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

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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

2) and 10B(3) of the Income Tax Rules, 1962.” 30.12. The ld. A/R of the assessee also submitted that the rates at which power is purchased by distribution companies from generation companies are the rates charged by generation companies to middlemen (i.e. B2B business models) which are governed by altogether different level of market and are therefore not comparable

SHREE CEMENT LIMITED,BEAWAR vs. NATIONAL FACELESS ASSESSMENT CENTRE, DELHI

Showing 1–20 of 41 · Page 1 of 3

Unexplained Cash Credit12
Disallowance10
Deduction8

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

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

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

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

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

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

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

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 JITENDRA KUMAR AGARWAL,JAIPUR vs. DCIT, CENTRAL CIRCLE-2, JAIPUR

In the result, based on the discussion so recorded here in above both

ITA 111/JPR/2020[2016-17]Status: DisposedITAT Jaipur07 Jun 2023AY 2016-17

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

For Appellant: Sh. Manish Agarwal (CA)For Respondent: Sh. Sanjay Dhariwal (CIT) &
Section 132Section 143Section 143(3)Section 145(3)Section 68

2. That the goods received on approval and considered as unaccounted sale should be treated as receipt of goods. 3. That necessary credit for the duplicate/ multiple entries deserve to be allowed. 4. That the credit of additions that have also been made in the case of Shri Chandra Prakash Agrawal (appellant’s father) should be allowed. Shri Jitendra Kumar

SHRI JITENDRA KUMAR AGARWAL,JAIPUR vs. DCIT, CENTRAL CIRCLE-2, JAIPUR

In the result, based on the discussion so recorded here in above both

ITA 110/JPR/2020[2015-16]Status: DisposedITAT Jaipur07 Jun 2023AY 2015-16

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

For Appellant: Sh. Manish Agarwal (CA)For Respondent: Sh. Sanjay Dhariwal (CIT) &
Section 132Section 143Section 143(3)Section 145(3)Section 68

2. That the goods received on approval and considered as unaccounted sale should be treated as receipt of goods. 3. That necessary credit for the duplicate/ multiple entries deserve to be allowed. 4. That the credit of additions that have also been made in the case of Shri Chandra Prakash Agrawal (appellant’s father) should be allowed. Shri Jitendra Kumar

SHRI JITENDRA KUMAR AGARWAL,JAIPUR vs. DCIT, CENTRAL CIRCLE-2, JAIPUR

In the result, based on the discussion so recorded here in above both

ITA 109/JPR/2020[2014-15]Status: DisposedITAT Jaipur07 Jun 2023AY 2014-15

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

For Appellant: Sh. Manish Agarwal (CA)For Respondent: Sh. Sanjay Dhariwal (CIT) &
Section 132Section 143Section 143(3)Section 145(3)Section 68

2. That the goods received on approval and considered as unaccounted sale should be treated as receipt of goods. 3. That necessary credit for the duplicate/ multiple entries deserve to be allowed. 4. That the credit of additions that have also been made in the case of Shri Chandra Prakash Agrawal (appellant’s father) should be allowed. Shri Jitendra Kumar

SHRI JITENDRA KUMAR AGARWAL,JAIPUR vs. DCIT, CENTRAL CIRCLE-2, JAIPUR

In the result, based on the discussion so recorded here in above both

ITA 108/JPR/2020[2013-14]Status: DisposedITAT Jaipur07 Jun 2023AY 2013-14

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

For Appellant: Sh. Manish Agarwal (CA)For Respondent: Sh. Sanjay Dhariwal (CIT) &
Section 132Section 143Section 143(3)Section 145(3)Section 68

2. That the goods received on approval and considered as unaccounted sale should be treated as receipt of goods. 3. That necessary credit for the duplicate/ multiple entries deserve to be allowed. 4. That the credit of additions that have also been made in the case of Shri Chandra Prakash Agrawal (appellant’s father) should be allowed. Shri Jitendra Kumar

SHRI JITENDRA KUMAR AGARWAL,JAIPUR vs. DCIT, CENTRAL CIRCLE-2, JAIPUR

In the result, based on the discussion so recorded here in above both

ITA 106/JPR/2020[2011-12]Status: DisposedITAT Jaipur07 Jun 2023AY 2011-12

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

For Appellant: Sh. Manish Agarwal (CA)For Respondent: Sh. Sanjay Dhariwal (CIT) &
Section 132Section 143Section 143(3)Section 145(3)Section 68

2. That the goods received on approval and considered as unaccounted sale should be treated as receipt of goods. 3. That necessary credit for the duplicate/ multiple entries deserve to be allowed. 4. That the credit of additions that have also been made in the case of Shri Chandra Prakash Agrawal (appellant’s father) should be allowed. Shri Jitendra Kumar

SHRI JITENDRA KUMAR AGARWAL,JAIPUR vs. DCIT, CENTRAL CIRCLE-2, JAIPUR

In the result, based on the discussion so recorded here in above both

ITA 107/JPR/2020[2012-13]Status: DisposedITAT Jaipur07 Jun 2023AY 2012-13

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

For Appellant: Sh. Manish Agarwal (CA)For Respondent: Sh. Sanjay Dhariwal (CIT) &
Section 132Section 143Section 143(3)Section 145(3)Section 68

2. That the goods received on approval and considered as unaccounted sale should be treated as receipt of goods. 3. That necessary credit for the duplicate/ multiple entries deserve to be allowed. 4. That the credit of additions that have also been made in the case of Shri Chandra Prakash Agrawal (appellant’s father) should be allowed. Shri Jitendra Kumar