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229 results for “transfer pricing”+ Section 11(6)clear

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Key Topics

Section 143(3)78Addition to Income78Section 6843Section 14740Section 26337Section 14831Section 80I31Disallowance31Section 153A25

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

6. We have heard the rival contentions, perused the material available on record and gone through the order of the authorities below. The Ld. CIT(A) has decided this issue in his order as under:- “4.3 I have perused the rectification order and submissions made by the appellant and find that issue raised is against the denial of exemption

Showing 1–20 of 229 · Page 1 of 12

...
Section 69C20
Deduction19
Exemption14

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 power directly to the ultimate industrial consumer i.e. the manufacturing units of assessee. 30.13. 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

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

ITA 497/JPR/2023[2017-18]Status: DisposedITAT Jaipur21 Feb 2024AY 2017-18
Section 115JSection 143Section 143(3)Section 144B(1)(xvi)Section 80Section 80I

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

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

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

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

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

WHOLE SALE CLOTH MERCHANT ASSOCIATION ,KOTA vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE KOTA , KOTA

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

ITA 961/JPR/2024[2014-2015]Status: DisposedITAT Jaipur24 Sept 2025AY 2014-2015
For Appellant: Shri Siddharth Ranka, AdvFor Respondent: Mrs. Anita Rinesh, JCIT-DR
Section 11Section 11(2)Section 143(3)Section 147Section 40

price) from the concerning person of all the 22 plots has not been taken in\nbooks.\n4. The trust property is used Personal benefit of the president\nShri Tejndra Pal Singh has taken loan & advances of Rs. 31,50,000/- from the\ntrust and violated the provisions of section 13(2) of the Act. Further no proper\nbooks of accounts

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

section 80IA(8) of the Act.\n30.10. Considering that TPO has disputed the Grid rate not to be\nthe market value in terms of provisions of Section 80A(6) of the\nAct, we would like to state here that that unlike Section 80IA(8),\nthe word \"OR\" is missing in provisions of Section 80A(6) of the\nAct

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)

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 and in case, there is a defective service of notice, it provides that if the assessee has cooperated, it will not be open for him to raise the plea, whereas in the instant

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)

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 and in case, there is a defective service of notice, it provides that if the assessee has cooperated, it will not be open for him to raise the plea, whereas in the instant

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)

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 and in case, there is a defective service of notice, it provides that if the assessee has cooperated, it will not be open for him to raise the plea, whereas in the instant

WHOLE SALE CLOTH MERCHANT ASSOCIATION ,KOTA vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE KOTA , KOTA

ITA 962/JPR/2024[2015-2016]Status: DisposedITAT Jaipur24 Sept 2025AY 2015-2016
For Respondent: \nMrs. Anita Rinesh, JCIT-DR
Section 11Section 11(2)Section 143(3)Section 147Section 40

price) from the concerning person of all the 22 plots has not been taken in\nbooks.\n\n4. The trust property is used Personal benefit of the president\nShri Tejndra Pal Singh has taken loan & advances of Rs.31,50,000/- from the\ntrust and violated the provisions of section 13(2) of the Act. Further no proper\nbooks of accounts

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

6,96,12,33,525/- under provisions of section 115JB of the Act. The case was taken up for scrutiny. In view of specified domestic transactions, a Shree Cement Limited, Beawar. reference under section 92CA was made to the Transfer Pricing Officer (TPO). The TPO passed an order under section 92CA(3) dated 25.10.2017 of the Act proposing various upward

ASSISTANT COMMISSIONER OF INCOME TAX,EXEMPTIONS,CIRCLE,JAIPUR, JAIPUR vs. GLOBAL INSTITUTE OF TECHNOLOGY SOCIETY, JAIPUR RAJASTHAN

In the results the appeal of the revenue stands dismissed

ITA 175/JPR/2024[2013-14]Status: DisposedITAT Jaipur27 Jun 2024AY 2013-14

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

For Appellant: Sh. S. L. Poddar, AdvFor Respondent: Sh. Anoop Singh, (Addl.CIT)
Section 11Section 12ASection 13(1)Section 13(3)Section 143(3)Section 147

6 to 17 and ITAT order is placed on paper book page no. 18 to 26. As per CIT(A) and ITAT order there is receipts of Rs. 27,72,06,233/- against expenditure of Rs. 38,44,17,857/- so there is loss of Rs. 10,72,11,620/- and no addition can be sustained. The assessee is also

