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64 results for “transfer pricing”+ Section 253(3)clear

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Key Topics

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

M/S VIJAYETA BUILDCON PVT. LTD.,JAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, JAIPUR

In the result, the ground of the assessee’s appeal is allowed

ITA 980/JPR/2018[2007-08]Status: DisposedITAT Jaipur27 Oct 2020AY 2007-08
For Appellant: Sh. S. R. Sharma (CA) &For Respondent: Sh. B. K. Gupta (CIT)
Section 153ASection 253(5)Section 40A(3)

transfer of ownership and management of the assessee company, would be handled by the erstwhile management group. It was further submitted that Sh. Jagdish Narain Khandelwal an employee of the erstwhile management who looks after the income tax matters collected the duly filled Form No. 36 and other papers from the Counsel and he handed over the said papers

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

Showing 1–20 of 64 · Page 1 of 4

Survey u/s 133A12
Disallowance12
Unexplained Cash Credit11
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

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

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 3

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

3,53,826/- Shri Jitendra Kumar Agarwal vs. DCIT 2016-17 59-60 1,84,14,307/- It is submitted that ld. CIT(A) after thorough analysis of such working has granted relief on this issue, appellant prays such action of ld.CIT(A) deserves to be upheld. Issue: Purchases considered as unaccounted sales: It is submitted that

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

3,53,826/- Shri Jitendra Kumar Agarwal vs. DCIT 2016-17 59-60 1,84,14,307/- It is submitted that ld. CIT(A) after thorough analysis of such working has granted relief on this issue, appellant prays such action of ld.CIT(A) deserves to be upheld. Issue: Purchases considered as unaccounted sales: It is submitted that

DCIT, CC-2, JAIPUR vs. SHRI JITENDRA KUMAR AGARWAL, JAIPUR

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

ITA 178/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

3,53,826/- Shri Jitendra Kumar Agarwal vs. DCIT 2016-17 59-60 1,84,14,307/- It is submitted that ld. CIT(A) after thorough analysis of such working has granted relief on this issue, appellant prays such action of ld.CIT(A) deserves to be upheld. Issue: Purchases considered as unaccounted sales: It is submitted that

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

3,53,826/- Shri Jitendra Kumar Agarwal vs. DCIT 2016-17 59-60 1,84,14,307/- It is submitted that ld. CIT(A) after thorough analysis of such working has granted relief on this issue, appellant prays such action of ld.CIT(A) deserves to be upheld. Issue: Purchases considered as unaccounted sales: It is submitted that

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

3,53,826/- Shri Jitendra Kumar Agarwal vs. DCIT 2016-17 59-60 1,84,14,307/- It is submitted that ld. CIT(A) after thorough analysis of such working has granted relief on this issue, appellant prays such action of ld.CIT(A) deserves to be upheld. Issue: Purchases considered as unaccounted sales: It is submitted that

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

3,53,826/- Shri Jitendra Kumar Agarwal vs. DCIT 2016-17 59-60 1,84,14,307/- It is submitted that ld. CIT(A) after thorough analysis of such working has granted relief on this issue, appellant prays such action of ld.CIT(A) deserves to be upheld. Issue: Purchases considered as unaccounted sales: It is submitted that

DCIT, CC-2, JAIPUR vs. SHRI JITENDRA KUMAR AGARWAL, JAIPUR

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

ITA 180/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

3,53,826/- Shri Jitendra Kumar Agarwal vs. DCIT 2016-17 59-60 1,84,14,307/- It is submitted that ld. CIT(A) after thorough analysis of such working has granted relief on this issue, appellant prays such action of ld.CIT(A) deserves to be upheld. Issue: Purchases considered as unaccounted sales: It is submitted that

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

3,53,826/- Shri Jitendra Kumar Agarwal vs. DCIT 2016-17 59-60 1,84,14,307/- It is submitted that ld. CIT(A) after thorough analysis of such working has granted relief on this issue, appellant prays such action of ld.CIT(A) deserves to be upheld. Issue: Purchases considered as unaccounted sales: It is submitted that

DCIT, CC-2, JAIPUR vs. SHRI JITENDRA KUMAR AGARWAL, JAIPUR

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

ITA 179/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

3,53,826/- Shri Jitendra Kumar Agarwal vs. DCIT 2016-17 59-60 1,84,14,307/- It is submitted that ld. CIT(A) after thorough analysis of such working has granted relief on this issue, appellant prays such action of ld.CIT(A) deserves to be upheld. Issue: Purchases considered as unaccounted sales: It is submitted that

RAJASTHAN STATE MINES & MINERALS LTD.,JAIPUR vs. ACIT, JAIPUR

In the result, appeal of the Revenue is partly allowed for statistical purpose

ITA 253/JPR/2015[2007-08]Status: DisposedITAT Jaipur30 May 2017AY 2007-08

transferable. The Normal land can be mortgaged and owner can avail loan on it, whereas in the case of wasting mining land, the assessee can neither mortgage these lands nor can avail loan on it. Therefore, the cost incurred for acquiring these lands is only for extracting the mineral which needs to be amortized over its useful life

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

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

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

PRADEEP VATRANA,ALWAR vs. DCIT, ALWAR

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

DCIT, CC-2, JAIPUR vs. M/S. ROYAL JEWELLERS, JAIPUR

In the result, appeal of the assessee in ITA No

ITA 175/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 143Section 143(3)Section 145(3)

transfer between the firms of the group, which also clearly reflect that these memorandum details are not only for the assessee firm but are for the entire group. It is further submitted that on these pages, the profit has been stated to be divided between 'GJ and `MJ in the ratio of 58% and 42% whereas in the appellant firm