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48 results for “transfer pricing”+ Section 172(4)clear

Sorted by relevance

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Key Topics

Addition to Income44Section 143(3)24Section 153A22Section 234A16Disallowance16Section 14713Section 6913Section 25013Business Income13

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 48 · Page 1 of 3

Section 10(38)12
Section 6811
Depreciation9

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

SHRI KRISHNARAJ BUILDHOME PVT LTD,JAIPUR vs. INCOME TAX OFFICER, JAIPUR

ITA 753/JPR/2023[2014-15]Status: DisposedITAT Jaipur14 Feb 2024AY 2014-15
For Appellant: Sh. Mukesh Kumar Sharma (Adv.)For Respondent: Sh. Monisha Choudhary (Addl.CIT)
Section 143(3)Section 271(1)(c)Section 43CSection 50

172 ITD 396 (ITAT Jaipur)\n“The provisions of section 43CA have been inserted by the Finance Act, 2013\nw.e.f 01.04.2014 relevant to assessment year 2014-15 and if we look at the\nprovisions of sub-section (3) and sub-section (4), it emphasizes a scenario\nwhere the date of agreement fixing value of consideration for transfer of the\nassets

PROFESSIONAL AUTOMOTIVES PRIVATE LIMITED,JAMMU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, JAIPUR

In the result the appeal of the assessee in ITA no

ITA 812/JPR/2025[2016-17]Status: DisposedITAT Jaipur23 Jul 2025AY 2016-17

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, आयकर अपील /ITA Nos.809 to 815/JP/2025 निर्धारण वर्ष /Assessment Years :2013-14 to 2019-20 Professional Automotives Pvt. बनाम ACIT, Ltd. Bahu Plaza, Bahu Plaza, Jammu Vs. Central Circle- 1, and Kashmir Jaipur स्थायी लेखा सं./जी.आई.आर. सं./PAN/GIR No.:AAACP9608E अपीलार्थी/Appellant प्र]त्यर्थी/Respondent निर्धारिती की ओर से / Assessee by :Shri Tarun Mittal, CA राजस्व की ओर से /Revenue by: Shri Ajey Malik, CIT (Th. V.C)

For Appellant: Shri Tarun Mittal, CAFor Respondent: Shri Ajey Malik, CIT (Th. V.C)
Section 143(3)Section 37(1)

Section 194 and 200 were challenged. It was noted in P. RatnakarRao and others V. Govt. Of A.P. and others (1996 (5) SCC 359) that the discretion given under Section 200(1) to the State Government to prescribe maximum rates for compounding the offence is not unguided, uncanalised and arbitrary. It was, inter alia, held as follows: ……………….. ………………. It is indisputable

JAIPAL SINGH,JAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, JAIPUR

ITA 115/JPR/2024[2013-14]Status: DisposedITAT Jaipur11 Mar 2025AY 2013-14
For Appellant: Sh. S.R. Sharma, CA &For Respondent: Sh. Arvind Kumar, CIT-DR
Section 115BSection 153A

172 (Raj.); Kailashben Manharlal Chokshi Vs. Commissioner of Income Tax,\n(2008) 174 Taxman 466 (Gujarat); Commissioner of Income Tax, Central-II,\nMumbai Vs. Omprakash K. Jain, (2009) 178 Taxman 179 (Bombay); Mehta\nParikh & Co. Vs. Commissioner of Income Tax, (1956) 30 ITR 181 (SC); Shree\nGanesh Trading Co. Vs. Commissioner of IncomeTax, Dhanbad, (2013) 257 CTR\n159 (Jharkhand); Commissioner

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

SURYA SINGHAL,KOTA vs. ASSTT. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, JAIPUR, JAIPUR

In the result, the appeal of the assessee is allowed

ITA 928/JPR/2025[2019-20]Status: DisposedITAT Jaipur17 Sept 2025AY 2019-20
For Appellant: Shri Vijay Goyal, C.AFor Respondent: Sh. Gaurav Awasthi, JCIT-DR
Section 115BSection 132(4)Section 143(3)Section 250Section 69

172 (Raj.) wherein it was\nheld that admission in statement during search is not conclusive\nproof of fact and can always be explained.\nviii) Hon'ble ITAT Jaipur Bench in the case of DCIT Vs Ashok Kumar\nAgarwal in ITA No 847/JP/ 2015 order dated 3/10/2016 that:-\n\"16. We have heard the rival contentions of both the parties

JAIPAL SINGH,JAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, JAIPUR

ITA 120/JPR/2024[2018-19]Status: DisposedITAT Jaipur11 Mar 2025AY 2018-19
For Appellant: Sh. S.R. Sharma, CA &For Respondent: Sh. Arvind Kumar, CIT-DR
Section 115BSection 153A

price of the immovable property was Rs.40 lakhs. In the\ncourse of search action it has been found that the appellant has been regularly\nindulging in transactions of sale and purchase of immovable properties and it\ncannot be said that he is not having other sources of income and he has been\nearning income as middleman and income as gain

