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22 results for “transfer pricing”+ Section 148Aclear

Sorted by relevance

Mumbai51Jaipur22Delhi21Bangalore8Chennai7Chandigarh7Kolkata5Agra5Pune4Rajkot4Hyderabad2Indore2Guwahati1Nagpur1Amritsar1Ahmedabad1Visakhapatnam1

Key Topics

Section 14824Section 14717Addition to Income14Section 143(3)13Section 689Section 69C9Section 153C8Section 148A5Section 142(1)5Bogus/Accommodation Entry

INCOME TAX OFFICER, WARD-1(2), JAIPUR, JAIPUR vs. MUKESH KUMAR SONI, JAIPUR

In the result appeal of the revenue is dismissed and the cross

ITA 656/JPR/2023[2018-19]Status: DisposedITAT Jaipur04 Mar 2024AY 2018-19

Bench: Moving Towards The Facts Of The Case We Would Like To Mention

For Appellant: Sh. S. B. Natani (FCA)For Respondent: Sh. Arvind Kumar (CIT)
Section 143(1)Section 143(3)Section 144BSection 147Section 148A

transfer pricing, data analytics, management or any other technical matter under this Act or an agreement entered into under section 90 or 90A, which may be required in a particular case or a class of cases, under this section and the term "technical unit", wherever used in this section, shall refer to an Assessing Officer having powers so assigned

Showing 1–20 of 22 · Page 1 of 2

4
Reassessment3
Reopening of Assessment3

LOVELY PROMOTERS PRIVATE LIMITED,KOLKATA vs. ACIT, CENTRAL CIRCLE, AJMER, AJMER

In the result, the appeal filed by the assessee is allowed

ITA 770/JPR/2023[2013-14]Status: DisposedITAT Jaipur08 Feb 2024AY 2013-14

Bench: him regarding non mentioning of Document Identification Number (DIN) in the body of the order u/s. 127 of the Act dated 08-09-2021 and various other technical pleas raised in grounds of appeal regarding validity of notice u/s. 148 of the Act, thereby appellate order passed by the CIT(A) is non-speaking order and deserves to be quashed. 4. On the facts and in circumstances of the case and in law, the AO erred in issuing notice u/s. 148 of the Act as it was a search related case u/s. 132 r/w

For Appellant: Shri Mayank Taparia (Adv.)For Respondent: Shri A.S. Nehra (Addl.CIT) a
Section 127Section 127(1)Section 132Section 147Section 148Section 148ASection 151Section 153C

transfer of jurisdiction from Kolkata to ACIT, central Circle, Ajmer (Rajsthan) was duly passed by the PCIT-5, Kolkata and the current AO was having jurisdiction on the date of passing the reassessment order. Thus the grounds in which the appellant had raised the objection of jurisdiction is duly dismissed. 9 Lovely promoters Pvt. Ltd. vs. ACIT Further, the appellant

SUVA LAL PAHARIA,JAIPUR vs. ITO WARD 6(3), JAIPUR

ITA 157/JPR/2024[2008-09]Status: DisposedITAT Jaipur24 Jun 2024AY 2008-09
For Appellant: Sh. Shrawan Kumar Gupta (Adv.) &For Respondent: Smt. Monisha Chaudhary (Addl.CIT)
Section 144Section 147Section 5

transferred to NFAC. The NFAC has passed the Exparty order on\ndt.29.11.2023, despite the Ws and reply filed by the assessee. The order was received on\nportal on dt. 29.11.2023 and on email, which was not served upon the assessee physical.\nHowever as per date of order the appeal was to be filed on or before 28.01.2024 but the\nsame

