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153 results for “transfer pricing”+ Section 250(6)clear

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Key Topics

Addition to Income86Section 143(3)70Section 6853Section 153A50Section 14835Section 25032Section 69C27Section 133A26Section 10(38)21

VAIBHAV GLOBAL LIMITED,JAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, JAIPUR, JAIPUR

In the result, the appeal of the assessee is allowed and disposed off in light of aforesaid directions

ITA 97/JPR/2021[2016-17]Status: DisposedITAT Jaipur07 Feb 2022AY 2016-17

Bench: Shri Sandeep Gosain & Shri Vikram Singh Yadavvaibhav Global Limited, Deputy Commissioner Of बनाम Jaipur. Income Tax, Central Circle-4, Jaipur. "थायी लेखा सं./Pan No: Aaacv4679F

For Appellant: Shri Vijay Mehta, C.AFor Respondent: Shri B.K. Gupta, Pr.CIT
Section 143(3)Section 144C(13)Section 234ASection 92CSection 92D

section 144C(13) of the Act was passed by the Assessing officer on 13.11.2019 wherein adjustment on account of transfer pricing as proposed by the Transfer Pricing Officer was made and the assessed income was determined at Rs.57,36,47,429/-. 3. Against the draft assessment order, the assessee filed its objections before the Dispute Resolution Panel and after considering

Showing 1–20 of 153 · Page 1 of 8

...
Disallowance21
Search & Seizure18
Business Income17

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

WORSHIP INFRAPROJECTS PRIVATE LIMITED,JAIPUR vs. DCIT, CEIRCLE-2, JAIPUR

In the result of the appeal of the assessee is allowed

ITA 394/JPR/2022[2014-15]Status: DisposedITAT Jaipur22 May 2023AY 2014-15

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Vijay Goyal, CA &For Respondent: Shri A.K. Bhardwaj, CIT &
Section 92C

250 of the IT Act for the assessment year 2014-15. The grounds raised by the assessee as well as revenue are as under :- 1. That the ld. AO grossly erred on law and facts in referring the matter with TPO by invoking section 92CA of I.T. Act, 1961 and the ld. CIT (A) also erred in not considering

DEPUTY COMMISSIONER OF INCOME TAX, JAIPUR vs. M/S WORSHIP INFRAPROJECTS PVT LTD(PREVIOUSLY KNOWN AS OM METALS SPML INFRAPROJECTS PVT LTD), JAIPUR

In the result of the appeal of the assessee is allowed

ITA 431/JPR/2022[2014-15]Status: DisposedITAT Jaipur22 May 2023AY 2014-15

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Vijay Goyal, CA &For Respondent: Shri A.K. Bhardwaj, CIT &
Section 92C

250 of the IT Act for the assessment year 2014-15. The grounds raised by the assessee as well as revenue are as under :- 1. That the ld. AO grossly erred on law and facts in referring the matter with TPO by invoking section 92CA of I.T. Act, 1961 and the ld. CIT (A) also erred in not considering

VAIBHAV GLOBAL LIMITED,JAIPUR vs. DCIT, CC-4, JAIPUR

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

ITA 1144/JPR/2024[2020-21]Status: DisposedITAT Jaipur30 Jun 2025AY 2020-21
For Appellant: Shri Vinod Kumar Gupta, AdvFor Respondent: Shri Rajesh Ojha, CIT-DR
Section 115JSection 115QSection 143(3)Section 144C(5)Section 36(1)(va)

pricing, discounts, credit worthiness, number of years of relationship. Etc. and accordingly, it would not be feasible to consider a uniform credit period without taking into consideration the specific factors for the particular trade. - 2. In the instant case, the appellant has granted a credit period of up to 180 days to both AEs as well as third parties

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

6,96,12,33,525/- under provisions of section 115JB of the Act. The case was taken up for scrutiny. In view of specified domestic transactions, a Shree Cement Limited, Beawar. reference under section 92CA was made to the Transfer Pricing Officer (TPO). The TPO passed an order under section 92CA(3) dated 25.10.2017 of the Act proposing various upward

VAIBHAV GLOBAL LIMITED,JAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-5, JAIPUR

In the result, the penalty is directed to be deleted and appeal of the assessee is allowed

ITA 731/JPR/2018[2010-11]Status: DisposedITAT Jaipur19 Dec 2018AY 2010-11
For Appellant: Shri Vijay Mehta (C.A.) &For Respondent: Smt. Roli Agarwal (CIT)
Section 143(3)Section 271(1)(c)Section 92C

6. Now coming to the penalty proceedings, the same were initiated by the Assessing Officer while completing the assessment proceedings U/s 143(3) r.w.s. 144C of the I.T. Act wherein the AO has made transfer pricing adjustment/addition of Rs. 18,68,02,513/-and has Vaibhav Global Ltd. vs. ACIT stated that penalty U/s 271(1)(c) is leviable

VAIBHAV GLOBAL LIMITED,JAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-5, JAIPUR