ACIT, CENTRAL CIRCLE, AJMER, AJMER vs. WONDER CEMENT LTD, MADANGANJ-KISHANGARH

In the result Ground No. 2 raised by the assessee is allowed

ITA 1543/JPR/2024[2020-21]Status: DisposedITAT Jaipur21 Feb 2025AY 2020-21

Bench: Shri Gagan Goyal & Shri Narinder Kumar

For Appellant: Mr. C. M. Agarwal, CA, Ld. ARFor Respondent: Mr. Sanjay Dhariwal, CIT, Ld. DR
Section 115JSection 143(3)Section 250Section 801A(8)Section 80A(6)Section 92Section 92CSection 92F

6) of the Act, inserted by Finance Act, 2012 (with effect from 1 April 2013) is applicable wherein the 'market value' has been defined to mean the arm's length price as defined in clause (ii) of section 92F of the Act which means 'price which is applied or proposed to be applied in a transaction between persons other than

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

In the result, the appeal in ITA no

ITA 665/JPR/2023[2009-10]Status: DisposedITAT Jaipur26 Apr 2024AY 2009-10

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:

For Appellant: Shri Amit Kothari (C.A.)For Respondent: Shri Ajay Malik (CIT)
Section 11Section 143(3)Section 234A

6. Aggrieved from the order of the ld. CIT(A), the assessee has filed the present appeal on the grounds as stated herein above. In support of the various grounds so taken the ld. AR of the assessee filed a detailed written submission dealing with the merits of the case and on the applicability of provision of section 11

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

In the result, the appeal in ITA no

ITA 666/JPR/2023[2013-14]Status: DisposedITAT Jaipur26 Apr 2024AY 2013-14

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

For Appellant: Shri Amit Kothari (C.A.)For Respondent: Shri Ajay Malik (CIT)
Section 11Section 143(3)Section 234A

6. Aggrieved from the order of the ld. CIT(A), the assessee has filed the present appeal on the grounds as stated herein above. In support of the various grounds so taken the ld. AR of the assessee filed a detailed written submission dealing with the merits of the case and on the applicability of provision of section 11

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

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

ITA 508/JPR/2025[2020-21]Status: DisposedITAT Jaipur12 Nov 2025AY 2020-21

Bench: This Tribunal Are As Under :

For Appellant: Sh. Mukesh Soni, AdvFor Respondent: Mrs. Anita Rinesh, JCIT-DR
Section 144CSection 153CSection 153DSection 250

Pricing Officer passed under sub-section (3) of section 92CA; and (ii) any non-resident not being a company, or any foreign company: 11. From the bare reading of the above-mentioned provisions of Section 144C, it is evident that the Assessing Officer must forward a draft of the proposed assessment order to the eligible assessee if any variation

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

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

ITA 506/JPR/2025[2016-17]Status: DisposedITAT Jaipur12 Nov 2025AY 2016-17

Bench: This Tribunal Are As Under :

For Appellant: Sh. Mukesh Soni, AdvFor Respondent: Mrs. Anita Rinesh, JCIT-DR
Section 144CSection 153CSection 153DSection 250

Pricing Officer passed under sub-section (3) of section 92CA; and (ii) any non-resident not being a company, or any foreign company: 11. From the bare reading of the above-mentioned provisions of Section 144C, it is evident that the Assessing Officer must forward a draft of the proposed assessment order to the eligible assessee if any variation

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

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

ITA 507/JPR/2025[A.Y. 2018-19]Status: DisposedITAT Jaipur12 Nov 2025

Bench: This Tribunal Are As Under :

For Appellant: Sh. Mukesh Soni, AdvFor Respondent: Mrs. Anita Rinesh, JCIT-DR
Section 144CSection 153CSection 153DSection 250

Pricing Officer passed under sub-section (3) of section 92CA; and (ii) any non-resident not being a company, or any foreign company: 11. From the bare reading of the above-mentioned provisions of Section 144C, it is evident that the Assessing Officer must forward a draft of the proposed assessment order to the eligible assessee if any variation

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

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

ITA 505/JPR/2025[2015-16]Status: DisposedITAT Jaipur12 Nov 2025AY 2015-16

Bench: This Tribunal Are As Under :

For Appellant: Sh. Mukesh Soni, AdvFor Respondent: Mrs. Anita Rinesh, JCIT-DR
Section 144CSection 153CSection 153DSection 250

Pricing Officer passed under sub-section (3) of section 92CA; and (ii) any non-resident not being a company, or any foreign company: 11. From the bare reading of the above-mentioned provisions of Section 144C, it is evident that the Assessing Officer must forward a draft of the proposed assessment order to the eligible assessee if any variation