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53 results for “transfer pricing”+ Section 224clear

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Key Topics

Section 143(3)53Section 153A31Addition to Income29Section 133A24Section 36(1)(iii)23Section 36(1)16Section 26316Section 14A15Limitation/Time-bar

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

Showing 1–20 of 53 · Page 1 of 3

14
Section 143(2)13
Condonation of Delay13
Disallowance12

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

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)

Price Waterhouse Coopers as the sales proceeds from amalgamation and calculated capital gains based on such figure. From the detailed submissions placed before me, it is seen that the word "transfer has been inclusively defined in section 2(47) to include exchange, relinquishment and extinguishment of an asset and is not merely restricted to sale of capital asset. Since investment

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)

Price Waterhouse Coopers as the sales proceeds from amalgamation and calculated capital gains based on such figure. From the detailed submissions placed before me, it is seen that the word "transfer has been inclusively defined in section 2(47) to include exchange, relinquishment and extinguishment of an asset and is not merely restricted to sale of capital asset. Since investment

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)

Price Waterhouse Coopers as the sales proceeds from amalgamation and calculated capital gains based on such figure. From the detailed submissions placed before me, it is seen that the word "transfer has been inclusively defined in section 2(47) to include exchange, relinquishment and extinguishment of an asset and is not merely restricted to sale of capital asset. Since investment

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)

Price Waterhouse Coopers as\nthe sales proceeds from amalgamation and calculated capital gains based on\nsuch figure.\nFrom the detailed submissions placed before me, it is seen that the word\n\"transfer has been inclusively defined in section 2(47) to include exchange,\nrelinquishment and extinguishment of an asset and is not merely restricted to\nsale of capital asset. Since

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)

Price Waterhouse Coopers as\nthe sales proceeds from amalgamation and calculated capital gains based on\nsuch figure.\nFrom the detailed submissions placed before me, it is seen that the word\n\"transfer has been inclusively defined in section 2(47) to include exchange,\nrelinquishment and extinguishment of an asset and is not merely restricted to\nsale of capital asset. Since

SHRI KALYAN BUILDMART PVT. LTD,JAIPUR vs. PRINCIPAL COMMISSIONER OF INCOME TAX-2, JAIPUR, JAIPUR

ITA 126/JPR/2022[2017-18]Status: DisposedITAT Jaipur16 Sept 2022AY 2017-18

Bench: The Date Of Hearing.”

For Appellant: Sh. Rajeev Sogani (CA) &For Respondent: Sh. Prathviraj Meena (CIT)
Section 143(2)Section 143(3)Section 263Section 6(3)(ii)

transferring the majority shareholding to a company & an Individual from where share capital and share premium has flown in on the basis of Asset Based method. The authenticity of the credits share capital and share premium has not been established.” 7. Based on the submission and discussion she has taken a view which in the proceeding before her under section

REGAL TRANSCORE LAMINATIONS PRIVATE LIMITED,JAIPUR vs. DCIT CIRCLE 7, JAIPUR, JAIPUR

In the result, the appeal filed by the assessee in I

ITA 33/JPR/2024[2012-13]Status: DisposedITAT Jaipur10 Apr 2024AY 2012-13

Bench: Sh. Sandep Gosain & Dr. M. L. Meena

For Appellant: Sh. Rohan Sogani, CAFor Respondent: Sh. A.S. Nehra, Addl. CIT
Section 143(2)Section 143(3)Section 145(3)

Transfer Pricing regulations through which additions, if at all, could have been made to the income of the company, were not enforce for the year under consideration as per unrebutted reply of the Assessee ( the [CIT(A)/NFAC Pages 14-15]. Without prejudice to above, we have upheld the decision of the CIT(A) being passed as per judicial discipline

