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61 results for “transfer pricing”+ Section 201(1)clear

Sorted by relevance

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Key Topics

Addition to Income43Section 143(3)38Section 80I31Section 153A30Section 6829Disallowance26Section 36(1)(iii)25Section 26321Section 234A19

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

section (6) to provide that, with effect from 1-4-2012, the provisions of sub-section shall cease to have effect. Accordingly, a SEZ developer or any entrepreneur carrying on business in an SEZ unit (being a company) would be liable to pay MAT on the profits arising from the development of SEZ or the business carried

Showing 1–20 of 61 · Page 1 of 4

Section 69C18
Business Income12
Bogus/Accommodation Entry10

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

Accordingly, the same is dismissed

ITA 490/JPR/2023[2016-17]Status: DisposedITAT Jaipur21 Feb 2024AY 2016-17
Section 115JSection 143Section 143(3)Section 144B(1)(xvi)Section 80Section 80I

transfer power directly to the ultimate industrial consumer i.e. the manufacturing units of assessee. 30.13. Further, the aspect as to why rate at which power is sold to 3rd parties including Power distribution companies should not be considered as internal CUP and hence considered for computing arm's length price under the Transfer Pricing regulations, needs to be dealt with

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

ITA 497/JPR/2023[2017-18]Status: DisposedITAT Jaipur21 Feb 2024AY 2017-18
Section 115JSection 143Section 143(3)Section 144B(1)(xvi)Section 80Section 80I

transfer power directly to the ultimate industrial consumer i.e. the manufacturing units of assessee.\n30.13. Further, the aspect as to why rate at which power is sold to 3rd parties including Power distribution companies should not be considered as internal CUP and hence considered for computing arm's length price under the Transfer Pricing regulations, needs to be dealt with

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. 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

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

ITA 489/JPR/2023[2015-16]Status: DisposedITAT Jaipur21 Feb 2024AY 2015-16
For Appellant: Sh. Dilip B Desai(C.A.)For Respondent: Sh. Alka Gautam (CIT) (V.H) &
Section 115JSection 143Section 143(3)Section 144B(1)(xvi)Section 80Section 80I

section 80IA(8) of the Act.\n30.10. Considering that TPO has disputed the Grid rate not to be\nthe market value in terms of provisions of Section 80A(6) of the\nAct, we would like to state here that that unlike Section 80IA(8),\nthe word \"OR\" is missing in provisions of Section 80A(6) of the\nAct

INCOME TAX OFFICER , SIKAR vs. BHASKAR CHAUHAN, JAIPUR

In the result the appeal of the revenue in ITA no

ITA 868/JPR/2024[2017-18]Status: DisposedITAT Jaipur24 Jul 2025AY 2017-18

Bench: Him.

For Appellant: Shri S.L.Poddar, AdvFor Respondent: Mrs Alka Gautam, CIT-DR a
Section 143(3)Section 144Section 153CSection 251Section 69Section 69ASection 69C

price received by the seller of the goods for the acquisition of which it has already incurred the cost. It is the realisation of excess over the cost incurred that only forms part of the profit included in the consideration of sales. (4) Manmohan Sadhani Vs. Commissioner of Income Tax, (2008) 304 ITR 0052 – Hon’ble M.P. HighCourt In this

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

201 to 218 on\nsecond floor of Arcade Building constructed on plot no. K-12, Malviya Marg,\nC-Scheme, Jaipur for an apparent consideration of Rs. 1,51,00,000/-. As\nagainst this apparent consideration of Rs. 1,51,00,000/-, the sub-registrar has\nvalued the property for purposes of Stamp Duty & Registration

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)

201 & 209/JP/2017 and 744/JP/2018, relating to the assessment years 2012-13, 2013-14 and 2014-15, relating to the appellant, wherein, it was held that no disallowance of interest could be made in respect of the amount invested by the assessee company in the subsidiaries, either u/s 36(1

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)

201 & 209/JP/2017 and 744/JP/2018, relating to the assessment years 2012-13, 2013-14 and 2014-15, relating to the appellant, wherein, it was held that no disallowance of interest could be made in respect of the amount invested by the assessee company in the subsidiaries, either u/s 36(1

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)

201 & 209/JP/2017 and 744/JP/2018, relating to the assessment years 2012-13, 2013-14 and 2014-15, relating to the appellant, wherein, it was held that no disallowance of interest could be made in respect of the amount invested by the assessee company in the subsidiaries, either u/s 36(1

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)

201(1A) of Rs. 42,55,977/- in Alwar Malt and Agro Foods Manufactures Co. Ltd., Alwar. respect of payments of Rs. 5,91,10,794/- made to three concerns namely M/s Saraya Distilleries Ltd., Pay Fair Enterprise and United Spirits Ltd., under the head “Franchise Expenses” holding that the impugned payments made by the assessee company does not come

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)

201(1A) of Rs. 42,55,977/- in Alwar Malt and Agro Foods Manufactures Co. Ltd., Alwar. respect of payments of Rs. 5,91,10,794/- made to three concerns namely M/s Saraya Distilleries Ltd., Pay Fair Enterprise and United Spirits Ltd., under the head “Franchise Expenses” holding that the impugned payments made by the assessee company does not come

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)

201(1A) of Rs. 42,55,977/- in Alwar Malt and Agro Foods Manufactures Co. Ltd., Alwar. respect of payments of Rs. 5,91,10,794/- made to three concerns namely M/s Saraya Distilleries Ltd., Pay Fair Enterprise and United Spirits Ltd., under the head “Franchise Expenses” holding that the impugned payments made by the assessee company does not come

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)

201 & 209/JP/2017 and\n744/JP/2018, relating to the assessment years 2012-13, 2013-14 and\n2014-15, relating to the appellant, wherein, it was held that no disallowance\nof interest could be made in respect of the amount invested by the\nassessee company in the subsidiaries, either u/s 36(1) (iii) or 14A of the\nAct\n05\nITA

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)

201 & 209/JP/2017 and\n744/JP/2018, relating to the assessment years 2012-13, 2013-14 and\n2014-15, relating to the appellant, wherein, it was held that no disallowance\nof interest could be made in respect of the amount invested by the\nassessee company in the subsidiaries, either u/s 36(1) (iii) or 14A of the\nAct\n05\nITA

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

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 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

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