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41 results for “transfer pricing”+ Section 253clear

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Key Topics

Section 143(3)35Addition to Income32Section 80I31Section 6826Section 14320Section 8020Section 26315Section 145(3)15Section 153A12

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

Showing 1–20 of 41 · Page 1 of 3

Unexplained Cash Credit12
Disallowance10
Deduction8
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, 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

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 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

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

transfer price) for determining the quantum of deduction under section 80IA already calimed in the original return of income. The judgment of Hon’ble Supreme Court in case ofWipro, is applicable to cases wherein “new claim” is filed by way of revised return for claiming “exemption” under section 10B of the IT Act. In the present case, there

SHREE CEMENT LIMITED,BANGUR NAGAR vs. ACIT, CENTRAL CIRCLE, AJMER

In the result, the appeal of the assessee - appellant in ITA No

ITA 1517/JPR/2024[2019-2020]Status: DisposedITAT Jaipur24 Jun 2025AY 2019-2020

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Shri Dilip B. Desai, FCAFor Respondent: Shri Arvind Kumar, CIT-DR
Section 115JSection 143(1)Section 254Section 36(1)(va)Section 80Section 801A

sections (4) to (10) and as increased by the applicable surcharge, for the purposes of the Union, calculated in the manner provided therein, shall be further increased by an additional surcharge, for the purposes of the Union, to be called the “Health and Education Cess on income-tax”, calculated at the rate of four per cent of such income

HARIRAM HOSPITAL,ALWAR vs. PCIT, ALWAR

In the result, the appeal of the assessee is allowed

ITA 1535/JPR/2024[2019-20]Status: DisposedITAT Jaipur17 Apr 2025AY 2019-20

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, AM आयकरअपीलसं./ITA No. 1535/JPR/2024 निर्धारणवर्ष / Assessment Year: 2019-20 Hariram Hospital Bye Pass Road Hariram Hospital Bhiwadi, Alwar – 310 019 (Raj) बनाम Vs. The Pr.CIT (Central) Jaipur प्रत्यर्थी / Respondent स्थायीलेखा सं. / जीआईआरसं./PAN/GIR No.: AAFFH 5746 M अपीलार्थी / Appellant निर्धारिती की ओरसे / Assesseeby : Shri Himanshu Goyal, CA राजस्व की ओरसे /Revenue by: Mrs. Alka Gautam, CIT-DR सुनवाई की तारीख / Da

For Appellant: Shri Himanshu Goyal, CAFor Respondent: Mrs. Alka Gautam, CIT-DR
Section 143(3)Section 263

253 of the Act contemplates that the Tribunal may admit an appeal or permit filing of memorandum of cross-objections after expiry of relevant period, if it is satisfied that there was a sufficient cause for not presenting it within that period. This expression “sufficient cause” employed in the section has also been used identically in sub- section

ANITA LODHA,JAIPUR vs. PCIT - 1, JAIPUR, JAIPUR

19. In view of the above findings, this appeal filed by the assessee deserves to be allowed

ITA 46/JPR/2024[2015-16]Status: DisposedITAT Jaipur17 Apr 2024AY 2015-16
For Appellant: Shri Mukesh Khandelwal (Adv.)For Respondent: Shri Anoop Singh (Addl.CIT)
Section 143(3)Section 144Section 147Section 151Section 253Section 263

253 of the Income Tax Act, 1961 (hereinafter referred to as “ the Act”). 2 Anita Lodha vs. PCIT 2. The assessee-appellant has challenged the order dated 4.01.2024 passed by Learned PCIT, Jaipur-1, while exercising powers of revision under section 263 of the Act. 3. Section 263 of the Act empowers PCIT, besides others specified therein, to call

