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18 results for “transfer pricing”+ Section 234Cclear

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Key Topics

Section 80I30Section 143(3)18Disallowance11Addition to Income10Section 809Deduction9Section 1488Section 115J7Exemption7Section 147

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

5
Section 2505
Section 685

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

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 144B(1)(xvi)(b) of the Act. 2. That on the facts and in the circumstances of the case, the Ld. CIT(Appeals) was not justified and erred in rejecting the appellant’s claim of allowing reliability charge of Rs. 1.5/unit in computing Transfer Price of Power for the purpose of Deduction u/s 80-IA in respect

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 143(3) of the Act on 23.02.2018 by making various disallowances/additions to the returned income of the assessee as under :- - Reduction in claim u/s 80IA on power undertakings on account of transfer pricing adjustment of power (Rs. 2,89,07,63,321/-, - Reduction in claim u/s 80IA on Solid Waste Management System on account of transfer pricing adjustment

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

ITA 498/JPR/2023[2018-19]Status: DisposedITAT Jaipur21 Feb 2024AY 2018-19
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 144B(1)(xvi)(b) of the Act.\n2. That on the facts and in the circumstances of the case, the Ld. \nCIT(Appeals) was not justified and erred in rejecting the appellant’s \nclaim of allowing reliability charge of Rs. 1.5/unit in computing Transfer \nPrice of Power for the purpose of Deduction u/s 80-IA in respect

BHARATPUR ROYAL FAMILY RELIGIOUS & CEREMONIAL TRUST,BHARATPUR vs. CIT(E), JAIPUR

In the result, we upheld the order of the ld PCIT in exercise of his powers u/s 263 in setting aside the order so passed by the AO and the grounds of appeal taken by the assessee are hereby dismissed

ITA 290/JPR/2020[2011-12]Status: DisposedITAT Jaipur13 Jul 2021AY 2011-12
For Appellant: Sh. P. C. Parwal (CA)For Respondent: Sh. Rajendra Singh (CIT)
Section 10Section 12ASection 154Section 24Section 263Section 297

234C of the IT Act. 4.4 The appellant has filed detailed submissions. It is stated that vide a certificate no. 4/26/56-Po11.III of Ministry of Home Affairs, Po11 III Section intimated vide letter dated 12th November, 1958, exemption from income tax was given to the trust. The appellant has stated that AO has failed to appreciate that Section

SHRI LALIT KUMAR KALWAR,SARWAR vs. INCOME TAX OFFICER, AJMER

ITA 379/JPR/2018[2013-14]Status: DisposedITAT Jaipur30 May 2023AY 2013-14

Bench: HON’BLE SHRI SANDEEP GOSAIN (Judicial Member)

For Appellant: Shri Mahendra Gargieya, AdvocateFor Respondent: Ms Monisha Choudhary (Addl.CIT)
Section 142(1)Section 143(2)Section 234ASection 48Section 50CSection 54FSection 54F(1)

234C. 9. That the petitioner may kindly be permitted to raise any additional or alternative grounds at or before the time of hearing. 2. The brief facts of the case are that the assessee was engaged in the trading of Tyres under the name and style M/s. Jai Ambey Tyres. The assessee filed his return of income declaring 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

234C of the Act. 9. That on the facts and circumstances of the case, the CIT(A) erred in not issuing directions for dropping penalty proceedings u/s. 271(1)(c) of the Act. 10. The appellant craves leave to add or to amend the foregoing ground of appeal, if it becomes necessary to do so in the interest of justice

ALOK KUMAR JAIN ,PEARL PLEASURE vs. ACIT CIR-6, JAIPUR, NEW CERNTRAL REVENUE BUILDING, BHAGWAN DASS ROAD, JAIPUR, RAJASTHAN,

ITA 1191/JPR/2024[2016-17]Status: DisposedITAT Jaipur24 Mar 2025AY 2016-17

Bench: Him.