INCOME TAX OFFICE, WARD-6(2), JAIPUR, JAIPUR vs. MEDICAL DESIGNS INDIA PVT. LTD., JAIPUR

ITA 236/JPR/2024[2011-12]Status: DisposedITAT Jaipur27 Sept 2024AY 2011-12
For Appellant: Shri Ratan Lal Goyal (C.A.) &For Respondent: Shri Arvind Kumar (CIT)
Section 127Section 142(1)Section 144Section 147Section 148

section 148A(b) did not align with notice issued under\nsection 148A(b), impugned order and consequential notice were to be set aside.\nFrom the above discussion it is clear that the alleged property in question for the\nreassessment was sold by the appellant and not purchased by the appellant.\nTherefore, the ground raised by the appellant is hereby allowed

FEDERATION OF RAJASTHAN TRADE AND INDUSTRY,JAIPUR vs. ITO-EXEMPTION WARD-2, JAIPUR

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 217/JPR/2024[2014-15]Status: DisposedITAT Jaipur04 Oct 2024AY 2014-15

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

For Appellant: Shri Rahul Pandya (Adv.) &For Respondent: Shri Anoop Singh (Addl.CIT) a
Section 127Section 12ASection 142(1)Section 143(2)Section 143(3)Section 250

price which property would fetch on sale in open market on relevant date Held, yes Whether Wealth Tax Act provides a mechanism under which property is valued and net wealth determined for purpose of payment of wealth tax and it is not a fair market value - Held, yes - Whether in determining fair market value, guideline value prescribed for purpose

SHREE CEMENT LIMITED,BANGUR NAGAR vs. ACIT, CENTRAL CIRCLE, AJMER

In the result, the appeal of the assessee - appellant in ITA No

ITA 1517/JPR/2024[2019-2020]Status: DisposedITAT Jaipur24 Jun 2025AY 2019-2020

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Shri Dilip B. Desai, FCAFor Respondent: Shri Arvind Kumar, CIT-DR
Section 115JSection 143(1)Section 254Section 36(1)(va)Section 80Section 801A

148A(b) of the Income-tax Act, 1961 was issued to the assessee on 30.03.2025 for making compliance on or before 21.04.2025. Reply of the assessee is awaited. 6. Further, the required additional grounds of appeal wise report, is as under: a) Inclusion of Reliability Charge while computing Transfer Price for Power undertaking u/s 80IA In the assessment years

DURGA PRASAD SHARMA,JAIPUR vs. I.T.O. WARD 1(1), JAIPUR, JAIPUR

In the result, the appeal of the assessee is allowed

ITA 1038/JPR/2025[A.Y. 2018-19]Status: HeardITAT Jaipur20 Nov 2025

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

For Appellant: Sh. G. M. Mehta, CAFor Respondent: Sh. Ghanshyam Meena, JCIT
Section 115BSection 148Section 2Section 69C

148A(b). Accordingly, the procedure adopted by the Assessing Officer does not suffer from any legal infirmity. The appellant also contended that no addition could be made under section. 69C when payments were made through banking channels. This argument is misplaced. Section 69C is not limited to cash payments but covers any unexplained or unsubstantiated expenditure, regardless of mode. Even

PRAMILA AGARWAL,JAIPUR vs. THE INCOME TAX OFFICER WARD-2(5), JAIPUR

In the result, the appeal of the assessee is allowed

ITA 531/JPR/2025[2011-12]Status: DisposedITAT Jaipur10 Oct 2025AY 2011-12
For Appellant: Shri Tarun Mittal, C.AFor Respondent: Shri Gorav Avasthi, JCIT
Section 147Section 148Section 68

transfer of long term securities (Conditions precedent)\n Assessment year 2014-15 - For relevant year, assessee filed her return claiming\nexemption under section 10(38) in respect of capital gains arising from sale of shares\nBoth lower authorities had disallowed assessee's claim for exemption on basis of\nevidence received from Investigation Wing as purchase and sale were found