JUHI BHANDARI, JAIPUR,JAIPUR vs. DCIT CIRCLE (INTL TAX), JAIPUR, JAIPUR

In the result, both appeals of the assessee are allowed

ITA 234/JPR/2025[2015-16]Status: DisposedITAT Jaipur13 Aug 2025AY 2015-16
For Appellant: Shri Siddharth Ranka, AdvFor Respondent: Smt. Runi Pal, CIT (through VC)
Section 144C(5)Section 153CSection 69

transfer\npricing orders wherein downward adjustments were made to the price\npaid for the equipment imported by the AE. The Assessee had filed an\nappeal to this Tribunal against the appellate order for Assessment Year\n2013-14 (arising from the assessment under Section 143(3) and the TPO\norder). This appeal was disposed in RKM POWERGEN PRIVATE\nLIMITED

AJAY BAKLIWAL,KOTA vs. ACIT, CENTRAL CIRCLE, KOTA, KOTA

ITA 1276/JPR/2024[2014-15]Status: DisposedITAT Jaipur11 Apr 2025AY 2014-15
For Appellant: Shri Rajendra SisodiaFor Respondent: Shri Rajesh Ojha, CIT-DR
Section 132Section 132(1)Section 132(4)Section 139Section 143(3)Section 153ASection 250

253 ITR 454 (Guj.): Interpretation of \ndocuments - Documents must be read as a whole. It is a well settled canon of \ninterpretation that a document has to be read as a whole" it is not permissible to \naccept a part and ignore the rest of the document.\nHissaria Brothers V/s ACIT (Jpr.): 22 Tax World 684 - Held that the seized

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

transferred for obtaining liquor license and after the close of tendering process the assessee returned back the demand drafts to unsuccessful bidders. The returned DDs have been deposited in the same bank account from which they were issued earlier. Thus, from these facts it is evidently clear that the nature of the amount received in the hands of the assessee

ASSTT. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, KOTA vs. BANAS MINERALS PRIVATE LIMITED, JHALAWAR

In the result the appeal of the revenue in ITA no

ITA 240/JPR/2024[2018-19]Status: DisposedITAT Jaipur03 Dec 2024AY 2018-19

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

For Appellant: Sh. Rajendra Jain (Adv.) (V.C)For Respondent: Smt. Alka Gautam, CIT-DR (V.H)
Section 153ASection 250Section 69B

253 of the Act for filing of appeal in the ITAT against the order of Ld. CIT(A)-2, Udaipur is as under:- (2) The [Principal Commissioner or] Commissioner may, if he objects to any order passed by a [Deputy Commissioner (Appeals] [before the 1ª day of October, 1998] [or as the case may be, a commissioner (Appeals)] under [section

ASSISTANT COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE, KOTA vs. BANAS BUILDERS AND DEVELOPERS LLP, JHALAWAR

In the result the appeal of the revenue in ITA no

ITA 269/JPR/2024[2018-19]Status: DisposedITAT Jaipur03 Dec 2024AY 2018-19

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

For Appellant: Sh. Rajendra Jain (Adv.) (V.C)For Respondent: Smt. Alka Gautam, CIT-DR (V.H)
Section 153ASection 250Section 69B

253 of the Act for filing of appeal in the ITAT against the order of Ld. CIT(A)-2, Udaipur is as under:- (2) The [Principal Commissioner or] Commissioner may, if he objects to any order passed by a [Deputy Commissioner (Appeals] [before the 1ª day of October, 1998] [or as the case may be, a commissioner (Appeals)] under [section

ACIT, CENTRAL CIRCLE, KOTA vs. BANAS MINERALS PRIVATE LIMITED, JHALAWAR

In the result the appeal of the revenue in ITA no

ITA 239/JPR/2024[2013-14]Status: DisposedITAT Jaipur03 Dec 2024AY 2013-14

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

For Appellant: Sh. Rajendra Jain (Adv.) (V.C)For Respondent: Smt. Alka Gautam, CIT-DR (V.H)
Section 153ASection 250Section 69B

253 of the Act for filing of appeal in the ITAT against the order of Ld. CIT(A)-2, Udaipur is as under:- (2) The [Principal Commissioner or] Commissioner may, if he objects to any order passed by a [Deputy Commissioner (Appeals] [before the 1ª day of October, 1998] [or as the case may be, a commissioner (Appeals)] under [section

