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

Accordingly, the same is dismissed

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

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, 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.

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, DELHI

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

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

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

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

DCIT, C-4, JAIPUR vs. M/S. JLC ELECTROMET PVT. LTD., JAIPUR

In the result, the appeal of the Department is dismissed

201 TTJ 811 (JP) (PB 552-578) holding as under: "23. We have heard the rival contentions and perused the material available on record. During the course of assessment proceedings, the Assessing Officer found that the assessee has made payment of selling commission, exhibition expenses and testing expenses to various non-resident entities, without deducting tax at source

INCOME TAX OFFICER , SIKAR vs. BHASKAR CHAUHAN, JAIPUR

In the result the appeal of the revenue in ITA no

Bench: Him.

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

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

VODAFONE DIGILINK LIMITED,JAIPUR vs. ITO, JAIPUR

In the result, appeal of the assessee is allowed

201(1) of the Act." While deciding the above said questions of law, the Hon'ble High Court has held in para 43 to 48 as under: 7 M/s. Vodafone Digilink Ltd., Jaipur. “43. We have heard learned counsel for the parties. 44. Now, the first question which has come up for our consideration is, ‘whether in the facts

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

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

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

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

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)

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

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

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

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

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

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

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

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

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

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

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