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120 results for “transfer pricing”+ Section 254clear

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Key Topics

Section 143(3)81Addition to Income72Section 153A58Section 6838Section 13237Search & Seizure35Section 36(1)(iii)29Section 133A26Disallowance

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

Showing 1–20 of 120 · Page 1 of 6

26
Section 14724
Section 14A24
Business Income14

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

ARYA SAMAJ MANDIR ,BHILWARA vs. CIT(E), JAIPUR

ITA 1021/JPR/2024[2019-20]Status: DisposedITAT Jaipur22 Apr 2025AY 2019-20

Bench: The Date Of Hearing.”

For Appellant: Shri Devang Gargieya, Advocate &For Respondent: Smt. Runi Pal, CIT-DR
Section 12ASection 80G

254 or section 260 or section 262 or section 263 or section 264 is to be given by the Assessing Officer [or the Transfer Pricing

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2, KOTA, KOTA vs. CHAMBAL FERTILIZERS AND CHEMICALS LTD., KOTA

ITA 1097/JPR/2024[2011-12]Status: DisposedITAT Jaipur27 Aug 2025AY 2011-12

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

For Appellant: Shri P.J. Pardiwala, AdvFor Respondent: Shri Rajesh Ojha, CIT &
Section 14ASection 36(1)Section 36(1)(iii)

254/- that was made by the Assessing Officer on account of disallowance of amount of loans and advances to subsidiary/group companies. Disallowance of contribution to DAV Trust Management Society Department has also challenged deletion of addition of Rs. 82,10,270/- made by the Assessing Officer by disallowing contribution to DAV Trust Management Society. ITAT No. 1099/JPR/2024

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2, KOTA, KOTA vs. CHAMBAL FERTILIZERS AND CHEMICALS LTD, KOTA

ITA 1090/JPR/2024[2010-11]Status: DisposedITAT Jaipur27 Aug 2025AY 2010-11

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

For Appellant: Shri P.J. Pardiwala, AdvFor Respondent: Shri Rajesh Ojha, CIT &
Section 14ASection 36(1)Section 36(1)(iii)

254/- that was made by the Assessing Officer on account of disallowance of amount of loans and advances to subsidiary/group companies. Disallowance of contribution to DAV Trust Management Society Department has also challenged deletion of addition of Rs. 82,10,270/- made by the Assessing Officer by disallowing contribution to DAV Trust Management Society. ITAT No. 1099/JPR/2024

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2, KOTA, KOTA vs. CHAMBAL FERTILIZERS AND CHEMICALS LTD, KOTA

ITA 1091/JPR/2024[2017-18]Status: DisposedITAT Jaipur27 Aug 2025AY 2017-18

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

For Appellant: Shri P.J. Pardiwala, AdvFor Respondent: Shri Rajesh Ojha, CIT &
Section 14ASection 36(1)Section 36(1)(iii)

254/- that was made by the Assessing Officer on account of disallowance of amount of loans and advances to subsidiary/group companies. Disallowance of contribution to DAV Trust Management Society Department has also challenged deletion of addition of Rs. 82,10,270/- made by the Assessing Officer by disallowing contribution to DAV Trust Management Society. ITAT No. 1099/JPR/2024

KOTHARI JEWELS PRIVATE LIMITED,MUMBAI vs. ACIT, JAIPUR

In the result, the appeal of the assessee is allowed

ITA 455/JPR/2015[2010-11]Status: DisposedITAT Jaipur04 Apr 2018AY 2010-11
For Appellant: Shri S. R. Sharma &For Respondent: Shri Varindar Mehta (CIT)
Section 132Section 133ASection 145(3)Section 153A

price and this clearly shows that in the instant case, the assessee has not reflected true GP on its sale by stock transfer to its sister concerns and as per discussion above, the difference in gold rates on the date of transfer comes to Rs. 43,99,029/-. The AO thereafter worked out the average

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2, KOTA, KOTA vs. CHAMBAL FERTILIZERS AND CHEMICALS LTD, KOTA

ITA 1098/JPR/2024[2015-16]Status: DisposedITAT Jaipur27 Aug 2025AY 2015-16
Section 14ASection 36(1)Section 36(1)(iii)

254/- that was made by the Assessing Officer on account of\ndisallowance of amount of loans and advances to subsidiary/group\ncompanies.\nDisallowance of contribution to DAV Trust Management Society\nDepartment has also challenged deletion of addition of Rs.\n82,10,270/- made by the Assessing Officer by disallowing contribution to\nDAV Trust Management Society.\nITAT No. 1099/JPR/2024

