RAJASTHAN STATE TEXT BOOK BOARD,JAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX (EXEMPTION)-CIRCLE, JAIPUR

In the result, both the appeals of the assessee are allowed

Bench: Or At The Time Of Hearing.”

Section 10(23C)(iiiab) of the Act the ld. AR has submitted that initially the assessee used to supply textbooks entirely to the government schools under the scheme of free of cost however, over the time the private educational institutions have taken the significant number of students the assessee has started supplying the textbooks to the private distributors

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

In the result, the appeal of the assessee in ITA no

section 115QA of Act and therefore, the company is liable to pay tax on the distributed income of Rs. 71,99,99,211/-. 3.7 Based on these observations, ld. AO prepared the draft order dated 26/09/2023 proposing the following additions: | Transfer pricing adjustment u/s 92CA | Rs. 1,37,27,79,147/- | |--------------------------------------------|----------------------| | Late deposit of PF amount 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

Bench: or at the time of hearing of this appeal.

Section 80IA(8), the word "OR" is missing in provisions of Section 80A(6) of the ACIT vs. Shree Cement Ltd. Act. It is noted that as per provisions of Section 80A(6), if any goods or services whether sold or acquired falls within the category specified domestic transactions of Section 92BA then in such case it is mandatory

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.

Section 80IA(8), the word "OR" is missing in provisions of Section 80A(6) of the ACIT vs. Shree Cement Ltd. Act. It is noted that as per provisions of Section 80A(6), if any goods or services whether sold or acquired falls within the category specified domestic transactions of Section 92BA then in such case it is mandatory

JODHPUR DEVELOPMENT AUTHORITY,JODHPUR vs. DCIT (EXEMPTION), JAIPUR

In the result, the appeal in ITA no

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, AM vk;djvihy la-@ITA No. 665 & 666/JPR/2023 fu/kZkj.ko"kZ@Assessment Years : 2009-10 & 2013-14 Jodhpur Development Authority 1, Opposite Railway Hospital, JDA Circle, Jodhpur. cuke Vs. Deputy Commissioner of Income Tax, Exemption, Jodhpur. LFkk;hys[kk la-@thvkbZvkj la-@PAN/GIR No.: AAALJ 0478 P vihykFkhZ@Appellant izR;FkhZ@Respondent fu/kZkfjrh dh vksjls@Assesseeby : Shri Amit Kothari (C.A.) jktLo dh vksjls@Revenue by:

10(20) may kindly be accepted for all the years under consideration. 1.23. The appellant has spent for development activities in accordance with provisions of JDA Act and in conformity with the instructions issued by the State Government from time to time. Such expenditure for public purposes have been incurred out of “Local Fund” / “Statutory Fund” in conformity with provisions

JODHPUR DEVELOPMENT AUTHORITY,JODHPUR vs. DCIT (EXEMPTION), JAIPUR

In the result, the appeal in ITA no

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

10(20) may kindly be accepted for all the years under consideration. 1.23. The appellant has spent for development activities in accordance with provisions of JDA Act and in conformity with the instructions issued by the State Government from time to time. Such expenditure for public purposes have been incurred out of “Local Fund” / “Statutory Fund” in conformity with provisions

LAL CHAND MEENA ,JAIPUR vs. ITO, WARD 7-3, JAIPUR

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

price do not arise for consideration. Hence, considering the legislative intent of section 45(3) vis-a-vis sec. 50C, it is incorrect to held that sec. 50C would override section 45(3). 7.6 It is further submitted that by Finance Bill, 2016, Sec. 50C is proposed to be amended w.e.f. 01.04.2017 to provide that where the date

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

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

transfer price) for determining the quantum of deduction under section 80IA already calimed in the original return of income. The judgment of Hon’ble Supreme Court in case ofWipro, is applicable to cases wherein “new claim” is filed by way of revised return for claiming “exemption” under section 10B of the IT Act. In the present case, there

SHARAD KUMAR BHANDARI, JAIPUR,JAIPUR vs. DCIT CIRCLE (INTL TAX), JAIPUR, JAIPUR

section 153C of the Act,\nnotices was issued for A.Y. 2015-2016 to 2021-2022 on 27.03.2023 by\nld. AO which was duly served upon the assessee through e-filing portal.\nReturn of income has been filed by the assessee in response to the notice\nu/s 153C of the Act on 26.04.2023. No additional income was declared in\nthe return