RAGHAV COMMODITIES,JAIPUR vs. ITO WARD 6(2), JAIPUR

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

ITA 943/JPR/2024[2015-2016]Status: DisposedITAT Jaipur29 Nov 2024AY 2015-2016

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Sh. Tarun Mittal, CAFor Respondent: Sh. Arvind Kumar, CIT-DR
Section 142(1)Section 147Section 148Section 148A

section 149 of the Income Tax Act, 1961. Counter submission: The contention of the assessee that the proceeding has been barred by limitation mentioned u/s 149 of the Act is not tenable in view of the Para- 6 of CBDT's Instruction No. 01/2022 (F.No. 279/Misc/M-51/2022-ITJ) dated 11th May, 2022. For the sake of clarity para 6 of CBDT

ALOK KUMAR JAIN ,PEARL PLEASURE vs. ACIT CIR-6, JAIPUR, NEW CERNTRAL REVENUE BUILDING, BHAGWAN DASS ROAD, JAIPUR, RAJASTHAN,

ITA 1191/JPR/2024[2016-17]Status: DisposedITAT Jaipur24 Mar 2025AY 2016-17

Bench: Him.

For Appellant: Sh. Prakul Khurana, Adv. &For Respondent: Mrs. Anita Rinesh, JCIT-Sr. DR
Section 10(38)Section 147Section 148Section 250Section 68Section 69A

148A(c) of the Act and thereby the notice u/s. 148 of the Act was issued to the assessee on 26.07.2022. The assessee also challenged issue notice u/s. 148 of the Act before the Jurisdictional High Court. As the High Court did not grant any stay or passed on the order the ld. AO proceeded by making the assessment based

RAVINDER SINGH THAKKAR,JAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, JAIPUR

In the result the appeal of the assessee in ITA no

ITA 819/JPR/2025[2018-19]Status: DisposedITAT Jaipur25 Jul 2025AY 2018-19
For Appellant: Shri Tarun Mittal, C.AFor Respondent: Shri Gorav Avasthi, JCIT
Section 143(3)Section 147

transfer the case) and not by JAO.\nHon'ble Bombay High Court in the case of Hexaware Technologies Ltd. v.\nACIT, Circle 15(1)(2), Mumbai and others [2024] 162 taxmann.com 225\n(Bombay), has held that there is no question of concurrent jurisdiction of JAO\nand FAO for issuance of reopening notice under section 148 or even for passing

RAVINDER SINGH THAKKAR,JAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, JAIPUR

In the result the appeal of the assessee in ITA no

ITA 820/JPR/2025[2019-20]Status: DisposedITAT Jaipur25 Jul 2025AY 2019-20
For Appellant: Shri Tarun Mittal, C.AFor Respondent: Shri Gorav Avasthi, JCIT
Section 143(3)Section 147

transfer the case) and not by JAO.\nHon'ble Bombay High Court in the case of Hexaware Technologies Ltd. v.\nACIT, Circle 15(1)(2), Mumbai and others [2024] 162 taxmann.com 225\n(Bombay), has held that there is no question of concurrent jurisdiction of JAO\nand FAO for issuance of reopening notice under section 148 or even for passing

RAVINDER SINGH THAKKAR,JAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, JAIPUR

In the result the appeal of the assessee in ITA no

ITA 818/JPR/2025[2017-18]Status: DisposedITAT Jaipur25 Jul 2025AY 2017-18
For Appellant: Shri Tarun Mittal, C.AFor Respondent: Shri Gorav Avasthi, JCIT
Section 143(3)Section 147

transfer the case) and not by JAO.\nHon'ble Bombay High Court in the case of Hexaware Technologies Ltd. v.\nACIT, Circle 15(1)(2), Mumbai and others [2024] 162 taxmann.com 225\n(Bombay), has held that there is no question of concurrent jurisdiction of JAO\nand FAO for issuance of reopening notice under section 148 or even for passing

