choudhary (Ca) Jktlo Dh Vksj Ls@ Revenue By : Shri B.K. Gupta (Cit-Dr) Lquokbz Dh Rkjh[K@ Date Of Hearing : 01/04/2021 Mn?Kks"K.Kk Dh Rkjh[K@ Date Of Pronouncement : 23/06/2021 Vkns'K@ Order Per: Sandeep Gosain, J.M. The Present Appeal Has Been Filed By The Assessee Against The Order Of Ld. Pcit, Udaipur Dated 03.02.2021 Passed U/S 263 Of The Income Tax Act, 1961 (In Short The Act) For The Assessment Year 2014-15. The Grounds Of Appeal Taken By The Assessee Are As Under: “1. That On The Facts & In The Circumstances Of The Case, The Learned Principal Commissioner Of Income Tax – Udaipur, (Here- In- After Referred To As Ld. Pr. Cit) Was Not Justified In Initiating Proceedings U/S 263 Of The Income Tax Act, 1961 Since The Order Passed By The Assessing Officer (A.O.) Was Neither Erroneous Nor Prejudicial To The Interest Of The Revenue.

For Appellant: Shri Dilip Desai (CA)For Respondent: Shri B.K. Gupta (CIT-DR)
Section 115JSection 142(1)Section 143(2)Section 143(3)Section 263

revise the above order of the A.O. on certain grounds. Subsequently, the Ld. PCIT passed order dated 03.02.2021 setting aside all issues to the file of the A.O. for re-verification and re- examination of all the issues raised vide notice u/s 263 of the Act. Ld. PCIT was of the view that the level of enquiry what should have

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,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

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

The appeal of the assessee is allowed

ITA 599/JPR/2025[2021-22]Status: DisposedITAT Jaipur15 Sept 2025AY 2021-22

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

For Appellant: Shri S.R. Sharma, C.A. &For Respondent: Shri Rajesh Ojha, CIT-DR a
Section 115Section 143(3)Section 148BSection 263Section 69A

revision proceedings u/s 263 of the IT Act, 1961 is wrong and bad in law in as much as power of the ld. Pr. CIT under this section do not extend to the assessments made in search cases by AO after obtaining mandatory approval of Addl. CIT u/s 148B of the IT Act, 1961. In this connection, it is submitted

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

The appeal of the assessee is allowed

ITA 600/JPR/2025[2021-22]Status: DisposedITAT Jaipur15 Sept 2025AY 2021-22

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

For Appellant: Shri S.R. Sharma, C.A. &For Respondent: Shri Rajesh Ojha, CIT-DR a
Section 115Section 143(3)Section 148BSection 263Section 69A

revision proceedings u/s 263 of the IT Act, 1961 is wrong and bad in law in as much as power of the ld. Pr. CIT under this section do not extend to the assessments made in search cases by AO after obtaining mandatory approval of Addl. CIT u/s 148B of the IT Act, 1961. In this connection, it is submitted

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

ITA 313/JPR/2023[2016-17]Status: DisposedITAT Jaipur27 Sept 2023AY 2016-17

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

For Appellant: Sh. P. C. ParwalFor Respondent: Sh. Ajay Malik (CIT) a
Section 143(3)Section 192Section 194Section 195Section 263Section 36(1)(va)Section 40

price. Thus, the view taken by AO in accepting the book value of the stock-in- trade was a plausible and permissible view and therefore, the PCIT could not exercise his powers u/s 263. PCIT Vs. Max India 295 ITR 282 (SC) Where two views are possible and the ITO has taken one view with which the PCIT does

HARIRAM HOSPITAL,ALWAR vs. PCIT, ALWAR

In the result, the appeal of the assessee is allowed

ITA 1535/JPR/2024[2019-20]Status: DisposedITAT Jaipur17 Apr 2025AY 2019-20

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, AM आयकरअपीलसं./ITA No. 1535/JPR/2024 निर्धारणवर्ष / Assessment Year: 2019-20 Hariram Hospital Bye Pass Road Hariram Hospital Bhiwadi, Alwar – 310 019 (Raj) बनाम Vs. The Pr.CIT (Central) Jaipur प्रत्यर्थी / Respondent स्थायीलेखा सं. / जीआईआरसं./PAN/GIR No.: AAFFH 5746 M अपीलार्थी / Appellant निर्धारिती की ओरसे / Assesseeby : Shri Himanshu Goyal, CA राजस्व की ओरसे /Revenue by: Mrs. Alka Gautam, CIT-DR सुनवाई की तारीख / Da