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

Section 144B(1)(xvi)(b) of the Act. 2. That on the facts and in the circumstances of the case, the Ld. CIT(Appeals) was not justified and erred in rejecting the appellant’s claim of allowing reliability charge of Rs. 1.5/unit in computing Transfer Price of Power for the purpose of Deduction u/s 80-IA in respect

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

Section 144B(1)(xvi)(b) of the Act. 2. That on the facts and in the circumstances of the case, the Ld. CIT(Appeals) was not justified and erred in rejecting the appellant’s claim of allowing reliability charge of Rs. 1.5/unit in computing Transfer Price of Power for the purpose of Deduction u/s 80-IA in respect

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

Section 144B(1)(xvi)(b) of the Act. 2. That on the facts and in the circumstances of the case, the Ld. CIT(Appeals) was not justified and erred in rejecting the appellant’s claim of allowing reliability charge of Rs. 1.5/unit in computing Transfer Price of Power for the purpose of Deduction u/s 80-IA in respect

KOTHARI JEWELS PRIVATE LIMITED,MUMBAI vs. ACIT, JAIPUR

In the result, the appeal of the assessee is allowed

10) of section 80-IA are applicable; or (vi) any other transaction as may be prescribed, and where the aggregate of such transactions entered into by the assessee in the previous year exceeds a sum of [twenty] crore rupees. “ Thus, even after introduction of Domestic Transfer Pricing, present case of sale to the sister concern are not covered within

VAIBHAV GLOBAL LIMITED,JAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-5, JAIPUR

In the result, the penalty is directed to be deleted and appeal of the assessee is allowed

transfer pricing adjustment/addition of Rs. 18,68,02,513/-and has Vaibhav Global Ltd. vs. ACIT stated that penalty U/s 271(1)(c) is leviable in accordance with explanation 7. Then, towards the end of assessment order, it has been stated that penalty proceedings U/s 271(1)(c) of the Act are initiated separately. 7. In the penalty order dated

VAIBHAV GLOBAL LIMITED,JAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-5, JAIPUR

In the result, the penalty is directed to be deleted and appeal of the assessee is allowed

transfer pricing adjustment/addition of Rs. 18,68,02,513/-and has Vaibhav Global Ltd. vs. ACIT stated that penalty U/s 271(1)(c) is leviable in accordance with explanation 7. Then, towards the end of assessment order, it has been stated that penalty proceedings U/s 271(1)(c) of the Act are initiated separately. 7. In the penalty order dated

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

SONU DUSAD,JAIPUR vs. DCIT CENTRAL CIRCLE, 1, JAIPUR, JAIPUR

In the results, the appeal of the assessee in ITA no

Bench: This Tribunal Are As Under :

10. In this context, reference is invited to provisions of Section 144C of the Act: Section 144C - Reference to dispute resolution panel. (1) The Assessing Officer shall, notwithstanding anything to the contrary contained in this Act, in the first instance, forward a draft of the proposed order of assessment (hereafter in this section referred to as the draft order

SONU DUSAD,JAIPUR vs. DCIT CENTRAL CIRCLE, 1, JAIPUR, JAIPUR

In the results, the appeal of the assessee in ITA no

Bench: This Tribunal Are As Under :

10. In this context, reference is invited to provisions of Section 144C of the Act: Section 144C - Reference to dispute resolution panel. (1) The Assessing Officer shall, notwithstanding anything to the contrary contained in this Act, in the first instance, forward a draft of the proposed order of assessment (hereafter in this section referred to as the draft order

SONU DUSAD,JAIPUR vs. DCIT CENTRAL CIRCLE, 1, JAIPUR, JAIPUR

In the results, the appeal of the assessee in ITA no

Bench: This Tribunal Are As Under :

10. In this context, reference is invited to provisions of Section 144C of the Act: Section 144C - Reference to dispute resolution panel. (1) The Assessing Officer shall, notwithstanding anything to the contrary contained in this Act, in the first instance, forward a draft of the proposed order of assessment (hereafter in this section referred to as the draft order