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64 results for “transfer pricing”+ Section 253(2)clear

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Key Topics

Addition to Income55Section 143(3)54Section 153A36Section 133A24Section 6823Section 13222Section 145(3)18Section 26318Section 14317

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)

price u/s 56(2)(viib) read with rule 11UA(2), following valuation certificates were submitted vide submission dated 13.05.2019 :- S. No. Date of Certificate Name of Valuer 1 18.03.2016 PC Modi & Co., Chartered Accountants 2 08.10.2016 PC Modi & Co., Chartered Accountants 3 31.10.2016 PC Modi & Co., Chartered Accountants 4 14.02.2017 PC Modi & Co., Chartered Accountants iii. & iv.c The income

PRADEEP VATRANA,ALWAR vs. DCIT, ALWAR

Showing 1–20 of 64 · Page 1 of 4

Survey u/s 133A12
Disallowance12
Unexplained Cash Credit11

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

ITA 930/JPR/2016[2012-13]Status: DisposedITAT Jaipur27 Feb 2018AY 2012-13
For Appellant: Shri P.C. Parwal (CA)For Respondent: Shri P. P. Meena (JCIT)
Section 54

253/- as business income. In appeal, the Ld. CIT(A) vide order dated 18.11.2014 after considering the facts of the case and also the various case laws including the decision of Hon’ble Rajasthan High Court directed the AO to assess the income from sale of these plots under the head “Income from Capital Gains”. The appeal of the department

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

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

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

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

DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-3, JAIPUR vs. KARNANI SOLVEX PRIVATE LIMITED, JAIPUR

In the result, the appeals of the revenue in ITA No

ITA 480/JPR/2025[2014-15]Status: DisposedITAT Jaipur13 Oct 2025AY 2014-15
For Appellant: Shri Deepak Sharma, CAFor Respondent: MS. Alka Gautam, CIT
Section 132(4)Section 153ASection 68

transferred via cheques or bank transfers, ensuring a transparent\naudit trail. Importantly, there were no outstanding balances associated\nwith these transactions at any point, indicating that loans were duly\nrepaid in subsequent years. This factor is pivotal in establishing the\ngenuneness of the transactions, as it reflects a legitimate business\npractice rather than an attempt to camouflage undisclosed income

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

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

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

ITA 1277/JPR/2024[2015-16]Status: DisposedITAT Jaipur11 Apr 2025AY 2015-16
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

section 132 of the Income Tax act together. The documents related to dissolution of JV of both of them were found from the premises of both the persons. Both of them accepted that the transaction in question was not loan but an accommodation entry against the settlement of dispute. In fact, some of the amounts as per seized paper

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

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

ASSISTANT COMMISSIONER OF INCOME TAX, AJMER vs. AJMER VIDHYUT VITRAN NIGAM LTD., AJMER

In the result, the appeals filed by the Revenue are dismissed

ITA 935/JPR/2017[2009-10]Status: DisposedITAT Jaipur07 Feb 2018AY 2009-10
For Appellant: Shri Subhash Porwal (C.A.)For Respondent: Shri Varinder Mehta (CIT)
Section 271(1)(c)Section 32

transfer of the asset and will not be a wobbling or fluctuating one as suggested by counsel for the assessee. . ." 14. Thus in view of Explanation 6 the written down value of the holding company is required to be taken into consideration. 15. Learned counsel for the assessee submitted that the difference between the WDV and the price received

ASSISTANT COMMISSIONER OF INCOME TAX, AJMER vs. M/S. AJMER VIDHYUT VITRAN NIGAM LTD., AJMER

In the result, the appeals filed by the Revenue are dismissed

ITA 937/JPR/2017[2011-12]Status: DisposedITAT Jaipur07 Feb 2018AY 2011-12
For Appellant: Shri Subhash Porwal (C.A.)For Respondent: Shri Varinder Mehta (CIT)
Section 271(1)(c)Section 32

transfer of the asset and will not be a wobbling or fluctuating one as suggested by counsel for the assessee. . ." 14. Thus in view of Explanation 6 the written down value of the holding company is required to be taken into consideration. 15. Learned counsel for the assessee submitted that the difference between the WDV and the price received

ASSISTANT COMMISSIONER OF INCOME TAX, AJMER vs. M/S. AJMER VIDHYUT VITRAN NIGAM LTD., AJMER

In the result, the appeals filed by the Revenue are dismissed

ITA 890/JPR/2017[2007-08]Status: DisposedITAT Jaipur07 Feb 2018AY 2007-08
For Appellant: Shri Subhash Porwal (C.A.)For Respondent: Shri Varinder Mehta (CIT)
Section 271(1)(c)Section 32

transfer of the asset and will not be a wobbling or fluctuating one as suggested by counsel for the assessee. . ." 14. Thus in view of Explanation 6 the written down value of the holding company is required to be taken into consideration. 15. Learned counsel for the assessee submitted that the difference between the WDV and the price received

ASSISTANT COMMISSIONER OF INCOME TAX, AJMER vs. M/S. AJMER VIDHYUT VITRAN NIGAM LTD., AJMER

In the result, the appeals filed by the Revenue are dismissed

ITA 933/JPR/2017[2004-05]Status: DisposedITAT Jaipur07 Feb 2018AY 2004-05
For Appellant: Shri Subhash Porwal (C.A.)For Respondent: Shri Varinder Mehta (CIT)
Section 271(1)(c)Section 32

transfer of the asset and will not be a wobbling or fluctuating one as suggested by counsel for the assessee. . ." 14. Thus in view of Explanation 6 the written down value of the holding company is required to be taken into consideration. 15. Learned counsel for the assessee submitted that the difference between the WDV and the price received

ASSISTANT COMMISSIONER OF INCOME TAX, AJMER vs. M/S. AJMER VIDHYUT VITRAN NIGAM LTD., AJMER

In the result, the appeals filed by the Revenue are dismissed

ITA 934/JPR/2017[2005-06]Status: DisposedITAT Jaipur07 Feb 2018AY 2005-06
For Appellant: Shri Subhash Porwal (C.A.)For Respondent: Shri Varinder Mehta (CIT)
Section 271(1)(c)Section 32

transfer of the asset and will not be a wobbling or fluctuating one as suggested by counsel for the assessee. . ." 14. Thus in view of Explanation 6 the written down value of the holding company is required to be taken into consideration. 15. Learned counsel for the assessee submitted that the difference between the WDV and the price received

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

SHRI BABU LAL DATA,ALWAR vs. DCIT, CENTRAL CIRCLE, ALWAR

In the result, appeal of the revenue is dismissed

ITA 1223/JPR/2019[2016-17]Status: DisposedITAT Jaipur05 May 2022AY 2016-17
For Appellant: Sh. P. C. Parwal, CAFor Respondent: S. Naiyer Ali Najmi, CIT
Section 127Section 132Section 139Section 153A

253 ITR 454 (Gnj), Mehta Parikh & Co vs CIT (1956) 30 TR 181 (SC) and Chander Mohan Mehta vs. Asstt. CIT (lm) (1999) 65 TTJ (Pune) 327 (1999) 71 TD 245 (Pune) applied. First thing the AO has to prove is that it is the investment of the assessec. In other words, the ownership of the investment must be proved