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47 results for “transfer pricing”+ Section 14Aclear

Sorted by relevance

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Key Topics

Section 14A54Section 143(3)46Addition to Income35Section 36(1)(iii)31Disallowance20Section 6816Section 36(1)16Section 26315Section 10(38)13Section 69C

GIRNAR SOFTWARE PRIVATE LIMITED,6TH FLOOR, JAIPUR TEXTILE MARKET, B-2, NEAR MODEL TOWN, MALVIYA NAGAR, JAIPUR vs. PCIT – 2, JAIPUR, NEW CENTRAL REVENUE BUILDING

In the result, the appeal of the assessee is allowed

ITA 330/JPR/2023[2018-19]Status: DisposedITAT Jaipur28 Aug 2023AY 2018-19

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

For Appellant: Shri PC Parwal, CAFor Respondent: Shri Arvind Kumar (CIT)
Section 142(1)Section 143(2)Section 14ASection 263

Transfer Pricing Officer, as the case may be,] shall be deemed to be erroneous in so far as it is prejudicial to the interests of the revenue, if, in the opinion of the Principal Chief Commissioner or Chief Commissioner or Principal Commissioner or Commissioner,— (a) the order is passed without making inquiries or verification which should have been made

Showing 1–20 of 47 · Page 1 of 3

11
Bogus/Accommodation Entry6
Deduction5

M/S SHRIRAM GENERAL INSURANCE COMPANY LTD.,E-8, EPIP RIICO INDUSTRIAL AREA, SITAPURA, JAIPUR vs. PCIT, JAIPUR-2, JAIPUR

In the result, this appeal of the assessee is allowed

ITA 260/JPR/2023[2018-19]Status: DisposedITAT Jaipur28 Jun 2023AY 2018-19

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

For Appellant: Shri P.C. Parwal, CAFor Respondent: Shri Ajey Malik, CIT
Section 142(1)Section 143(2)Section 143(3)Section 14ASection 263Section 30Section 44

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

CASTAMET WORKS PRIVATE LIMITED,KHARWA vs. PRINCIPLE COMMISSIONER OF INCOME TAX, UDAIPUR

ITA 187/JPR/2022[2017-18]Status: DisposedITAT Jaipur04 Oct 2022AY 2017-18
For Appellant: Sh. Prakul Khurana (Adv.) &For Respondent: Sh. Sanjay Dhariwal (CIT)
Section 143(1)Section 143(3)Section 14ASection 263Section 36(1)(va)

14A of the Act and having regard to settled jurisprudence of provision of Section 36(1)(va) of the Act took a plausible view for making assessment after accepting the claim of the Appellant. Further, for passing the assessment order Ld. AO also complied with the requisite procedure to be followed by him as per Income Tax Act. Hence

M/S. CHAMBAL FERTILIZERS AND CHEMICALS LIMITED,KOTA vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2, KOTA

In the result, appeal of the revenue is dismissed

ITA 744/JPR/2018[2014-15]Status: DisposedITAT Jaipur13 May 2022AY 2014-15
For Appellant: Shri Percy PardiwallaFor Respondent: Shri Sanjay Dhariwal (CIT)
Section 40A(2)(b)

Transfer of Property Act and Registration Act etc. but nevertheless is entitled to hold the property to the exclusion of all others.” 12 ITA NO. 201(6)/JP/2017 M/s. Chambal Fertilizers & Chemicals Ltd. 70. In the present case, applying the ratio so laid down by the Hon’ble Supreme Court in case of Mysore Minerals, we agree with the findings

CHAMBAL FERTILISERS AND CHEMICALS LIMITED,KOTA vs. DCIT, KOTA

In the result, appeal of the revenue is dismissed

ITA 201/JPR/2017[2012-13]Status: DisposedITAT Jaipur13 May 2022AY 2012-13
For Appellant: Shri Percy PardiwallaFor Respondent: Shri Sanjay Dhariwal (CIT)
Section 40A(2)(b)

Transfer of Property Act and Registration Act etc. but nevertheless is entitled to hold the property to the exclusion of all others.” 12 ITA NO. 201(6)/JP/2017 M/s. Chambal Fertilizers & Chemicals Ltd. 70. In the present case, applying the ratio so laid down by the Hon’ble Supreme Court in case of Mysore Minerals, we agree with the findings

CHAMBAL FERTILISERS AND CHEMICALS LIMITED,KOTA vs. ACIT, KOTA

In the result, appeal of the revenue is dismissed

ITA 291/JPR/2017[2013-14]Status: DisposedITAT Jaipur13 May 2022AY 2013-14
For Appellant: Shri Percy PardiwallaFor Respondent: Shri Sanjay Dhariwal (CIT)
Section 40A(2)(b)

