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80 results for “transfer pricing”+ Section 133Aclear

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Key Topics

Addition to Income62Section 143(3)52Section 6850Section 14731Survey u/s 133A25Section 153A22Section 145(3)20Section 133A19Section 13219Section 148

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

Showing 1–20 of 80 · Page 1 of 4

19
Disallowance16
Natural Justice10

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

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 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 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

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 509/JPR/2025[2021-22]Status: DisposedITAT Jaipur12 Nov 2025AY 2021-22
For Appellant: Sh. Mukesh Soni, AdvFor Respondent: Mrs. Anita Rinesh, JCIT-DR
Section 144CSection 153CSection 153DSection 250

Pricing Officer passed under sub-section (3)\nof section 92CA; and\n(ii) any non-resident not being a company, or any foreign company:\n11. From the bare reading of the above-mentioned provisions of Section\n144C, it is evident that the Assessing Officer must forward a draft of the proposed\nassessment order to the eligible assessee if any variation

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

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

133A of the Act conducted in the case of assessee on 02.03.2020. During the year, the assessee earned commission income from real estate transactions and reported agricultural income. The case of the assessee was selected for compulsory scrutiny in accordance with the guidelines issued by the Central Board of Direct Taxes (CBDT) on account of the survey. In the assessment

DEPUTY COMMISSINER OF INCOME TAX, LIC BUILDING vs. M/S GEE VEE DEVELOPERS PVT. LTD., JAIPUR

In the result, the appeals of the revenue stands dismissed

ITA 267/JPR/2022[2016-17]Status: DisposedITAT Jaipur24 May 2023AY 2016-17

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

Section 143(3)

price as on 18.06.2015 Rs. 27,89,92,000/- Less:- Cost of acquisition 903892*1081/223= Rs. 43,81,647/- Rs. 87,96,055/- 430619*1081/244= Rs. 19,07,783/- 221058*1081/259= Rs. 9,22,640/- 570000*1081/389= Rs. 15,83,985/- Long term capital gain Rs. 27,01,95,945/- From the above discussion, it is clear that the assessee

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-3, JAIPUR vs. M/S VISION ESTATES PVT. LTD., JAIPUR

In the result, the appeals of the revenue stands dismissed

ITA 266/JPR/2022[2016-17]Status: DisposedITAT Jaipur24 May 2023AY 2016-17

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

Section 143(3)

price as on 18.06.2015 Rs. 27,89,92,000/- Less:- Cost of acquisition 903892*1081/223= Rs. 43,81,647/- Rs. 87,96,055/- 430619*1081/244= Rs. 19,07,783/- 221058*1081/259= Rs. 9,22,640/- 570000*1081/389= Rs. 15,83,985/- Long term capital gain Rs. 27,01,95,945/- From the above discussion, it is clear that the assessee

DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-3, JAIPUR vs. M/S RIGID CONDUCTORS (RAJ.) PVT. LTD., JAIPUR

In the result, the appeals of the revenue stands dismissed

ITA 264/JPR/2022[2016-17]Status: DisposedITAT Jaipur24 May 2023AY 2016-17

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

Section 143(3)

price as on 18.06.2015 Rs. 27,89,92,000/- Less:- Cost of acquisition 903892*1081/223= Rs. 43,81,647/- Rs. 87,96,055/- 430619*1081/244= Rs. 19,07,783/- 221058*1081/259= Rs. 9,22,640/- 570000*1081/389= Rs. 15,83,985/- Long term capital gain Rs. 27,01,95,945/- From the above discussion, it is clear that the assessee

DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-3, JAIPUR vs. M/S CHOKHI DHANI DEVELOPERS PVT. LTD., JAIPUR

In the result, the appeals of the revenue stands dismissed

ITA 265/JPR/2022[2016-17]Status: DisposedITAT Jaipur24 May 2023AY 2016-17

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

Section 143(3)

price as on 18.06.2015 Rs. 27,89,92,000/- Less:- Cost of acquisition 903892*1081/223= Rs. 43,81,647/- Rs. 87,96,055/- 430619*1081/244= Rs. 19,07,783/- 221058*1081/259= Rs. 9,22,640/- 570000*1081/389= Rs. 15,83,985/- Long term capital gain Rs. 27,01,95,945/- From the above discussion, it is clear that the assessee