REGAL TRANSCORE LAMINATIONS PRIVATE LIMITED,JAIPUR vs. DCIT, CIRCLE- 7, JAIPUR , JAIPUR

In the result, the appeal filed by the assessee in I

ITA 714/JPR/2023[2014-15]Status: DisposedITAT Jaipur10 Apr 2024AY 2014-15

Bench: Sh. Sandep Gosain & Dr. M. L. Meena

For Appellant: Sh. Rohan Sogani, CAFor Respondent: Sh. A.S. Nehra, Addl. CIT
Section 143(2)Section 143(3)Section 145(3)

Transfer Pricing regulations through which additions, if at all, could have been made to the income of the company, were not enforce for the year under consideration as per unrebutted reply of the Assessee ( the [CIT(A)/NFAC Pages 14-15]. Without prejudice to above, we have upheld the decision of the CIT(A) being passed as per judicial discipline

RAJASTHAN TRANSMAT PRIVATE LIMITED,JAIPUR vs. INCOME TAX OFFICER ,WARD 7(2),, JAIPUR

In the result, the appeal of the assessee partly allowed

ITA 165/JPR/2023[2012-13]Status: DisposedITAT Jaipur11 Jul 2023AY 2012-13

Bench: SHRI SANDEEP GOSAIN (Judicial Member), DR MEETHA LAL MEENA (Accountant Member)

For Appellant: Mrs. Prabha Rana, AR and Shri Vinod Kumar, AdvocateFor Respondent: Mrs. Runi Pal, Addl. CIT-DR
Section 133(6)Section 142(1)Section 143(2)

transfer pricing adjustment. It is hereby informed that the Board has accepted the decision of the High Court of Bombay in the above mentioned Writ Petition. In view of the acceptance of the above judgment, it is directed that the ratio decidenal of the judgment must be adhered to by the field officers in all cases where this issue

MARIE PRODUCTS PRIVATE LIMITED,JAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE 7, JAIPUR

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

ITA 771/JPR/2023[2018-19]Status: DisposedITAT Jaipur21 Apr 2025AY 2018-19

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Sh. P. C. Parwal, CAFor Respondent: Sh. Ajay Malik, CIT
Section 14Section 142(1)Section 143(3)

transferred under sub-section (8)], on or after the 1st day of April, 2021, shall be non est if such assessment is not made in accordance with the procedure laid down under this section." (emphasis supplied) 14. Keeping in view the aforesaid, this Court is of the opinion that learned counsel for the petitioner is correct in submitting that Section

MANOJ KUMAR SHARMA,JAIPUR vs. PCIT(CENTRAL), JAIPUR

In the result appeal of the assessee in the ITA No

ITA 283/JPR/2022[2015-16]Status: DisposedITAT Jaipur25 Nov 2022AY 2015-16
For Appellant: ShriMahendraGargieya (Adv.)&For Respondent: ShriJames Kurian (CIT)
Section 143(3)Section 263

Transfer Pricing Officer, as the case may be,] is erroneous in so far as it is prejudicial to the interests of the revenue, he may, after giving the assessee an opportunity of being heard and after making or causing to be made such inquiry as he deems necessary, pass such order thereon as the circumstances of the case justify

RAM KISHAN VERMA,KOTA vs. PCIT (CENTRAL), JAIPUR

In the result appeal of the assessee in the ITA No

ITA 222/JPR/2022[2017-18]Status: DisposedITAT Jaipur25 Nov 2022AY 2017-18
For Appellant: ShriMahendraGargieya (Adv.)&For Respondent: ShriJames Kurian (CIT)
Section 143(3)Section 263

Transfer Pricing Officer, as the case may be,] is erroneous in so far as it is prejudicial to the interests of the revenue, he may, after giving the assessee an opportunity of being heard and after making or causing to be made such inquiry as he deems necessary, pass such order thereon as the circumstances of the case justify