JAIPAL SINGH,JAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, JAIPUR

ITA 118/JPR/2024[2016-17]Status: DisposedITAT Jaipur11 Mar 2025AY 2016-17
For Appellant: Sh. S.R. Sharma, CA &For Respondent: Sh. Arvind Kumar, CIT-DR
Section 115BSection 153A

price of the immovable property was Rs.40 lakhs. In the\ncourse of search action it has been found that the appellant has been regularly\nindulging in transactions of sale and purchase of immovable properties and it\ncannot be said that he is not having other sources of income and he has been\nearning income as middleman and income as gain

JAIPAL SINGH,JAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, JAIPUR

ITA 116/JPR/2024[2014-15]Status: DisposedITAT Jaipur11 Mar 2025AY 2014-15
For Appellant: Sh. S.R. Sharma, CA &For Respondent: Sh. Arvind Kumar, CIT-DR
Section 115BSection 153A

price of the immovable property was Rs.40 lakhs. In the\ncourse of search action it has been found that the appellant has been regularly\nindulging in transactions of sale and purchase of immovable properties and it\ncannot be said that he is not having other sources of income and he has been\nearning income as middleman and income as gain

DCIT, CIRCLE-6, JAIPUR, NCRB, JAIPUR vs. BARMER LIGNITE MINING COMPANY LIMITED, UDYOG BHAWAN, JAIPUR

Appeals of the assessee are allowed for statistical purposes in view of our detailed order (supra)

ITA 455/JPR/2023[2020-21]Status: DisposedITAT Jaipur16 Dec 2024AY 2020-21

Bench: Dr. S. Seethalakshmi & Shri Gagan Goyal

For Appellant: Mr. P. C. Parwal, CA, Ld. ARFor Respondent: MS. Alka Gautam, CIT, Ld. DR
Section 234ASection 250Section 94E

section 139; 38. The refund has been granted by way of adjustment against the demand in A.Y. 2012-13 on 18.12.2019. Therefore, interest u/s. 244A of the Act is to be calculated from 01.04.2018 to 18.12.2019 i.e. for 21 months. All these facts were explained before the Ld. CIT (A) but the same were ignored by him. In view

DCIT, CIRCLE-6, JAIPUR, NCRB, JAIPUR vs. BARMER LIGNITE MINING COMPANY LIMITED, UDYOG BHAWAN, JAIPUR

Appeals of the assessee are allowed for statistical purposes in view of our detailed order (supra)

ITA 454/JPR/2023[2018-19]Status: DisposedITAT Jaipur16 Dec 2024AY 2018-19

Bench: Dr. S. Seethalakshmi & Shri Gagan Goyal

For Appellant: Mr. P. C. Parwal, CA, Ld. ARFor Respondent: MS. Alka Gautam, CIT, Ld. DR
Section 234ASection 250Section 94E

section 139; 38. The refund has been granted by way of adjustment against the demand in A.Y. 2012-13 on 18.12.2019. Therefore, interest u/s. 244A of the Act is to be calculated from 01.04.2018 to 18.12.2019 i.e. for 21 months. All these facts were explained before the Ld. CIT (A) but the same were ignored by him. In view

BARMER LIGNITE MINING CO. LTD.,C-SCHEME, JAIPUR vs. DCIT, CIRCLE-6, JAIPUR, JAIPUR

Appeals of the assessee are allowed for statistical purposes in view of our detailed order (supra)

ITA 461/JPR/2023[2017-18]Status: DisposedITAT Jaipur16 Dec 2024AY 2017-18

Bench: Dr. S. Seethalakshmi & Shri Gagan Goyal

For Appellant: Mr. P. C. Parwal, CA, Ld. ARFor Respondent: MS. Alka Gautam, CIT, Ld. DR
Section 234ASection 250Section 94E

section 139; 38. The refund has been granted by way of adjustment against the demand in A.Y. 2012-13 on 18.12.2019. Therefore, interest u/s. 244A of the Act is to be calculated from 01.04.2018 to 18.12.2019 i.e. for 21 months. All these facts were explained before the Ld. CIT (A) but the same were ignored by him. In view

DCIT, CIRCLE 6, JAIPUR, NCRB, JPR vs. BARMER LIGNITE MINING COMPANY LIMITED, UDYOG BHAWAN JAIPUR

Appeals of the assessee are allowed for statistical purposes in view of our detailed order (supra)

