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29 results for “transfer pricing”+ Section 144C(3)clear

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Key Topics

Section 80I36 Section 153C29 Section 143(3)25 Section 8018 Section 26315 Section 92C15 Transfer Pricing15 Addition to Income14 Section 115J13

DCIT, JAIPUR vs. JAIPUR RUGS COMPANY (P) LTD., JAIPUR

In the result, the appeal filed by the assessee is partly allowed and appeal filed by the Revenue stands dismissed

ITA 1084/JPR/2016[2011-12]Status: DisposedITAT Jaipur23 Apr 2018AY 2011-12

For Appellant: Shri Rajeev Sogani (CA)For Respondent: Smt. Seema Meena (JCIT) fu/kZkfjrh dh vksj ls@

Section 143(1)Section 143(2)Section 144CSection 92CSection 92C(2)

Transfer Pricing Officer passed under sub-section (3) of section 92CA; and (ii) any foreign company. 15. The scheme of section 144C

VAIBHAV GLOBAL LIMITED,JAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, JAIPUR, JAIPUR

Showing 1–20 of 29 · Page 1 of 2

In the result, the appeal of the assessee is allowed and disposed off in light of aforesaid directions

ITA 97/JPR/2021[2016-17]Status: DisposedITAT Jaipur07 Feb 2022AY 2016-17

Bench: Shri Sandeep Gosain & Shri Vikram Singh Yadavvaibhav Global Limited, Deputy Commissioner Of बनाम Jaipur. Income Tax, Central Circle-4, Jaipur. "थायी लेखा सं./Pan No: Aaacv4679F

For Appellant: Shri Vijay Mehta, C.AFor Respondent: Shri B.K. Gupta, Pr.CIT

Section 143(3)Section 144C(13)Section 234ASection 92CSection 92D

section 144C(13) of the Act was passed by the Assessing officer on 13.11.2019 wherein adjustment on account of transfer pricing as proposed by the Transfer Pricing Officer was made and the assessed income was determined at Rs.57,36,47,429/-. 3

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

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

ITA 1144/JPR/2024[2020-21]Status: DisposedITAT Jaipur30 Jun 2025AY 2020-21

For Appellant: Shri Vinod Kumar Gupta, AdvFor Respondent: Shri Rajesh Ojha, CIT-DR

Section 115JSection 115QSection 143(3)Section 144C(5)Section 36(1)(va)

section 143(3) r.w.s 144C(13) of the Income Tax Act, 1961 - 4. Under the facts and circumstances of the case and in law, the Ld. TPO, Ld. AO and the Hon'ble DRP erred in rejecting the economic analysis including the Most Appropriate Method and the filters applied by the appellant in the Transfer Pricing

M/S. JHANDEWALA FOODS LIMITED 35, JOHARI BAZAR, JAIPUR,JAIPUR vs. ACIT CIRCLE-1, JAIPUR, CIRCLE-1, JAIPUR

In the result, the ground no

ITA 940/JPR/2019[2014-15]Status: DisposedITAT Jaipur01 Jan 2020AY 2014-15

For Appellant: NoneFor Respondent: Shri K. C. Gupta (CIT)

Section 142(1)Section 143(2)Section 144CSection 144C(1)Section 156Section 271(1)(c)Section 92C

Transfer Pricing Officer passed under sub-section (3) of section 92CA; and (ii) any foreign company. 15. The scheme of section 144C

M/S CENTURY INFRA POWER P. LTD.,JAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2, JAIPUR

In the result, appeal of the assessee is allowed

ITA 169/JPR/2019[2014-15]Status: DisposedITAT Jaipur02 Oct 2019AY 2014-15

For Appellant: Shri Manish Agarwal (CA)For Respondent: Sh. Bhanwar Singh (JCIT)

Section 143Section 143(2)Section 32(1)Section 92CSection 92C(3)

Transfer Pricing Officer u/s 92CA(3) for determination of Arms Length Price in respect of domestic transactions with Associated Enterprises during the Financial Year 2013-14 relevant to impugned assessment year 2014-15. 3. The TPO passed the order u/s 92CA(3) on 30.06.2017 wherein he has proposed an adjustment of Rs. 1,31,425/- to the income

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 144B(1)(xvi)(b) of the Act. 3. 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 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 144B(1)(xvi)(b) of the Act. 3. 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

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

Transfer 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

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

Transfer 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

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

Transfer 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

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

Transfer 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

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

Transfer Pricing Officer (TPO). The TPO passed an order under section 92CA(3) dated 25.10.2017 of the Act proposing various upward adjustments aggregating to Rs. 4,85,58,87,970/-. The AO after incorporating the proposed adjustments made by the TPO passed draft assessment order under section 144C

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

Transfer 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

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

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

Section 144B(1)(xvi)(b) of the Act. 3. 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

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

Section 144B(1)(xvi)(b) of the Act. 3. 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

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 144B(1)(xvi)(b) of the Act. 3. 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

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

ITA 730/JPR/2018[2009-10]Status: DisposedITAT Jaipur19 Dec 2018AY 2009-10

For Appellant: Shri Vijay Mehta (C.A.) &For Respondent: Smt. Roli Agarwal (CIT)

Section 143(3)Section 271(1)(c)Section 92C

section 92C of the Income Tax Act. 3. During the course of assessment proceedings, the matter was referred by the Assessing officer to the Transfer Pricing Officer (TPO) and the TPO has adopted the CUP method for determination of arm’s length price and has proposed an adjustment of Rs. 18,65,77,973/- determined as the value of interest

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

ITA 731/JPR/2018[2010-11]Status: DisposedITAT Jaipur19 Dec 2018AY 2010-11

For Appellant: Shri Vijay Mehta (C.A.) &For Respondent: Smt. Roli Agarwal (CIT)

Section 143(3)Section 271(1)(c)Section 92C

section 92C of the Income Tax Act. 3. During the course of assessment proceedings, the matter was referred by the Assessing officer to the Transfer Pricing Officer (TPO) and the TPO has adopted the CUP method for determination of arm’s length price and has proposed an adjustment of Rs. 18,65,77,973/- determined as the value of interest

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

ITA 498/JPR/2023[2018-19]Status: DisposedITAT Jaipur21 Feb 2024AY 2018-19

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

3) r.w.s. 144C as invalid and void ab initio \nwhich is liable to be quashed since not passed in accordance with the \nprovisions of Section 144B(1)(xvi)(b) of the Act.\n2. That on the facts and in the circumstances of the case, the Ld. \nCIT(Appeals) was not justified and erred in rejecting the appellant’s \nclaim

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

ITA 1485/JPR/2024[2021-22]Status: DisposedITAT Jaipur30 Jun 2025AY 2021-22

For Appellant: Shri Vinod Kumar Gupta, AdvFor Respondent: Shri Rajesh Ojha, CIT-DR

Section 115JSection 115QSection 143(3)Section 36(1)(va)

3) r.w.s 144C(13) of the Income Tax Act, 1961. \n\n3. The Ld. TPO and Hon'ble DRP has erred on facts and in law in proposing an \nadjustment of amount of Rs.136,31,75,249/- to the income of the appellant on \naccount of alleged difference in Arm's Length Price (ALP) of the international \ntransaction of sale