RAM KISHAN VERMA,KOTA vs. PCIT (CENTRAL), JAIPUR

In the result appeal of the assessee in the ITA No

ITA 217/JPR/2022[2012-13]Status: DisposedITAT Jaipur25 Nov 2022AY 2012-13
For Appellant: ShriMahendraGargieya (Adv.)&For Respondent: ShriJames Kurian (CIT)
Section 143(3)Section 263

Transfer Pricing Officer, as the case may be,] is erroneous in so far as it is prejudicial to the interests of the revenue, he may, after giving the assessee an opportunity of being heard and after making or causing to be made such inquiry as he deems necessary, pass such order thereon as the circumstances of the case justify

RAM KISHAN VERMA,KOTA vs. PCIT (CENTRAL), JAIPUR

In the result appeal of the assessee in the ITA No

ITA 223/JPR/2022[2018-19]Status: DisposedITAT Jaipur25 Nov 2022AY 2018-19
For Appellant: ShriMahendraGargieya (Adv.)&For Respondent: ShriJames Kurian (CIT)
Section 143(3)Section 263

Transfer Pricing Officer, as the case may be,] is erroneous in so far as it is prejudicial to the interests of the revenue, he may, after giving the assessee an opportunity of being heard and after making or causing to be made such inquiry as he deems necessary, pass such order thereon as the circumstances of the case justify

HARISH JAIN,JAIPUR vs. PCIT (CENTRAL), JAIPUR

In the result appeal of the assessee in the ITA No

ITA 215/JPR/2022[2015-16]Status: DisposedITAT Jaipur25 Nov 2022AY 2015-16
For Appellant: ShriMahendraGargieya (Adv.)&For Respondent: ShriJames Kurian (CIT)
Section 143(3)Section 263

Transfer Pricing Officer, as the case may be,] is erroneous in so far as it is prejudicial to the interests of the revenue, he may, after giving the assessee an opportunity of being heard and after making or causing to be made such inquiry as he deems necessary, pass such order thereon as the circumstances of the case justify

HARISH JAIN,KOTA vs. PCIT (CENTRAL), JAIPUR

In the result appeal of the assessee in the ITA No

ITA 216/JPR/2022[2016-17]Status: DisposedITAT Jaipur25 Nov 2022AY 2016-17
For Appellant: ShriMahendraGargieya (Adv.)&For Respondent: ShriJames Kurian (CIT)
Section 143(3)Section 263

Transfer Pricing Officer, as the case may be,] is erroneous in so far as it is prejudicial to the interests of the revenue, he may, after giving the assessee an opportunity of being heard and after making or causing to be made such inquiry as he deems necessary, pass such order thereon as the circumstances of the case justify

RAM KISHAN VERMA,KOTA vs. PCIT (CIRCLE), JAIPUR

In the result appeal of the assessee in the ITA No

ITA 219/JPR/2022[2014-15]Status: DisposedITAT Jaipur25 Nov 2022AY 2014-15
For Appellant: ShriMahendraGargieya (Adv.)&For Respondent: ShriJames Kurian (CIT)
Section 143(3)Section 263

Transfer Pricing Officer, as the case may be,] is erroneous in so far as it is prejudicial to the interests of the revenue, he may, after giving the assessee an opportunity of being heard and after making or causing to be made such inquiry as he deems necessary, pass such order thereon as the circumstances of the case justify

RAM KISHAN VERMA,KOTA vs. PCIT (CENTRAL), JAIPUR

In the result appeal of the assessee in the ITA No

ITA 218/JPR/2022[2013-14]Status: DisposedITAT Jaipur25 Nov 2022AY 2013-14
For Appellant: ShriMahendraGargieya (Adv.)&For Respondent: ShriJames Kurian (CIT)
Section 143(3)Section 263

Transfer Pricing Officer, as the case may be,] is erroneous in so far as it is prejudicial to the interests of the revenue, he may, after giving the assessee an opportunity of being heard and after making or causing to be made such inquiry as he deems necessary, pass such order thereon as the circumstances of the case justify