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2, KOTA, KOTA vs. CHAMBAL FERTILIZERS AND CHEMICALS LTD., KOTA

ITA 1099/JPR/2024[2016-17]Status: DisposedITAT Jaipur27 Aug 2025AY 2016-17
For Appellant: Shri P.J. Pardiwala, AdvFor Respondent: Shri Rajesh Ojha, CIT &
Section 14ASection 36(1)Section 36(1)(iii)

254/- that was made by the Assessing Officer on account of\ndisallowance of amount of loans and advances to subsidiary/group\ncompanies.\nDisallowance of contribution to DAV Trust Management Society\nDepartment has also challenged deletion of addition of Rs.\n82,10,270/- made by the Assessing Officer by disallowing contribution to\nDAV Trust Management Society.\nITAT No. 1099/JPR/2024

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

section 143(1) of the Income Tax Act, 1961 [ for short Act ] on 15.01.2021. 2 Shree Cement Limited vs. ACIT 2. In this appeal, the assessee has raised the following grounds: - “1. That on the facts and in the circumstances of the case, the ld. CIT(Appeals) was not justified and erred in not deleting the disallowance

DCIT, CIRCLE 6, JAIPUR, NCRB, JPR vs. BARMER LIGNITE MINING COMPANY LIMITED, UDYOG BHAWAN JAIPUR

Appeals of the assessee are allowed for statistical purposes in view of our detailed order (supra)

ITA 453/JPR/2023[2017-18]Status: DisposedITAT Jaipur16 Dec 2024AY 2017-18

Bench: Dr. S. Seethalakshmi & Shri Gagan Goyal

For Appellant: Mr. P. C. Parwal, CA, Ld. ARFor Respondent: MS. Alka Gautam, CIT, Ld. DR
Section 234ASection 250Section 94E

transferred, before the expiry of the period of ten years specified in sub-section (1), to another Indian company in a scheme of demerger,— (i) no deduction shall be admissible under sub-section (1) in the case of the demerged company for the previous year in which the demerger takes place; and (ii) the provisions of this section shall

BARMER LIGNITE MINING CO. LTD.,C-SCHEME, JAIPUR vs. DCIT, CIRCLE-6, JAIPUR, JAIPUR

Appeals of the assessee are allowed for statistical purposes in view of our detailed order (supra)

ITA 462/JPR/2023[2018-19]Status: DisposedITAT Jaipur16 Dec 2024AY 2018-19

Bench: Dr. S. Seethalakshmi & Shri Gagan Goyal

For Appellant: Mr. P. C. Parwal, CA, Ld. ARFor Respondent: MS. Alka Gautam, CIT, Ld. DR
Section 234ASection 250Section 94E

transferred, before the expiry of the period of ten years specified in sub-section (1), to another Indian company in a scheme of demerger,— (i) no deduction shall be admissible under sub-section (1) in the case of the demerged company for the previous year in which the demerger takes place; and (ii) the provisions of this section shall

DCIT, CIRCLE-6 JAIPUR, NCRB, JAIPUR vs. BARMER LIGNITE MINING COMPANY LIMITED, UDYOG BHAWAN, TILAK NAGAR JPR

Appeals of the assessee are allowed for statistical purposes in view of our detailed order (supra)

ITA 452/JPR/2023[2016-17]Status: DisposedITAT Jaipur16 Dec 2024AY 2016-17

Bench: Dr. S. Seethalakshmi & Shri Gagan Goyal

For Appellant: Mr. P. C. Parwal, CA, Ld. ARFor Respondent: MS. Alka Gautam, CIT, Ld. DR
Section 234ASection 250Section 94E

transferred, before the expiry of the period of ten years specified in sub-section (1), to another Indian company in a scheme of demerger,— (i) no deduction shall be admissible under sub-section (1) in the case of the demerged company for the previous year in which the demerger takes place; and (ii) the provisions of this section shall

BARMER LIGNITE MINING CO. LTD.,C-SCHEME, JAIPUR vs. DCIT, CIRCLE-6, JAIPUR, JAIPUR

Appeals of the assessee are allowed for statistical purposes in view of our detailed order (supra)

ITA 461/JPR/2023[2017-18]Status: DisposedITAT Jaipur16 Dec 2024AY 2017-18

Bench: Dr. S. Seethalakshmi & Shri Gagan Goyal

For Appellant: Mr. P. C. Parwal, CA, Ld. ARFor Respondent: MS. Alka Gautam, CIT, Ld. DR
Section 234ASection 250Section 94E

transferred, before the expiry of the period of ten years specified in sub-section (1), to another Indian company in a scheme of demerger,— (i) no deduction shall be admissible under sub-section (1) in the case of the demerged company for the previous year in which the demerger takes place; and (ii) the provisions of this section shall

DCIT, CIRCLE-6, JAIPUR, NCRB, JAIPUR vs. BARMER LIGNITE MINING COMPANY LIMITED, UDYOG BHAWAN, JAIPUR

Appeals of the assessee are allowed for statistical purposes in view of our detailed order (supra)