KIRAN FINE JEWELLERS PRIVATE LIMITED,JAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2,, JAIPUR

In the result ground no 2 raised by the assessee is allowed

ITA 648/JPR/2024[2017-18]Status: DisposedITAT Jaipur25 Feb 2025AY 2017-18

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Sh. S. R. Sharma, CA &For Respondent: Sh. P. P. Meena, CIT-Th. V.H
Section 115BSection 143(3)Section 145(3)Section 68Section 69A

section 145(3) of the Act is hereby upheld. This ground of Appeal is hereby dismissed. 23 Kiran Fine Jewellers Pvt. Ltd. vs. DCIT Ground No. 2 5.2 I have considered the facts of the case and written submissions of the appellant as against the observations/findings of the AO in the assessment order for the year under consideration. The contentions/submissions

SHRI RUPAL JAIAN,JAIPUR vs. ITO, WARD-1(2), JAIPUR

In the result, appeal of the assessee is dismissed

ITA 209/JPR/2020[2014-15]Status: DisposedITAT Jaipur04 Apr 2023AY 2014-15

Bench: The Date Of Appeal.

For Appellant: Shri Saurabh Harsh, AdvocateFor Respondent: Shri Anoop Singh, (Addl. CIT)
Section 10(38)Section 133ASection 142(1)Section 143(2)Section 68

price Transfer Exempt income expenses claimed u/s 10(38) M/s. Sunrise Asian 25,20,930/- 1,00,000/- - 24,20,930/- Limited On examination of the share sale transactions made by the assessee during the year, it was found that the entire sale proceeds, that have been claimed as exempt income, were received from sale of one scrip

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

133A of the Income Tax Act was conducted at the premises of Hariram Hospital (Assessee), on 28.08.2018 The assessee filed its return of income declaring an income of Rs. 9,63,910/ under Section 139(1) of the Act on 30.10.2019. Thereafter the said return was selected for compulsory scrutiny. That the assessing officer had made detailed query in regard

KANTA AGARWAL ,JAIPUR vs. DCIT CIRCLE 6, JAIPUR

ITA 64/JPR/2023[2015-16]Status: HeardITAT Jaipur05 Oct 2023AY 2015-16

Bench: HON’BLE SHRI SANDEEP GOSAIN (Judicial Member)

For Appellant: Shri Sarwan Kumar Gupta, AdvocateFor Respondent: Smt. Monisha Choudhary (JCIT)
Section 10(38)Section 134ASection 14ASection 250Section 68Section 69C

133A of the IT Act. It has been manifestly accepted by them that such penny stock companies are the conduit for converting untaxed money brought on record by paying no taxes Smt. Kanta Agarwal, Jaipur. in the garb of exempted income. The investigation finally identified 84 such penny stock companies which were involved in the pool of the entry providers

KANTA DEVI,JAIPUR vs. ITO WARD 6(5), JAIPUR

ITA 77/JPR/2023[2014-2015]Status: HeardITAT Jaipur05 Oct 2023AY 2014-2015

Bench: HON’BLE SHRI SANDEEP GOSAIN (Judicial Member)

For Appellant: Shri Sarwan Kumar Gupta, AdvocateFor Respondent: Smt. Monisha Choudhary (JCIT)
Section 10(38)Section 134ASection 14ASection 250Section 68Section 69C

133A of the IT Act. It has been manifestly accepted by them that such penny stock companies are the conduit for converting untaxed money brought on record by paying no taxes Smt. Kanta Agarwal, Jaipur. in the garb of exempted income. The investigation finally identified 84 such penny stock companies which were involved in the pool of the entry providers

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

Section 14A of the Act can\nbe made if the assessee had not earned any exempt income? - HELD THAT:- A\nperusal of the Memorandum of the Finance Bill, 2022 reveals that it explicitly stipulates\nthat the amendment made to Section 14A will take effect from 1st April, 2022 and will\napply in relation to the assessment year

JYPORE MANUFACTURING JEWELLERS PRIVATE LIMITED,JAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, JAIPUR

In the result, the appeal of the assessee is allowed

ITA 432/JPR/2025[2018-19]Status: DisposedITAT Jaipur25 Jun 2025AY 2018-19
For Appellant: Sh. S. L. Poddar, AdvFor Respondent: Mrs. Alka Gautam, CIT-DR
Section 127Section 133ASection 142(1)Section 143(2)

133A conducted on 09.03.2018 physical verification, cash of\nRs.17,95,840/- was found as against book position of cash of Rs.\n11,38,319/-. Thus, there was a discrepancy of cash of Rs.6,57,521/-,\nbeing in excess with reference to cash book. In view of this, the Id. AO has\nmade addition of Rs.6,57,521/- on account