Transfer of Property Act and Registration Act etc. but nevertheless is entitled to hold the property to the exclusion of all others.” 12 ITA NO. 201(6)/JP/2017 M/s. Chambal Fertilizers & Chemicals Ltd. 70. In the present case, applying the ratio so laid down by the Hon’ble Supreme Court in case of Mysore Minerals, we agree with the findings

RAJASTHAN STATE INDUSTRIAL DEVELOPMENT & INVESTMENT CORP. LTD.,JAIPUR vs. ACIT, JAIPUR

In the result, both set of cross appeals for the respective assessment years are disposed off with above directions

ITA 380/JPR/2017[2013-14]Status: DisposedITAT Jaipur29 Mar 2018AY 2013-14
For Appellant: Shri P C ParwalFor Respondent: Shri Varindar Mehta (CIT) fu/kZkfjrh dh vksj ls@
Section 115JSection 14ASection 80I

section 37 of the Income Tax Act which reads as Under. “37. (1) Any expenditure (not being expenditure of the nature described in sections 30 to 36 and not being in the nature of capital expenditure or personal expenses of the assessee), laid out or expended wholly and exclusively for the purposes of the business or profession shall be allowed

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2, KOTA, KOTA vs. CHAMBAL FERTILIZERS AND CHEMICALS LTD, KOTA

ITA 1090/JPR/2024[2010-11]Status: DisposedITAT Jaipur27 Aug 2025AY 2010-11

Bench: SHRI GAGAN GOYAL (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: Shri P.J. Pardiwala, AdvFor Respondent: Shri Rajesh Ojha, CIT &
Section 14ASection 36(1)Section 36(1)(iii)

14A of the Act worked out to be Nil as the investment had its source in cash generated from business operation. o23 ITA No. 1090, 1097 TO 1099 & 1091/JPR/2024 Chambal Fertilizers and Chemicals Ltd., Kota Nothing to the contrary has been argued before us on behalf of the department. Consequently, this ground raised by the department in the two appeals

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2, KOTA, KOTA vs. CHAMBAL FERTILIZERS AND CHEMICALS LTD, KOTA

ITA 1091/JPR/2024[2017-18]Status: DisposedITAT Jaipur27 Aug 2025AY 2017-18

Bench: SHRI GAGAN GOYAL (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: Shri P.J. Pardiwala, AdvFor Respondent: Shri Rajesh Ojha, CIT &
Section 14ASection 36(1)Section 36(1)(iii)

14A of the Act worked out to be Nil as the investment had its source in cash generated from business operation. o23 ITA No. 1090, 1097 TO 1099 & 1091/JPR/2024 Chambal Fertilizers and Chemicals Ltd., Kota Nothing to the contrary has been argued before us on behalf of the department. Consequently, this ground raised by the department in the two appeals

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2, KOTA, KOTA vs. CHAMBAL FERTILIZERS AND CHEMICALS LTD., KOTA

ITA 1097/JPR/2024[2011-12]Status: DisposedITAT Jaipur27 Aug 2025AY 2011-12

Bench: SHRI GAGAN GOYAL (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: Shri P.J. Pardiwala, AdvFor Respondent: Shri Rajesh Ojha, CIT &
Section 14ASection 36(1)Section 36(1)(iii)

14A of the Act worked out to be Nil as the investment had its source in cash generated from business operation. o23 ITA No. 1090, 1097 TO 1099 & 1091/JPR/2024 Chambal Fertilizers and Chemicals Ltd., Kota Nothing to the contrary has been argued before us on behalf of the department. Consequently, this ground raised by the department in the two appeals

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2, KOTA, KOTA vs. CHAMBAL FERTILIZERS AND CHEMICALS LTD., KOTA

ITA 1099/JPR/2024[2016-17]Status: DisposedITAT Jaipur27 Aug 2025AY 2016-17
For Appellant: Shri P.J. Pardiwala, AdvFor Respondent: Shri Rajesh Ojha, CIT &
Section 14ASection 36(1)Section 36(1)(iii)

14A of the Act worked out\nto be Nil as the investment had its source in cash generated from business\noperation.\n023\nITA No. 1090, 1097 TO 1099 & 1091/JPR/2024\nChambal Fertilizers and Chemicals Ltd., Kota\nNothing to the contrary has been argued before us on behalf of the\ndepartment. Consequently, this ground raised by the department in the two\nappeals

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2, KOTA, KOTA vs. CHAMBAL FERTILIZERS AND CHEMICALS LTD, KOTA

ITA 1098/JPR/2024[2015-16]Status: DisposedITAT Jaipur27 Aug 2025AY 2015-16
Section 14ASection 36(1)Section 36(1)(iii)