ITA 455/JPR/2023[2020-21]Status: DisposedITAT Jaipur16 Dec 2024AY 2020-21

Bench: Dr. S. Seethalakshmi & Shri Gagan Goyal

For Appellant: Mr. P. C. Parwal, CA, Ld. ARFor Respondent: MS. Alka Gautam, CIT, Ld. DR
Section 234ASection 250Section 94E

transferred, before the expiry of the period of ten years specified in sub-section (1), to another Indian company in a scheme of demerger,— (i) no deduction shall be admissible under sub-section (1) in the case of the demerged company for the previous year in which the demerger takes place; and (ii) the provisions of this section shall

DCIT, CIRCLE-6, JAIPUR, NCRB, JAIPUR vs. BARMER LIGNITE MINING COMPANY LIMITED, UDYOG BHAWAN, JAIPUR

Appeals of the assessee are allowed for statistical purposes in view of our detailed order (supra)

ITA 454/JPR/2023[2018-19]Status: DisposedITAT Jaipur16 Dec 2024AY 2018-19

Bench: Dr. S. Seethalakshmi & Shri Gagan Goyal

For Appellant: Mr. P. C. Parwal, CA, Ld. ARFor Respondent: MS. Alka Gautam, CIT, Ld. DR
Section 234ASection 250Section 94E

transferred, before the expiry of the period of ten years specified in sub-section (1), to another Indian company in a scheme of demerger,— (i) no deduction shall be admissible under sub-section (1) in the case of the demerged company for the previous year in which the demerger takes place; and (ii) the provisions of this section shall

BARMER LIGNITE MINING CO. LTD.,C-SCHEME, JAIPUR vs. DCIT, CIRCLE-6, JAIPUR, JAIPUR

Appeals of the assessee are allowed for statistical purposes in view of our detailed order (supra)

ITA 463/JPR/2023[2020-21]Status: DisposedITAT Jaipur16 Dec 2024AY 2020-21

Bench: Dr. S. Seethalakshmi & Shri Gagan Goyal

For Appellant: Mr. P. C. Parwal, CA, Ld. ARFor Respondent: MS. Alka Gautam, CIT, Ld. DR
Section 234ASection 250Section 94E

transferred, before the expiry of the period of ten years specified in sub-section (1), to another Indian company in a scheme of demerger,— (i) no deduction shall be admissible under sub-section (1) in the case of the demerged company for the previous year in which the demerger takes place; and (ii) the provisions of this section shall

BARMER LIGNITE MINING CO. LTD.,C-SCHEME, JAIPUR vs. DCIT, CIRCLE-6, JAIPUR

ITA 460/JPR/2023[2016-17]Status: DisposedITAT Jaipur16 Dec 2024AY 2016-17
Section 234ASection 250Section 94E

transferred, before the expiry of the period of ten years specified in sub-section (1),\nto another Indian company in a scheme of demerger, —\n(i) no deduction shall be admissible under sub-section (1) in the case of the demerged\ncompany for the previous year in which the demerger takes place; and\n(ii) the provisions of this section

HARISH SHARMA HUF,B-1, PATODIYA MARG, SHASTRI NAGAR, JAIPUR vs. ITO, WARD-5(3), JAIPUR

In the result the appeal of the assessee is dismissed

ITA 318/JPR/2022[2014-15]Status: DisposedITAT Jaipur11 Nov 2022AY 2014-15
For Appellant: Sh. P. C. Parwal (CA)For Respondent: Shri Chanchal Meena (JCIT)
Section 10(38)Section 133ASection 143(2)Section 143(3)Section 68Section 69C

transferred to the beneficiary at a very nominal price mostly off-line through preferential allotment or off line sale to save STT The beneficiary (an Individual) holds the share for one year, the statutory period after which LTCG is exempt under section 10(38) of the Income tax Act, 1961. In the meantime the operators rig the price

KIRAN FINE JEWELLERS PRIVATE LIMITED,JAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2,, JAIPUR

In the result ground no 2 raised by the assessee is allowed

ITA 648/JPR/2024[2017-18]Status: DisposedITAT Jaipur25 Feb 2025AY 2017-18

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Sh. S. R. Sharma, CA &For Respondent: Sh. P. P. Meena, CIT-Th. V.H
Section 115BSection 143(3)Section 145(3)Section 68Section 69A

price', is ab- initio void as per the provisions of sec.23of the Contracts Act, 1872 and thus non- est in the eyes of law. Hence, such SBNs cannot be treated as having arisen out of a contract for sale…….” It is held by the Hon'ble ITAT as under:- “70. From the reading of the above notification, it is abundantly