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121 results for “transfer pricing”+ Section 254(2)clear

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Key Topics

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

SMT. BIRMA DEVI,JAIPUR vs. INCOME TAX OFFICER, WARD-6-2, JAIPUR

In the result, appeal of the assessee is allowed in terms indicated

ITA 678/JPR/2018[2013-14]Status: DisposedITAT Jaipur12 Apr 2019AY 2013-14

Bench: The Hearing Of This Appeal.”

For Appellant: Shri S.L. Poddar (Adv)For Respondent: Shri B.K. Gupta (CIT-DR)
Section 139(1)Section 139(4)Section 143(3)Section 2(14)(iii)Section 54B

254 (vi) ACIT vs. KAMLAKAR MOGHA (HIGH COURT OF BOMBAY) (2015) 125 DTR 0273 (Bom), 9. In the additional ground so raised at sl. No. (iii) and (iv) it was submitted in the written submission so placed on record that the agricultural land sold by the assessee was not an asset u/s 2(14)(iii). The same deserves

Showing 1–20 of 121 · Page 1 of 7

26
Section 14724
Section 14A24
Business Income14

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

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

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

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

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

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, 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

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, 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

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 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

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

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

2), an order of fresh assessment 43[or fresh order under section 92CA, as the case may be,] in pursuance of an order under section 254 or section 263 or section 264, setting aside or cancelling an assessment, 43[or an order under section 92CA, as the case may be], may be made at any time before the expiry

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

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

DEPUTY COMMISISONER OF INCOME TAX , JAIPUR vs. M/S. MAN PRAKSH TALKIES PVT. LTD, JAIPUR

ITA 406/JPR/2018[2008-09]Status: DisposedITAT Jaipur27 Sept 2024AY 2008-09

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, vk;dj vihy la-@ITA. Nos.406 & 407/JP/2018 fu/kZkj.k o"kZ@Assessment Years : 2008-09 & 2009-10 Dy. Commissioner of Income Tax, Circle-02, Jaipur cuke Vs. M/s Man Prakash Talkies Pvt Ltd. Near Yadgar, M. I. Road, Jaipur LFkk;h ys[kk la-@thvkbZvkj la-@PAN/GIR No.: AABCM 6231 F vihykFkhZ@Appellant izR;FkhZ@Respondent vk;dj vihy la-@C.O. Nos.11 & 12/JP/2018 (Arising out of ITA Nos.406 & 407/JP/2018) fu/kZkj.k o"kZ@Assessment

For Appellant: Sh. Sidharth Ranka, Adv. &For Respondent: Sh. Ajay Malik (CIT) &
Section 147

254(2) of the I.T.Act, 1961 for adjudication by recalling and modifying the order dated 20/02/2020 in the case of DCIT, Circle-2, Jaipur vs. M/s. Man Prakash Talkies Pvt. Ltd. in ITA No. 407/JP/2018(Revenue's appeal) for A.Y. 2009-10.’’ Hence, keeping in view the submissions as well as the grounds raised by the respective parties