NARAIN LAL AGRAWAL,JAIPUR vs. DCIT CIRCLE 1 JAIPUR, JAIPUR

In the result the appeal of the assessee is allowed

price\nmentioned in the sale deed and stamp value levied under Stamp Duty Act\namounting to Rs.58,36,000/- has been brought to tax.\nDuring the course of appellate proceedings, the appellant has uploaded written\nsubmission, letter of allotment and the case laws relied upon in support of his\ncontention and claimed that the addition made deserves to be deleted

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

14,94,000/- was also received\non 19/03/2014. Thus, the assessee would not have anticipated or predicted\nthe enactment of new provisions of Sec. 43 CA from assessment year 2014-\n15 while executing the agreement to sell on 10/09/2008. In view of these\nfacts and the decisions of various courts quoted above, the Hon'ble ITAT is\nrequested to delete

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

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

14), hence in my opinion, extinguishment of right/ relinquishment of shares pursuant to merger of the CTL with CVL would be 'transfer of the investments held in CTL thereby attracting the provisions of section 45 of the Act. In the case of Orient Trading Co. Ltd. v. CIT [1997] 224 ITR 371 1 referred to by the appellant

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

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

14), hence in my opinion, extinguishment of right/ relinquishment of shares pursuant to merger of the CTL with CVL would be 'transfer of the investments held in CTL thereby attracting the provisions of section 45 of the Act. In the case of Orient Trading Co. Ltd. v. CIT [1997] 224 ITR 371 1 referred to by the appellant

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

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

14), hence in my opinion, extinguishment of right/ relinquishment of shares pursuant to merger of the CTL with CVL would be 'transfer of the investments held in CTL thereby attracting the provisions of section 45 of the Act. In the case of Orient Trading Co. Ltd. v. CIT [1997] 224 ITR 371 1 referred to by the appellant

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

14), hence in my\nopinion, extinguishment of right/ relinquishment of shares pursuant to merger of\nthe CTL with CVL would be 'transfer of the investments held in CTL thereby\nattracting the provisions of section 45 of the Act.\nIn the case of Orient Trading Co. Ltd. v. CIT [1997] 224 ITR 371 1 referred to by\nthe appellant

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

14), hence in my\nopinion, extinguishment of right/ relinquishment of shares pursuant to merger of\nthe CTL with CVL would be 'transfer of the investments held in CTL thereby\nattracting the provisions of section 45 of the Act.\nIn the case of Orient Trading Co. Ltd. v. CIT [1997] 224 ITR 371 1 referred to by\nthe appellant

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

Accordingly, the same is dismissed

iii) to the Explanation u/s 80A(6) r/w Sec. 80IA(8), transfer price of power captively consumed has to be based on arms’ length principles enshrined in Sec. 92F(ii), since it is specified domestic transaction vide Sec. 92BA.  As could be seen from the Order of Haryana Electricity Regulatory Commission (HERC) dated 14-03-2013, Discoms had claimed reliability

SHREE CEMENT LIMITED,BEAWAR vs. NATIONAL FACELESS ASSESSMENT CENTRE, DELHI

In the result, the appeal of the Revenue in ITA No

Bench: or at the time of hearing of this appeal.

iii) to the Explanation u/s 80A(6) r/w Sec. 80IA(8), transfer price of power captively consumed has to be based on arms’ length principles enshrined in Sec. 92F(ii), since it is specified domestic transaction vide Sec. 92BA.  As could be seen from the Order of Haryana Electricity Regulatory Commission (HERC) dated 14-03-2013, Discoms had claimed reliability

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

Bench: or at the time of hearing of this appeal.

iii) to the Explanation u/s 80A(6) r/w Sec. 80IA(8), transfer price of power captively consumed has to be based on arms’ length principles enshrined in Sec. 92F(ii), since it is specified domestic transaction vide Sec. 92BA.  As could be seen from the Order of Haryana Electricity Regulatory Commission (HERC) dated 14-03-2013, Discoms had claimed reliability

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

iii) to the Explanation u/s 80A(6) r/w Sec. 80IA(8), transfer price of power captively consumed has to be based on arms’ length principles enshrined in Sec. 92F(ii), since it is specified domestic transaction vide Sec. 92BA.\n As could be seen from the Order of Haryana Electricity Regulatory Commission (HERC) dated 14-03-2013, Discoms had claimed

JODHPUR DEVELOPMENT AUTHORITY,JODHPUR vs. DCIT (EXEMPTION), JAIPUR

In the result, the appeal in ITA no

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, AM vk;djvihy la-@ITA No. 665 & 666/JPR/2023 fu/kZkj.ko"kZ@Assessment Years : 2009-10 & 2013-14 Jodhpur Development Authority 1, Opposite Railway Hospital, JDA Circle, Jodhpur. cuke Vs. Deputy Commissioner of Income Tax, Exemption, Jodhpur. LFkk;hys[kk la-@thvkbZvkj la-@PAN/GIR No.: AAALJ 0478 P vihykFkhZ@Appellant izR;FkhZ@Respondent fu/kZkfjrh dh vksjls@Assesseeby : Shri Amit Kothari (C.A.) jktLo dh vksjls@Revenue by:

iii. The ld. CIT(A) and the ld. AO have failed to appreciate the Audited financial statements which were submitted giving Income and Expenditure Statement. The assessment made on the basis of Receipts and payments made by the ld. AO was absolutely unjustified and such order deserves to be set aside. The ld. CIT(A) was not justified in confirming

JODHPUR DEVELOPMENT AUTHORITY,JODHPUR vs. DCIT (EXEMPTION), JAIPUR

In the result, the appeal in ITA no

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

iii. The ld. CIT(A) and the ld. AO have failed to appreciate the Audited financial statements which were submitted giving Income and Expenditure Statement. The assessment made on the basis of Receipts and payments made by the ld. AO was absolutely unjustified and such order deserves to be set aside. The ld. CIT(A) was not justified in confirming

RAJESH CHOUDHARY,GURGAON vs. ACIT CENTRAL CIRCLE, ALWAR, ALWAR

In the result, the appeal of the assessee is allowed

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

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 (2

SONU DUSAD,JAIPUR vs. DCIT CENTRAL CIRCLE, 1, JAIPUR, JAIPUR

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

Bench: This Tribunal Are As Under :

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

Bench: This Tribunal Are As Under :

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

Bench: This Tribunal Are As Under :

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

Bench: This Tribunal Are As Under :

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