For Appellant: Shri Himanshu Goyal, CAFor Respondent: Mrs. Alka Gautam, CIT-DR
Section 143(3)Section 263

u/s 263 dated 18.03.2024 which is illegal, void and unsustainable in law. The assessee respectfully submits that the impugned revisionary order passed under section 263 is bad in law, as the Ld. PCIT has failed to satisfy the twin conditions laid down under section 263(1) of the Act namely, (i) that the order passed by the AO is erroneous

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

u/s 143(3), where the Assessing officer has forgot to invoke the provisions of section 115JB of the Act, the matter clearly falls within purview of section 154 of the Act and the same can be rectified as mistake apparent from record. 15. Now, coming to another contention of the ld AR that in view of sub-section

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

263 – Revision of Orders Prejudice to Revenue 12 SHRI RAJESH CHOUDHARY VS ACIT, CENTRAL CIRCLE, ALWAR “1. The [Principal Chief Commissioner or Chief Commissioner or Principal Commissioner] or Commissioner may call for and examine the record of any proceeding under this Act, and if he considers that any order passed therein by the Assessing Officer [or the Transfer Pricing Officer

DEPUTY COMMISSIONER OF INCOME TAX (EXEMPTION), CIRCLE, JAIPUR vs. MODERN SCHOOL SOCIETY, KOTA

In the result, this appeal of the revenue stands dismissed

ITA 357/JPR/2019[2013-14]Status: DisposedITAT Jaipur18 Jan 2021AY 2013-14

Bench: Shri Sandeep Gosain, Jm & Shri Vikram Singh Yadav, Am Vk;Dj Vihy La-@Ita No. 1361 & 1362/Jp/2018 Assessment Years: 2011-12 & 2012-13 Deputy Commissioner Of Cuke M/S Modern School Society, Vs. Income Tax (Exemptions) Sector-A, Talwandi, Kota Circle, Jaipur. (Rajasthan) Pan No.: Aaatm 7045 H Vihykfkhz@Appellant Izr;Fkhz@Respondent Vk;Dj Vihy La-@Ita No. 357/Jp/2019 Assessment Year: 2013-14 Deputy Commissioner Of Cuke M/S Modern School Society, Vs. Income Tax (Exemptions) Sector-A, Talwandi, Kota Circle, Jaipur. (Rajasthan) Pan No.: Aaatm 7045 H Vihykfkhz@Appellant Izr;Fkhz@Respondent Jktlo Dh Vksj Ls@ Revenue By : Smt. Rooni Paul (Addl.Cit-Dr) Fu/Kzkfjrh Dh Vksj Ls@ Assessee By: Shri Rajiv Sogani (Ca) Lquokbz Dh Rkjh[K@ Date Of Hearing : 21/12/2020 Mn?Kks"K.Kk Dh Rkjh[K@ Date Of Pronouncement : 18/01/2021 Vkns'K@ Order Per: Sandeep Gosain, J.M. These Are The Appeals Filed By The Revenue Against The Separate Orders Of The Ld. Cit(A)-3, Jaipur Dated 04/09/2018 & 12/12/2018 For The A.Y. 2011-12 To 2013-14 Respectively.

For Appellant: Shri Rajiv Sogani (CA)For Respondent: Smt. Rooni Paul (Addl.CIT-DR) fu/kZkfjrh dh vksj ls@
Section 10Section 11Section 13(1)(c)Section 13(1)(d)Section 13(2)(h)Section 13(3)

revise his order u/s. 263 of the Act, the order passed was liable to be set aside. The relevant portion of the order of Hon’ble Allahabad High Court reads as under:- “6. On perusal of the aforesaid provisions, it will be abundantly clear that the provisions of Section 299-BB deals with the procedure for service of notice