For Appellant: Sh. Prakul Khurana, Adv. &For Respondent: Mrs. Anita Rinesh, JCIT-Sr. DR
Section 10(38)Section 147Section 148Section 250Section 68Section 69A

transfer of long-term capital asset being equity shares of company shall not be form part of total income if securities transaction tax is applicable on such transaction. In the present case, the share in which Appellant was invested were long term capital assets and it is clearly evident from the contract notes that securities transaction tax was charged

YOGESH GINNING MILL, PROP. YOGESH CHAND GUPTA,GOVINDGARH vs. ACIT, ALWAR

In the result, the appeals filed by the assessee are allowed

ITA 1045/JPR/2024[2017-18]Status: DisposedITAT Jaipur12 Dec 2024AY 2017-18

Bench: This Tribunal Which Were Passed By The Commissioner Of Income Tax (Appeal)- 4, Jaipur [ For Short Cit(A) ] Passed On Dates & F For The Assessment Years Mentioned As Tabulated Here In Below, In Turn Those Orders Were Arises Because The Assessee Has Yogesh Ginning Mill Vs. Acit

For Appellant: Shri Paridhi Jain, AdvFor Respondent: Shri Gajendra Singh (Addl.CIT) a
Section 143(2)Section 143(3)Section 145(3)Section 250Section 68

transferred to theAOof theother person on the date ofrecordingofsatisfactionby the commonAO. Since, the Revenue has not producedthesatisfactionnoterecordedby the commonAOin this case, one can only presume thatsatisfactionwasrecordedimmediately prior to the issue of notice under Section 153C of the Act. As per standard practice of the Department the notice u/s 153C is issued immediately after recording of satisfaction. v) Therefore, the whole

YOGESH GINNING MILL, PROP. YOGESH CHAND GUPTA,GOVINDGARH vs. ACIT, CIRCLE I, ALWAR

In the result, the appeals filed by the assessee are allowed

ITA 540/JPR/2024[2018-19]Status: DisposedITAT Jaipur12 Dec 2024AY 2018-19

Bench: This Tribunal Which Were Passed By The Commissioner Of Income Tax (Appeal)- 4, Jaipur [ For Short Cit(A) ] Passed On Dates & F For The Assessment Years Mentioned As Tabulated Here In Below, In Turn Those Orders Were Arises Because The Assessee Has Yogesh Ginning Mill Vs. Acit

For Appellant: Shri Paridhi Jain, AdvFor Respondent: Shri Gajendra Singh (Addl.CIT) a
Section 143(2)Section 143(3)Section 145(3)Section 250Section 68

transferred to theAOof theother person on the date ofrecordingofsatisfactionby the commonAO. Since, the Revenue has not producedthesatisfactionnoterecordedby the commonAOin this case, one can only presume thatsatisfactionwasrecordedimmediately prior to the issue of notice under Section 153C of the Act. As per standard practice of the Department the notice u/s 153C is issued immediately after recording of satisfaction. v) Therefore, the whole

DCIT, JAIPUR vs. AMRAPALI JEWELS PVT. LTD. , JAIPUR

In the result, the appeal filed by the assessee is partly allowed and

ITA 740/JPR/2024[2021]Status: DisposedITAT Jaipur19 Feb 2025

Bench: Him.

For Appellant: Sh. Sanjay Jhanwar, Sr. AdvFor Respondent: Mrs. Alka Gautam, CIT-DR
Section 143(3)Section 145(3)Section 153DSection 251Section 69B

price for Head Office and Panch Batti Stores/location. 16. Under the facts and circumstances of the case and in law, the Ld. CIT(A) is not justified in sustaining the impugned addition on account of alleged unaccounted sale to the extent of Rs. 6,80,05,286/- out of total addition of Rs. 24,95,17,849/- on the basis

INTEGRAL URBAN CO-OPERATIVE BANK LTD.,JAIPUR vs. INCOME TAX OFFICER, WARD-2-1, JAIPUR

In the result, the appeal is partly allowed

ITA 1075/JPR/2018[2012-13]Status: DisposedITAT Jaipur13 May 2019AY 2012-13

Bench: Us. In This Appeal, The Assessee Bank Has Taken The Following Grounds Of Appeal:-