PINCITY JEWLHOUSE PVT. LTD.,JAIPUR vs. PCIT, CC, JAIPUR, JAIPUR

In the result, the appeal of the assessee is allowed

ITA 63/JPR/2021[2015-16]Status: DisposedITAT Jaipur07 Mar 2024AY 2015-16

Bench: the date of hearing." 3. At the outset of hearing, the Bench observed that there is delay of 58 days in filing of the present appeal by the assessee for which the Id. AR of 3

For Appellant: Sh. Siddharth Ranka, Adv. &For Respondent: Sh. Ajey Malik, CIT
Section 10ASection 147Section 253(5)Section 263Section 5

253(5) of the I.T. Act, 1961 read with section 5 of Limitation Act in filing of appeal Hon'ble Sir(s), The humble assessee appellant applicant respectfully prays for the condonation of delay in the filling of Appeal for the following reason: 1. That the Id. PCIT (Central), Jaipur passed his order on 17.03.2021 which was served upon

HOLIDAY TRIANGLE TRAVEL PRIVATE LIMITED,GURGAON vs. INCOME TAX OFFICER, JAIPUR

In the result, appeal of the assessee is allowed

ITA 67/JPR/2024[2014-15]Status: DisposedITAT Jaipur20 Jan 2025AY 2014-15

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI GAGAN GOYAL (Accountant Member)

For Appellant: Shri Dilip Shivpuri, Advocate &For Respondent: Shri Gautam Singh Choudhary, JCIT
Section 142(1)Section 143(2)Section 250Section 56(2)(viib)

253/- per share. In total share premium of Rs. 52,89,920/- was received by the assessee during the year under consideration. We note that the Ld AO doubted on such premium by stating that the assessee Company was a continuous loss making company and hence no prudent person would invest in a company with poor financial results and that

RAM NIWAS YADAV,SHAHPURA vs. INCOME TAX OFFICER BEHROR, BEHROR

In the result, the appeal filed by the assessee is allowed for statistical

ITA 275/JPR/2025[2010-11]Status: DisposedITAT Jaipur08 May 2025AY 2010-11

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Sh. Jaideep Malik, AdvFor Respondent: Sh. Gautam Singh Choudhary, JCIT
Section 144Section 234ASection 271(1)(b)Section 44A

253 ITR 798 (SC) (v) Collector, Land & Acquisition v/s Mst. Katiji & Others (1987) 167 ITR 471 (SC) has advocated for a very liberal approach while considering a case for condonation of delay. The following observations of the Hon'ble Court are notable: The legislature has conferred the power to condone delay by enacting section 5 of the Limitation

RAJRAJESHWARI GUPTA ,KOTA vs. ITO , WARD 1(1),KOTA, KOTA

In the result, the appeal of the assessee is allowed with no orders as to costs

ITA 245/JPR/2024[2012-13]Status: DisposedITAT Jaipur07 Aug 2024AY 2012-13

Bench: Hon’ble SHRI SANDEEP GOSAIN (Judicial Member)

For Appellant: Shri Rajendra Sisodia AdvFor Respondent: Shri Rajesh Kumar Meena, Addl. CIT-DR
Section 10(38)Section 143(3)Section 148Section 68Section 69C

transferred, they were still lying in the name of assessee much after the sale to M/s S.K. Sharma & Co. (The impugned shares ceased to exist in the demat account of the assessee post sale) The only positive aspect was the receipt of sale consideration through cheques. It was under these circumstances that the Hon’ble Tribunal made the observations quoted

M/S DEEPS SPECIAL STEELS LIMITED,LUDHIANA vs. DCIT, CIRCLE-1, ALWAR

ITA 1016/JPR/2024[2015-16]Status: DisposedITAT Jaipur28 Aug 2025AY 2015-16

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

For Appellant: Shri Pankaj Bhalla, C.AFor Respondent: Shri Rajendra Ojha, CIT
Section 115JSection 142(1)Section 143(1)Section 50C

section 50C were not attracted in the case of lease hold property, and the assessee was found to have taken said land on lease of 99 years, and as such, it was not a capital asset. Sale of shares of KAPPAC PHARMA 9. Coming to the only issue of sale of KAPPAC Pharma, argued before us, during the year under