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35 results for “transfer pricing”+ Section 192clear

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Key Topics

Addition to Income23Section 26322Section 143(3)18Section 153A16Section 80I16Section 153C13Section 201(1)12Section 6811Disallowance11

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 35 · Page 1 of 2

Section 809
Survey u/s 133A7
Deduction6

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

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 price of power adopted by the assessee in the said case. The Ld. D/R had nothing to defend against the aforesaid contention of the assessee. 8.4 Therefore, respectfully following the aforesaid decision of the coordinate bench of the Jodhpur Tribunal in the case of Hindustan Zinc (supra), we are of the view that reliability charge @15% of Grid rate

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 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 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 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

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

ARUN PALAWAT,JAIPUR vs. PRINCIPAL COMMISSIONER OF INCOME TAX, (CENTRAL),, JAIPUR

The appeal of the assessee is allowed

ITA 599/JPR/2025[2021-22]Status: DisposedITAT Jaipur15 Sept 2025AY 2021-22

Bench: DR. MITHA LAL MEENA (Accountant Member), DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Shri S.R. Sharma, C.A. &For Respondent: Shri Rajesh Ojha, CIT-DR a
Section 115Section 143(3)Section 148BSection 263Section 69A

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

ZARI SILK (INDIA) PRIVATE LIMITED,JAIPUR vs. PRINCIPAL COMMISSIONER OF INCOME TAX (CENTRAL), JAIPUR , JAIPUR

The appeal of the assessee is allowed

ITA 600/JPR/2025[2021-22]Status: DisposedITAT Jaipur15 Sept 2025AY 2021-22

Bench: DR. MITHA LAL MEENA (Accountant Member), DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Shri S.R. Sharma, C.A. &For Respondent: Shri Rajesh Ojha, CIT-DR a
Section 115Section 143(3)Section 148BSection 263Section 69A

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

NEERU MOHAN NAGPAL,JAIPUR vs. INCOME TAX OFFICER, ITO WARD 2(3)

In the result, the appeal of the assessee is allowed

ITA 151/JPR/2022[2016-17]Status: DisposedITAT Jaipur03 May 2024AY 2016-17
For Appellant: MS. Pallavi Khuntenta, (C.A.)For Respondent: Shri Anoop Singh (Addl. CIT)
Section 142(1)Section 143(2)Section 2(47)

section\n2(47) is wide enough to includes the sale exchange or relinquishment of\nthe asset or the astonishment of any right therein or the compulsory\nacquisition thereof under any law. Thus, the assessee had a right that\ninstead of assigning the right to third party/parties, the assessee can\nrelinquished those rights by terminating of the earlier agreement

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

GILLETTE INDIA LIMITED,SPA-65A, INDUSTRIAL AREA, BHIWADI, DISTRICT- ALWAR vs. PCIT, JAIPUR-1, JAIPUR

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

ITA 313/JPR/2023[2016-17]Status: DisposedITAT Jaipur27 Sept 2023AY 2016-17

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

For Appellant: Sh. P. C. ParwalFor Respondent: Sh. Ajay Malik (CIT) a
Section 143(3)Section 192Section 194Section 195Section 263Section 36(1)(va)Section 40

192 of the Act. 5. On the facts and the circumstances of the case and in law, the Ld. PCIT has erred by holding that the total rent of Rs.8,74,00,000/- paid during the year should have been subjected to TDS under section 194-I of the Act and 30% of the balance amount of Rs.3

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

192(SC) The Hon'ble\nCourt held that if, two views are possible, the view in favour of the\nassessee should be preferred.\n(b) Shree Ganesh Trading Co. Vs CIT, Dhanbad (2013) 257 CTR\n159 (Jharkhand)\n(c) CIT, Karnataka Vs Shri Ramdas Motor Transport Ltd. (2015)\n230 Taxman 187 (Andhra Pradesh)\n(d) Chetnaben J. Shah Vs Income

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

section 147 in the reason was typographical error, if considered correct, 46 Lovely promoters Pvt. Ltd. vs. ACIT non-observation of such serious typographical error by two senior officers i.e. (i) Range Head forwarding reason to approval authority with recommendation for approval and (ii) Pr. CIT, approving Authority. Non observation of such serious typographical error led to the conclusion that

INCOME TAX OFFICER, ALWAR vs. ALWAR MALT AND AGRO FOODS MANUFACTURES COMPANY LIMITED, ALWAR

In the result the appeal of the revenue in ITA no

ITA 80/JPR/2025[2014-15]Status: DisposedITAT Jaipur06 Aug 2025AY 2014-15

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

For Appellant: Shri Kranti Mehata, C.AFor Respondent: Shri Gaurav Awasthi, JCIT, Sr.-DR
Section 133ASection 194JSection 201Section 201(1)

192, to a director of a company, or (c) royalty, or (d) any sum referred to in clause (va) of section 28, shall, at the time of credit of such sum to the account of the payee or at the time of payment thereof in cash or by issue of a cheque or draft or by any other mode, whichever

INCOME TAX OFFICER, ALWAR vs. ALWAR MALT AND AGRO FOODS MANUFACTURES COMPANY LIMITED, ALWAR

In the result the appeal of the revenue in ITA no

ITA 81/JPR/2025[2015-16]Status: DisposedITAT Jaipur06 Aug 2025AY 2015-16

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

For Appellant: Shri Kranti Mehata, C.AFor Respondent: Shri Gaurav Awasthi, JCIT, Sr.-DR
Section 133ASection 194JSection 201Section 201(1)

192, to a director of a company, or (c) royalty, or (d) any sum referred to in clause (va) of section 28, shall, at the time of credit of such sum to the account of the payee or at the time of payment thereof in cash or by issue of a cheque or draft or by any other mode, whichever

INCOME TAX OFFICER, ALWAR vs. ALWAR MALT AND AGRO FOODS MANUFACTURES COMPANY LIMITED, ALWAR

In the result the appeal of the revenue in ITA no

ITA 79/JPR/2025[2013-14]Status: DisposedITAT Jaipur06 Aug 2025AY 2013-14

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

For Appellant: Shri Kranti Mehata, C.AFor Respondent: Shri Gaurav Awasthi, JCIT, Sr.-DR
Section 133ASection 194JSection 201Section 201(1)

192, to a director of a company, or (c) royalty, or (d) any sum referred to in clause (va) of section 28, shall, at the time of credit of such sum to the account of the payee or at the time of payment thereof in cash or by issue of a cheque or draft or by any other mode, whichever

SAKET AGARWAL,JAIPUR vs. ITO WARD 2(3) JAIPUR, JAIPUR

In the result appeal filed by the assessee is allowed

ITA 646/JPR/2024[2014-15]Status: DisposedITAT Jaipur01 Oct 2024AY 2014-15

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

For Appellant: Ms. Satwika Jhan, AdvFor Respondent: Ms. Alka Gautam (CIT) a
Section 143(2)Section 143(3)Section 271(1)(c)Section 41(1)

price through fictitious invoices in the name of the parties mentioned in the letter. 3.4 In response to the Final Show cause notice the A/R of the assessee filed written submission on 23rd Dec., 2016. The assessee contended that the address taken from purchase bills has been supplied, further, during the year in some of the cases the amount

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)

192,875\n6,520,997\n725,000\n11,624,320\n5,596,340\n170,000\nTotal B\n13,438,872\n17,390,660\nLess: Closing Stock\nOld Gold\nSilver\nCopper\nTotal C\n149,610\n45,896\n4,857\n200,363\n196,902\n231,610\n4.957\n433,469\nTOTAL RAW MATERIAL CONSUMED