For Appellant: Shri Dilip Shivpuri (Adv.)For Respondent: Shri K.C. Meena (ACIT)
Section 145Section 234ASection 36(1)(viia)Section 36(1)(viii)Section 37(1)

price is higher than the face value, "the premium should be amortized for the remaining period of maturity of the security". From the above it is clear that the premium has to be amortized for the remaining period of maturity of the security. The learned A.R. fairly conceded that details of such premium splitting over the remaining period

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

In the result, the appeal in ITA no

ITA 665/JPR/2023[2009-10]Status: DisposedITAT Jaipur26 Apr 2024AY 2009-10

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:

For Appellant: Shri Amit Kothari (C.A.)For Respondent: Shri Ajay Malik (CIT)
Section 11Section 143(3)Section 234A

transfer of land to them either by tenant or any other person claiming through the tenant, whose tenancy rights have been resumed or surrendered, under the said provision, on such terms and conditions and subject to payment to the Trust of such charges or premium or both, as the case may be, and at such rates as may be prescribed

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

In the result, the appeal in ITA no

ITA 666/JPR/2023[2013-14]Status: DisposedITAT Jaipur26 Apr 2024AY 2013-14

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

For Appellant: Shri Amit Kothari (C.A.)For Respondent: Shri Ajay Malik (CIT)
Section 11Section 143(3)Section 234A

transfer of land to them either by tenant or any other person claiming through the tenant, whose tenancy rights have been resumed or surrendered, under the said provision, on such terms and conditions and subject to payment to the Trust of such charges or premium or both, as the case may be, and at such rates as may be prescribed

DCIT, JAIPUR vs. JADAU JEWELLERS & MFG (P) LTD., JAIPUR

In the result, the appeals filed by the assessee are partly allowed and that of the Revenue are dismissed

ITA 502/JPR/2016[2010-11]Status: DisposedITAT Jaipur28 Feb 2017AY 2010-11
For Appellant: Shri Vijay Goyal and Shri Gulshan Agarwal, CAFor Respondent: Shri R.A. Verma, Addl.CIT - DR
Section 142Section 144Section 153A

price vary day to day on the basis of market rate of bullion, therefore the few instances of the few days cannot be compared with the sale of whole year and the comparison can only be made for the sample collected for whole year and also for all items. From the perusal of chart of instance (PB page

SUNIL KUMAR AGARWAL,JAIPUR vs. ACIT, CEN. CIR-2, JAIPUR

In the result the appeal of the assessee in ITA no

ITA 513/JPR/2025[2016-17]Status: DisposedITAT Jaipur14 Oct 2025AY 2016-17
For Appellant: Shri S. L. Poddar, AdvFor Respondent: Mrs. Anita Rinesh, JCIT, Sr-DR
Section 132Section 139Section 153ASection 234B

Section 68 Case pertains to Asst. Year 1966-67 Decision in favour of: Assessee Cash credits—Addition under s. 68—ITO can make addition under s. 68 as income from undisclosed sources, simultaneously with addition to trading results— However, assessee can claim the addition under s. 68 as covered by intangible additions to trading results—In the present case

BLUEPRINT INFRAHOMES LLP,JAIPUR vs. ADIT CPC BENGALURU OR ITO WARD 6(1) JAIPUR, JAIPUR

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 68/JPR/2023[2021-22]Status: DisposedITAT Jaipur30 Aug 2023AY 2021-22

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

For Appellant: Shri Shrawan Kumar Gupta (Adv.)For Respondent: Smt. Monisha Choudhary (Addl. CIT)
Section 143(1)Section 234ASection 801BSection 80I

234C.. The appellant totally denies it liability of charging of any such interest. The interest, so charged, being contrary to the provisions of law and facts, may kindly be deleted in full. 4.Ground4. The appellant prays your honour indulgences to add. amend or alter of or any of the grounds of the appeal on or before the date