DEPUTY COMMISSIONER OF INCOME TAX (EXEMPTION), CIRCLE, JAIPUR vs. MODERN SCHOOL SOCIETY, KOTA

In the result, this appeal of the revenue stands dismissed

ITA 1361/JPR/2018[2011-12]Status: DisposedITAT Jaipur18 Jan 2021AY 2011-12

Bench: Shri Sandeep Gosain, Jm & Shri Vikram Singh Yadav, Am Vk;Dj Vihy La-@Ita No. 1361 & 1362/Jp/2018 Assessment Years: 2011-12 & 2012-13 Deputy Commissioner Of Cuke M/S Modern School Society, Vs. Income Tax (Exemptions) Sector-A, Talwandi, Kota Circle, Jaipur. (Rajasthan) Pan No.: Aaatm 7045 H Vihykfkhz@Appellant Izr;Fkhz@Respondent Vk;Dj Vihy La-@Ita No. 357/Jp/2019 Assessment Year: 2013-14 Deputy Commissioner Of Cuke M/S Modern School Society, Vs. Income Tax (Exemptions) Sector-A, Talwandi, Kota Circle, Jaipur. (Rajasthan) Pan No.: Aaatm 7045 H Vihykfkhz@Appellant Izr;Fkhz@Respondent Jktlo Dh Vksj Ls@ Revenue By : Smt. Rooni Paul (Addl.Cit-Dr) Fu/Kzkfjrh Dh Vksj Ls@ Assessee By: Shri Rajiv Sogani (Ca) Lquokbz Dh Rkjh[K@ Date Of Hearing : 21/12/2020 Mn?Kks"K.Kk Dh Rkjh[K@ Date Of Pronouncement : 18/01/2021 Vkns'K@ Order Per: Sandeep Gosain, J.M. These Are The Appeals Filed By The Revenue Against The Separate Orders Of The Ld. Cit(A)-3, Jaipur Dated 04/09/2018 & 12/12/2018 For The A.Y. 2011-12 To 2013-14 Respectively.

For Appellant: Shri Rajiv Sogani (CA)For Respondent: Smt. Rooni Paul (Addl.CIT-DR) fu/kZkfjrh dh vksj ls@
Section 10Section 11Section 13(1)(c)Section 13(1)(d)Section 13(2)(h)Section 13(3)

revise his order u/s. 263 of the Act, the order passed was liable to be set aside. The relevant portion of the order of Hon’ble Allahabad High Court reads as under:- “6. On perusal of the aforesaid provisions, it will be abundantly clear that the provisions of Section 299-BB deals with the procedure for service of notice

DEPUTY COMMISSIONER OF INCOME TAX (EXEMPTION), CIRCLE, JAIPUR vs. MODERN SCHOOL SOCIETY, KOTA

In the result, this appeal of the revenue stands dismissed

ITA 1362/JPR/2018[2012-13]Status: DisposedITAT Jaipur18 Jan 2021AY 2012-13

Bench: Shri Sandeep Gosain, Jm & Shri Vikram Singh Yadav, Am Vk;Dj Vihy La-@Ita No. 1361 & 1362/Jp/2018 Assessment Years: 2011-12 & 2012-13 Deputy Commissioner Of Cuke M/S Modern School Society, Vs. Income Tax (Exemptions) Sector-A, Talwandi, Kota Circle, Jaipur. (Rajasthan) Pan No.: Aaatm 7045 H Vihykfkhz@Appellant Izr;Fkhz@Respondent Vk;Dj Vihy La-@Ita No. 357/Jp/2019 Assessment Year: 2013-14 Deputy Commissioner Of Cuke M/S Modern School Society, Vs. Income Tax (Exemptions) Sector-A, Talwandi, Kota Circle, Jaipur. (Rajasthan) Pan No.: Aaatm 7045 H Vihykfkhz@Appellant Izr;Fkhz@Respondent Jktlo Dh Vksj Ls@ Revenue By : Smt. Rooni Paul (Addl.Cit-Dr) Fu/Kzkfjrh Dh Vksj Ls@ Assessee By: Shri Rajiv Sogani (Ca) Lquokbz Dh Rkjh[K@ Date Of Hearing : 21/12/2020 Mn?Kks"K.Kk Dh Rkjh[K@ Date Of Pronouncement : 18/01/2021 Vkns'K@ Order Per: Sandeep Gosain, J.M. These Are The Appeals Filed By The Revenue Against The Separate Orders Of The Ld. Cit(A)-3, Jaipur Dated 04/09/2018 & 12/12/2018 For The A.Y. 2011-12 To 2013-14 Respectively.