RAVINDER SINGH THAKKAR,JAIPUR vs. ASSISTANT COMMSSIONER OF INCOME TAX, JAIPUR

In the result the appeal of the assessee in ITA no

ITA 817/JPR/2025[2016-17]Status: DisposedITAT Jaipur25 Jul 2025AY 2016-17
For Appellant: Shri Tarun Mittal, C.AFor Respondent: Shri Gorav Avasthi, JCIT
Section 143(3)Section 147

transfer the case) and not by JAO.\nHon'ble Bombay High Court in the case of Hexaware Technologies Ltd. v.\nACIT, Circle 15(1)(2), Mumbai and others [2024] 162 taxmann.com 225\n(Bombay), has held that there is no question of concurrent jurisdiction of JAO\nand FAO for issuance of reopening notice under section 148 or even for passing

RAVINDER SINGH THAKKAR,JAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, JAIPUR

In the result the appeal of the assessee in ITA no

ITA 816/JPR/2025[2015-16]Status: DisposedITAT Jaipur25 Jul 2025AY 2015-16
For Appellant: Shri Tarun Mittal, C.AFor Respondent: Shri Gorav Avasthi, JCIT
Section 143(3)Section 147

transfer the case) and not by JAO.\nHon'ble Bombay High Court in the case of Hexaware Technologies Ltd. v.\nACIT, Circle 15(1)(2), Mumbai and others [2024] 162 taxmann.com 225\n(Bombay), has held that there is no question of concurrent jurisdiction of JAO\nand FAO for issuance of reopening notice under section 148 or even for passing

RADHAKISHNA BENIWAL,JAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 1, JAIPUR, JAIPUR

In the result, the appeal filed by the assessee in ITA no

ITA 694/JPR/2025[2015-16]Status: DisposedITAT Jaipur10 Sept 2025AY 2015-16

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Shri P. C. Parwal, CA &For Respondent: Shri Gorav Avasthi, JCIT
Section 139Section 144Section 147rSection 148Section 148ASection 194CSection 251Section 68

transfer upon Principal Chief Commissioner or Principal Director General of National e- Assessment Centre and not upon any other Principal Director General or Director General or Principal Chief Commissioner or Chief Commissioner or Principal Commissioner or Commissioner. As is evident from the above, the Court came to the firm conclusion that irrespective of the system of faceless assessment that

RADHAKISHAN BENIWAL,JAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 1, JAIPUR, JAIPUR

In the result, the appeal filed by the assessee in ITA no

ITA 695/JPR/2025[2016-17]Status: DisposedITAT Jaipur10 Sept 2025AY 2016-17

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Shri P. C. Parwal, CA &For Respondent: Shri Gorav Avasthi, JCIT
Section 139Section 144Section 147rSection 148Section 148ASection 194CSection 251Section 68

transfer upon Principal Chief Commissioner or Principal Director General of National e- Assessment Centre and not upon any other Principal Director General or Director General or Principal Chief Commissioner or Chief Commissioner or Principal Commissioner or Commissioner. As is evident from the above, the Court came to the firm conclusion that irrespective of the system of faceless assessment that

JUHI BHANDARI, JAIPUR,JAIPUR vs. DCIT CIRCLE (INTL TAX), JAIPUR, JAIPUR

In the result, both appeals of the assessee are allowed

ITA 234/JPR/2025[2015-16]Status: DisposedITAT Jaipur13 Aug 2025AY 2015-16
For Appellant: Shri Siddharth Ranka, AdvFor Respondent: Smt. Runi Pal, CIT (through VC)
Section 144C(5)Section 153CSection 69

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

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

DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-3, JAIPUR vs. SAPNA KARNANI, TONK PHATAK

In the result, the appeals of the revenue in ITA No

ITA 712/JPR/2025[2017-18]Status: DisposedITAT Jaipur14 Oct 2025AY 2017-18
For Appellant: Shri Deepak Sharma, CAFor Respondent: Ms. Alka Gautam, CIT, DR
Section 139(1)Section 153ASection 153CSection 68Section 69C

148A of the Act of 1961 which has no\napplication in the present cases.\n18\nITA Nos.709/JP/2025\nDCIT vs. Sapna Karnani\n16. Learned counsel for the revenue does not dispute the legal position that where the\nbasis for reassessment is incriminating material and information collected during search,\nthe only legally permissible course of action is the one provided under section