14A of the Act worked out\nto be Nil as the investment had its source in cash generated from business\noperation.\n023\nITA No. 1090, 1097 ΤΟ 1099 & 1091/JPR/2024\nChambal Fertilizers and Chemicals Ltd., Kota\nNothing to the contrary has been argued before us on behalf of the\ndepartment. Consequently, this ground raised by the department in the two\nappeals

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-3, JAIPUR vs. NARESH KUMAR GUPTA, SRIGANGANAGAR

In the results the appeal of the revenue stands dismissed and the

ITA 458/JPR/2024[2014-15]Status: DisposedITAT Jaipur28 Nov 2024AY 2014-15

Bench: Him The Order Passed Under Section 143(3) Of The Income Tax Act, [ For Short “Act” ] By The Acit, Circle, Sri Ganganagar [

For Appellant: Shri P.C. Parwal (C.A.)For Respondent: Ms. Alka Gautam (CIT) (V.H.)
Section 143(3)Section 14ASection 36(1)(iii)

14A would apply even if no dividend was earned by assessee from investments in shares. 3 (iii) Whether on facts and in circumstances of the case, the CIT(A) is justified in restricting the addition of Rs.97,63,413/- made by the AO on account of 3 & CO No. 09/JPR/2024 DCIT vs. Naresh Kumar Gupta disallowance of interest paid

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)

14A) The provisions of this section shall not apply to any assessment or reassessment order passed by the Assessing Officer with the prior approval of the Principal Commissioner or Commissioner as provided in sub-section (12) of section 144BA. (15) For the purposes of this section,— (a) "Dispute Resolution Panel" means a collegiums comprising of three Principal Commissioners or] Commissioners

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

sections (4) to (10) and as increased by the applicable surcharge, for the purposes of the Union, calculated in the manner provided therein, shall be further increased by an additional surcharge, for the purposes of the Union, to be called the “Health and Education Cess on income-tax”, calculated at the rate of four per cent of such income

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

14A - As decided in Era\nInfrastructure (India) Ltd. [2022 (7) TMI 1093 - DELHI HIGH COURT]Amendment to\nsection 14A of the Act which is for removal of doubts cannot be presumed to be\nretrospective.\n• Hon'ble Delhi High Court in the case of PCIT v. Era Infrastructure (India) Ltd.\n(2022) 7 TMI 1093:Whether ITAT erred in relying

RAJASTHAN STATE INDUSTRIAL DEVELOPMENT & INVESTMENT CORP. LTD.,JAIPUR vs. DCIT, JAIPUR

In the result, appeals of the assessee are partly allowed and appeals of the Revenues are dismissed

ITA 311/JPR/2014[2009-10]Status: DisposedITAT Jaipur23 Feb 2018AY 2009-10
Section 143(3)

transferred from State Government and the Government is allowing the grant from time to time and also allowing the assessee to adjust these liability against amounts payable to the government on account of lease rentals as well as development charges received from allottees. Accordingly, following the earlier order of this Tribunal for the assessment year 2005-06 as well

ACIT, JAIPUR vs. RAJASTHAN STATE INDUSTRIAL DEVELOPMENT & INVESTMENT CORP., JAIPUR

In the result, appeals of the assessee are partly allowed and appeals of the Revenues are dismissed

ITA 420/JPR/2014[2009-10]Status: DisposedITAT Jaipur23 Feb 2018AY 2009-10
Section 143(3)

transferred from State Government and the Government is allowing the grant from time to time and also allowing the assessee to adjust these liability against amounts payable to the government on account of lease rentals as well as development charges received from allottees. Accordingly, following the earlier order of this Tribunal for the assessment year 2005-06 as well

RAJASTHAN STATE INDUSTRIAL DEVELOPMENT & INVESTMENT CORP. LTD.,JAIPUR vs. ACIT, JAIPUR

In the result, appeals of the assessee are partly allowed and appeals of the Revenues are dismissed

ITA 93/JPR/2015[2011-12]Status: DisposedITAT Jaipur23 Feb 2018AY 2011-12
Section 143(3)

transferred from State Government and the Government is allowing the grant from time to time and also allowing the assessee to adjust these liability against amounts payable to the government on account of lease rentals as well as development charges received from allottees. Accordingly, following the earlier order of this Tribunal for the assessment year 2005-06 as well

DCIT, JAIPUR vs. RAJASTHAN STATE INDUSTRIAL DEVELOPMENT & INVESTMENT CORPORTATION LTD., JAIPUR

In the result, appeals of the assessee are partly allowed and appeals of the Revenues are dismissed

ITA 208/JPR/2015[2012-13]Status: DisposedITAT Jaipur23 Feb 2018AY 2012-13
Section 143(3)

transferred from State Government and the Government is allowing the grant from time to time and also allowing the assessee to adjust these liability against amounts payable to the government on account of lease rentals as well as development charges received from allottees. Accordingly, following the earlier order of this Tribunal for the assessment year 2005-06 as well