In the result, the penalty is directed to be deleted and appeal of the assessee is allowed

ITA 730/JPR/2018[2009-10]Status: DisposedITAT Jaipur19 Dec 2018AY 2009-10
For Appellant: Shri Vijay Mehta (C.A.) &For Respondent: Smt. Roli Agarwal (CIT)
Section 143(3)Section 271(1)(c)Section 92C

6. Now coming to the penalty proceedings, the same were initiated by the Assessing Officer while completing the assessment proceedings U/s 143(3) r.w.s. 144C of the I.T. Act wherein the AO has made transfer pricing adjustment/addition of Rs. 18,68,02,513/-and has Vaibhav Global Ltd. vs. ACIT stated that penalty U/s 271(1)(c) is leviable

ACIT, CENTRAL CIRCLE, AJMER, AJMER vs. WONDER CEMENT LTD, MADANGANJ-KISHANGARH

In the result Ground No. 2 raised by the assessee is allowed

ITA 1543/JPR/2024[2020-21]Status: DisposedITAT Jaipur21 Feb 2025AY 2020-21

Bench: Shri Gagan Goyal & Shri Narinder Kumar

For Appellant: Mr. C. M. Agarwal, CA, Ld. ARFor Respondent: Mr. Sanjay Dhariwal, CIT, Ld. DR
Section 115JSection 143(3)Section 250Section 801A(8)Section 80A(6)Section 92Section 92CSection 92F

250 of the Income Tax Act, 1961 (in short ‘the Act’).The revenue has raised the following grounds of appeal:- 1.Ground-(i) Whether on the facts and in circumstances of the case, the Hon'ble CIT(A) (by referring decision of ITAT) is right in holding that the TPO determining the Transfer Pricing cannot take another suitable methodology with cogent

JAGDISH CHANDRA SUWALKA,JAIPUR vs. JCIT, RANGE-7, JAIPUR

In the result, appeal of the assessee is allowed

ITA 376/JPR/2022[2015-16]Status: DisposedITAT Jaipur28 Apr 2023AY 2015-16

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

For Appellant: Shri Mahendra Gargieya, AdvocateFor Respondent: Ms Monisha Choudhary (Addl. CIT)
Section 143(1)Section 143(2)Section 143(3)Section 269SSection 271DSection 44A

250(6) of the Act. Therefore, in the substantial interest of justice, we set aside the ex parte order of the ld. CIT(A) and restore the matter back to the file of the ld. CIT(A) for deciding the issue afresh on merits. The assessee is also directed to appear before the ld. CIT(A) within two months from

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

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

ITA 508/JPR/2025[2020-21]Status: DisposedITAT Jaipur12 Nov 2025AY 2020-21

Bench: This Tribunal Are As Under :

For Appellant: Sh. Mukesh Soni, AdvFor Respondent: Mrs. Anita Rinesh, JCIT-DR
Section 144CSection 153CSection 153DSection 250

250 of the Income Tax Act, 1961 [“the Act”] is perverse, arbitrary and bad in law. 2. Under the facts and circumstances of the case and in law, the Ld. CIT (A) is not justified in observing and giving impugned finding on merits of the case while dismissing the appeal at threshold on the grounds of delay. 3. Under

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

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

ITA 507/JPR/2025[A.Y. 2018-19]Status: DisposedITAT Jaipur12 Nov 2025

Bench: This Tribunal Are As Under :

For Appellant: Sh. Mukesh Soni, AdvFor Respondent: Mrs. Anita Rinesh, JCIT-DR
Section 144CSection 153CSection 153DSection 250

250 of the Income Tax Act, 1961 [“the Act”] is perverse, arbitrary and bad in law. 2. Under the facts and circumstances of the case and in law, the Ld. CIT (A) is not justified in observing and giving impugned finding on merits of the case while dismissing the appeal at threshold on the grounds of delay. 3. Under

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

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

ITA 505/JPR/2025[2015-16]Status: DisposedITAT Jaipur12 Nov 2025AY 2015-16

Bench: This Tribunal Are As Under :

For Appellant: Sh. Mukesh Soni, AdvFor Respondent: Mrs. Anita Rinesh, JCIT-DR
Section 144CSection 153CSection 153DSection 250

250 of the Income Tax Act, 1961 [“the Act”] is perverse, arbitrary and bad in law. 2. Under the facts and circumstances of the case and in law, the Ld. CIT (A) is not justified in observing and giving impugned finding on merits of the case while dismissing the appeal at threshold on the grounds of delay. 3. Under

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

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

ITA 506/JPR/2025[2016-17]Status: DisposedITAT Jaipur12 Nov 2025AY 2016-17

Bench: This Tribunal Are As Under :

For Appellant: Sh. Mukesh Soni, AdvFor Respondent: Mrs. Anita Rinesh, JCIT-DR
Section 144CSection 153CSection 153DSection 250