For Appellant: Shri Rajiv Sogani (CA)For Respondent: Smt. Rooni Paul (Addl.CIT-DR) fu/kZkfjrh dh vksj ls@
Section 10Section 11Section 13(1)(c)Section 13(1)(d)Section 13(2)(h)Section 13(3)

revise his order u/s. 263 of the Act, the order passed was liable to be set aside. The relevant portion of the order of Hon’ble Allahabad High Court reads as under:- “6. On perusal of the aforesaid provisions, it will be abundantly clear that the provisions of Section 299-BB deals with the procedure for service of notice

MUJMMEEL ,KOTA vs. ACIT-CENTRAL CIRCLE , KOTA

In the result, appeal of the assessee is allowed

ITA 620/JPR/2024[2020-21]Status: DisposedITAT Jaipur14 Feb 2025AY 2020-21

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

For Appellant: Miss. Swatika Jha, AdvFor Respondent: Ms. Alka Gautam, CIT a
Section 115BSection 133ASection 139Section 143(2)Section 143(3)Section 263Section 69Section 69A

u/s. 263 of the Act it would appropriate to go through the provision of that section which reads as under : Revision of orders prejudicial to revenue. 263. (1) The Principal Chief Commissioner or Chief Commissioner or Principal Commissioner or Commissioner may call for and examine the record of any proceeding under this Act, and if he considers that any order

NAINA SARAF,JAIPUR vs. PR.CIT-2, JAIPUR

In the result, this appeal of the assessee is allowed

ITA 271/JPR/2020[2015-16]Status: DisposedITAT Jaipur14 Sept 2021AY 2015-16

Bench: Shri Sandeep Gosain, Jm & Shri Vikram Singh Yadav, Am Vk;Dj Vihy La-@Ita No. 271/Jp/2020 Assessment Year: 2015-16 Cuke Naina Saraf, Pr.Cit-2, Vs. B-93, Surya Marg, Tilak Nagar, Jaipur. Jaipur. Pan No.: Aevps 4665 N Vihykfkhz@Appellant Izr;Fkhz@Respondent

For Appellant: Shri Mahendra Gargieya (Adv.)For Respondent: Shri B.K. Gupta (CIT-DR)
Section 142(1)Section 143(3)Section 263Section 56(2)(vii)

u/s 263, is that the order of the Assessing Officer is established to be erroneous in so far as it is prejudicial to the interest of the Revenue. The Commissioner has to be satisfied of twin conditions, namely (i) The order of the Assessing Officer sought to be revised is erroneous; and (ii) it is prejudicial to the interests

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

price. Thus, the view taken by AO in accepting the book value of the stock-in-trade was a plausible and permissible view and therefore, the CIT could not exercise his powers u/s 263. CIT Vs. Max India 295 ITR 282 (SC) Where two views are possible and the ITO has taken one view with which the CIT does

MIKUNI INDIA PRIVATE LIMITED,ALWAR vs. PRINCIPAL COMMISSIONER OF INCOME TAX, PCIT,

12. In view of the above discussion, we find merit in this appeal, when the assessment order dated 27

ITA 745/JPR/2024[2017-18]Status: DisposedITAT Jaipur26 Dec 2024AY 2017-18

Bench: passing the impugned order, Learned PCIT issued notice to the assessee, as Learned PCIT found that the Assessing Officer, while framing the above said assessment and the making addition, did not initiate penalty proceedings 270A of the Act. Learned PCIT was of the view that penalty proceedings were to be initiated under the said provision on account of misreporting of income, which came to be added by the Assessing Officer to the total income of the assessee company. It being a Transfer Pri

For Appellant: Shri Abhishek Agarwal, C.A. (Through V.C.) &For Respondent: Ms. Alka Gautam (CIT)
Section 143(3)Section 144C(5)Section 194C(5)Section 263Section 270ASection 92CSection 94C

Transfer Pricing-2(3)(2), Delhi passed order dated 29.01.2021 u/s 92CA of the Act, thereby determining the amount of TP adjustment at Rs. 7,01,72,622/- and the said amount was proposed to be added to the income of the assessee. It is also not in dispute on 07.04.2021, the Assessing Officer passed draft order u/s

GIRNAR SOFTWARE PRIVATE LIMITED,6TH FLOOR, JAIPUR TEXTILE MARKET, B-2, NEAR MODEL TOWN, MALVIYA NAGAR, JAIPUR vs. PCIT – 2, JAIPUR, NEW CENTRAL REVENUE BUILDING

In the result, the appeal of the assessee is allowed

ITA 330/JPR/2023[2018-19]Status: DisposedITAT Jaipur28 Aug 2023AY 2018-19

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

For Appellant: Shri PC Parwal, CAFor Respondent: Shri Arvind Kumar (CIT)
Section 142(1)Section 143(2)Section 14ASection 263

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