ITA 453/JPR/2023[2017-18]Status: DisposedITAT Jaipur16 Dec 2024AY 2017-18

Bench: Dr. S. Seethalakshmi & Shri Gagan Goyal

For Appellant: Mr. P. C. Parwal, CA, Ld. ARFor Respondent: MS. Alka Gautam, CIT, Ld. DR
Section 234ASection 250Section 94E

section 139; 38. The refund has been granted by way of adjustment against the demand in A.Y. 2012-13 on 18.12.2019. Therefore, interest u/s. 244A of the Act is to be calculated from 01.04.2018 to 18.12.2019 i.e. for 21 months. All these facts were explained before the Ld. CIT (A) but the same were ignored by him. In view

BARMER LIGNITE MINING CO. LTD.,C-SCHEME, JAIPUR vs. DCIT, CIRCLE-6, JAIPUR, JAIPUR

Appeals of the assessee are allowed for statistical purposes in view of our detailed order (supra)

ITA 462/JPR/2023[2018-19]Status: DisposedITAT Jaipur16 Dec 2024AY 2018-19

Bench: Dr. S. Seethalakshmi & Shri Gagan Goyal

For Appellant: Mr. P. C. Parwal, CA, Ld. ARFor Respondent: MS. Alka Gautam, CIT, Ld. DR
Section 234ASection 250Section 94E

section 139; 38. The refund has been granted by way of adjustment against the demand in A.Y. 2012-13 on 18.12.2019. Therefore, interest u/s. 244A of the Act is to be calculated from 01.04.2018 to 18.12.2019 i.e. for 21 months. All these facts were explained before the Ld. CIT (A) but the same were ignored by him. In view

DCIT, CIRCLE-6 JAIPUR, NCRB, JAIPUR vs. BARMER LIGNITE MINING COMPANY LIMITED, UDYOG BHAWAN, TILAK NAGAR JPR

Appeals of the assessee are allowed for statistical purposes in view of our detailed order (supra)

ITA 452/JPR/2023[2016-17]Status: DisposedITAT Jaipur16 Dec 2024AY 2016-17

Bench: Dr. S. Seethalakshmi & Shri Gagan Goyal

For Appellant: Mr. P. C. Parwal, CA, Ld. ARFor Respondent: MS. Alka Gautam, CIT, Ld. DR
Section 234ASection 250Section 94E

section 139; 38. The refund has been granted by way of adjustment against the demand in A.Y. 2012-13 on 18.12.2019. Therefore, interest u/s. 244A of the Act is to be calculated from 01.04.2018 to 18.12.2019 i.e. for 21 months. All these facts were explained before the Ld. CIT (A) but the same were ignored by him. In view

BARMER LIGNITE MINING CO. LTD.,C-SCHEME, JAIPUR vs. DCIT, CIRCLE-6, JAIPUR, JAIPUR

Appeals of the assessee are allowed for statistical purposes in view of our detailed order (supra)

ITA 463/JPR/2023[2020-21]Status: DisposedITAT Jaipur16 Dec 2024AY 2020-21

Bench: Dr. S. Seethalakshmi & Shri Gagan Goyal

For Appellant: Mr. P. C. Parwal, CA, Ld. ARFor Respondent: MS. Alka Gautam, CIT, Ld. DR
Section 234ASection 250Section 94E

section 139; 38. The refund has been granted by way of adjustment against the demand in A.Y. 2012-13 on 18.12.2019. Therefore, interest u/s. 244A of the Act is to be calculated from 01.04.2018 to 18.12.2019 i.e. for 21 months. All these facts were explained before the Ld. CIT (A) but the same were ignored by him. In view

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

SHRI LALIT KUMAR KALWAR,SARWAR vs. INCOME TAX OFFICER, AJMER

ITA 894/JPR/2017[2013-14]Status: DisposedITAT Jaipur28 Jun 2023AY 2013-14

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

For Appellant: Shri Devang Gargieya (Adv.)For Respondent: Smt. Monisha Choudhary (Addl.CIT) a
Section 271(1)(c)Section 54F

4) is not at all attracted. We may clarify here that provisions of section 54(2) are almost identically worded as in invested the amount for the purchase/ construction of the house within the stipulated period as also observed above while deciding the first issue. The assessee has proved such investment during the assessment proceedings and, thus, the assessee

BARMER LIGNITE MINING CO. LTD.,C-SCHEME, JAIPUR vs. DCIT, CIRCLE-6, JAIPUR

ITA 460/JPR/2023[2016-17]Status: DisposedITAT Jaipur16 Dec 2024AY 2016-17
Section 234ASection 250Section 94E

section 139;\n38. The refund has been granted by way of adjustment against the demand in\nΑ.Υ. 2012-13 on 18.12.2019. Therefore, interest u/s. 244A of the Act is to be\ncalculated from 01.04.2018 to 18.12.2019 i.e. for 21 months. All these facts were\nexplained before the Ld. CIT (A) but the same were ignored by him. In view