250 of the Income Tax Act, 1961 [“the Act”] is perverse, arbitrary and bad in law. 2. Under the facts and circumstances of the case and in law, the Ld. CIT (A) is not justified in observing and giving impugned finding on merits of the case while dismissing the appeal at threshold on the grounds of delay. 3. Under

GUNMALA JAIN,AJMER vs. INCOME TAX OFFICER, WD-2(2), AJMER, AJMER

Appeal of the assessee is dismissed

ITA 1262/JPR/2025[2019-20]Status: DisposedITAT Jaipur22 Dec 2025AY 2019-20

Bench: SMT. ANNAPURNA GUPTA, AM आयकर अपील सं. / ITA No.1262/JPR/2025 निर्धारणवर्ष / AssessmentYears :2019-20 Gunmala Jain, बनाम 28 Abhi Lash Nikunj, Kalyan Vs. Income Tax Officer, Ward-2(2) Colony, Ajmer Road Kekri, Ajmer स्थायीलेखा सं. / जीआईआर सं./ PAN/GIR No.: ABRPJ 4764E Ajmer अपीलार्थी / Appellant प्रत्यर्थी / Respondent निर्धारिती की ओर से/Assesseeby :Sh. Sunil Porwal, CA (Thr.V.C.) राजस्व की ओर से / Revenue by : Sh. Gautam Singh Choudhary (Addl. CIT) सुनवाई की तारीख / Date of Hearing : 18/1

For Appellant: Sh. Sunil Porwal, CA (Thr.V.C.)For Respondent: Sh. Gautam Singh Choudhary
Section 148Section 250Section 270ASection 80G

250 of the Income Tax Act, 1961, (hereinafter referred to as “Act”), confirming the levy of penalty under Section 270A of the Act. 2. The grounds raised by the assessee read as under:- 2 Gunmala Jain 1. The ld. CIT(A) confirming the penalty u/sec. 270A at Rs.33,280/- (200%) is bad in law. Penalty levied on suo motto disallowance

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

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

ITA 509/JPR/2025[2021-22]Status: DisposedITAT Jaipur12 Nov 2025AY 2021-22
For Appellant: Sh. Mukesh Soni, AdvFor Respondent: Mrs. Anita Rinesh, JCIT-DR
Section 144CSection 153CSection 153DSection 250

250 of the Income Tax Act, 1961 [“the\nAct\"] is perverse, arbitrary and bad in law.\n2. Under the facts and circumstances of the case and in law, the Ld. CIT (A)\nis not justified in observing and giving impugned finding on merits of the case\nwhile dismissing the appeal at threshold on the grounds of delay.\n3. Under

DEVIKA BUILDESTATE PRIVATE LIMITED,JAIPUR vs. INCOME TAX OFFICER, JAIPUR

In the result, the appeal of the assessee is allowed

ITA 525/JPR/2025[2012-13]Status: DisposedITAT Jaipur21 Jul 2025AY 2012-13

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

For Appellant: Sh. Vinod Kumar Gupta, CAFor Respondent: Sh. Gautam Singh Choudhary, Addl. CIT
Section 133(6)Section 142(1)Section 143(2)Section 143(3)Section 271(1)(c)

250 dated 28.01.2025) “In this ground the appellant asserts that the professional fees were legitimate expenses for land development services. However, the following points rebut this claim: 1. The services rendered were not clearly defined or corroborated with tangible evidences, despite opportunities given by the concerned AO. 2. Notices under Section 133(6) to the recipients were returned undelivered, further

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

In the result, the appeal of the assessee is allowed

ITA 597/JPR/2024[2019-20]Status: DisposedITAT Jaipur01 Jan 2025AY 2019-20

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

For Appellant: Shri R.S. Poonia, CAFor Respondent: Ms. Alka Gautam, CIT-DR
Section 127Section 133ASection 139Section 142(1)Section 143(2)Section 143(3)Section 263

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

DCIT, JAIPUR vs. JAIPUR RUGS COMPANY (P) LTD., JAIPUR

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

ITA 1084/JPR/2016[2011-12]Status: DisposedITAT Jaipur23 Apr 2018AY 2011-12
For Appellant: Shri Rajeev Sogani (CA)For Respondent: Smt. Seema Meena (JCIT) fu/kZkfjrh dh vksj ls@
Section 143(1)Section 143(2)Section 144CSection 92CSection 92C(2)

250, Mansarovar Industrial Area, Jaipur LFkk;h ys[kk la-@thvkbZvkj la-@PAN/GIR No.: AABCJ6934C vihykFkhZ@Appellant izR;FkhZ@Respondent jktLo dh vksj ls@ Revenue by : Smt. Seema Meena (JCIT) fu/kZkfjrh dh vksj ls@ Assessee by : Shri Rajeev Sogani (CA) lquokbZ dh rkjh[k@ Date of Hearing : 12/04/2018 mn?kks"k.kk dh rkjh[k@Date of Pronouncement : 24/04/2018 vkns