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

price paid for settling a \ndispute by Shri R.K.Verma. So, there exists a quid-pro-quo in this \ntransaction. In a legal context, it refers to a situation where one party provides \nsomething of value to another party in exchange for something in return. The amount has not been \nreceived without consideration. Consideration is something of value exchanged \nbetween

VAIBHAV GLOBAL LIMITED,JAIPUR vs. DCIT, CC-4, JAIPUR

transfer pricing guidelines. \nIn doing so, the ld. TPO, Ld. AO and the Hon’ble DRP also failed to appreciate that \nBerry ratio is applied only in specific circumstances i.e. low risk procurement and \ndistributors. Additionally, the ld. AO has erred in applying 'Berry Ratio' even when \nin appellant’s own case. Berry Ratio was rejected

VAIBHAV GLOBAL LIMITED,JAIPUR vs. DCIT, CC-4, JAIPUR

sections": [ "143(3)", "144C(13)", "144C(5)", "92D", "10D", "92C(3)", "92B", "92C", "115JB", "270A", "36(1)(va)", "115QA", "69C", "115QB", "10B(2)", "10C", "92", "10A" ], "issues": "The key issues involve the appropriateness of the transfer pricing

MARIE PRODUCTS PRIVATE LIMITED,JAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE 7, JAIPUR

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

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

transferred under sub-section (8)], on or after the 1st day of April, 2021, shall be non est if such assessment is not made in accordance with the procedure laid down under this section." (emphasis supplied) 14. Keeping in view the aforesaid, this Court is of the opinion that learned counsel for the petitioner is correct in submitting that Section

MIKUNI INDIA PRIVATE LIMITED,ALWAR vs. PRINCIPAL COMMISSIONER OF INCOME TAX, PCIT,

12. In view of the above discussion, we find merit in this appeal, when the assessment order dated 27

Bench: passing the impugned order, Learned PCIT issued notice to the assessee, as Learned PCIT found that the Assessing Officer, while framing the above said assessment and the making addition, did not initiate penalty proceedings 270A of the Act. Learned PCIT was of the view that penalty proceedings were to be initiated under the said provision on account of misreporting of income, which came to be added by the Assessing Officer to the total income of the assessee company. It being a Transfer Pri

Section 270A of the Act. Reliance has also been placed on the decision dated 20.2.2023 in Anjis Developers Private Limited vs. PCIT, ITA No. 959/MUM/2022. 6. Admittedly, the assessee company entered into various international transactions with its Associate Enterprises; that the case was selected for scrutiny, and referred to Transfer Pricing Officer (in short “TPO”) u/s 92CA

SH. MAHENDRA KUMAR GOYAL,SIKAR vs. ACIT, CENTRAL CIRCLE-3, JAIPUR, JAIPUR

In the result of the appeal of the assessee are disposed off as under

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

Section 33(4) of the 1922 Act, analogous to Section 250/254 of the 1961 Act) do not confer on the appellate authority a power to make any direction on matters not arising in the appeal, especially as the Act provides separate mechanisms (like Section 34 of 1922 Act, now Section 147) to deal with escaped income. Accordingly, the Apex Court

SH. MAHENDRA KUMAR GOYAL,SIKAR vs. ACIT, CENTRAL CIRCLE-3, JAIPUR, JAIPUR

In the result of the appeal of the assessee are disposed off as under

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

Section 33(4) of the 1922 Act, analogous to Section 250/254 of the 1961 Act) do not confer on the appellate authority a power to make any direction on matters not arising in the appeal, especially as the Act provides separate mechanisms (like Section 34 of 1922 Act, now Section 147) to deal with escaped income. Accordingly, the Apex Court

SH. MAHENDRA KUMAR GOYAL,SIKAR vs. ACIT, CENTRAL CIRCLE-3, JAIPUR, JAIPUR

In the result of the appeal of the assessee are disposed off as under

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, आंकड़ुठरधारी आइटीएए सं.र@ITA Nos.493, 495 to 498, 500/JP/2025 निर्धारण वर्ष@Assessment Years : 2014-15 to 2016-17, 2018-19 to 2020-21 Mahendra Kumar Goyal चुके Vs. ACIT/DCIT Ward No. 2, Shahpura Road Neem Ka Thana, Sikar Central Circle-03, Jaipur लेखा संख्याल्लेय सं.जीआइआर सं.पान@PAN/GIR No.: ACFPG0306G अपीलार्थी@Appellant प्रत्यार्थी@Respondent निर्धारीती की आर से@ Assessee by : Shri P. C. Parwal, CA राजस्व की आर से@ R

Section 33(4) of the 1922 Act, analogous to Section 250/254 of the 1961 Act) do not confer on the appellate authority a power to make any direction on matters not arising in the appeal, especially as the Act provides separate mechanisms (like Section 34 of 1922 Act, now Section 147) to deal with escaped income. Accordingly, the Apex Court

SH. MAHENDRA KUMAR GOYAL,SIKAR vs. ACIT, CENTRAL CIRCLE-3, JAIPUR, JAIPUR

In the result of the appeal of the assessee are disposed off as under

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

Section 33(4) of the 1922 Act, analogous to Section 250/254 of the 1961 Act) do not confer on the appellate authority a power to make any direction on matters not arising in the appeal, especially as the Act provides separate mechanisms (like Section 34 of 1922 Act, now Section 147) to deal with escaped income. Accordingly, the Apex Court

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

In the result, the appeal of the assessee is allowed

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

270A of the Act for under reporting of income and thereby completed the assessment determining the total income at Rs. 3,87,72,400/-. u/s. 143(3) r.w.s. 153A of the Act. 3. Aggrieved from the order of Assessing Officer, assessee preferred an appeal before the ld. CIT(A). Apropos to the grounds so raised the relevant finding

PROFESSIONAL AUTOMOTIVES PRIVATE LIMITED,JAMMU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, JAIPUR

In the result the appeal of the assessee in ITA no

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, आयकर अपील /ITA Nos.809 to 815/JP/2025 निर्धारण वर्ष /Assessment Years :2013-14 to 2019-20 Professional Automotives Pvt. बनाम ACIT, Ltd. Bahu Plaza, Bahu Plaza, Jammu Vs. Central Circle- 1, and Kashmir Jaipur स्थायी लेखा सं./जी.आई.आर. सं./PAN/GIR No.:AAACP9608E अपीलार्थी/Appellant प्र]त्यर्थी/Respondent निर्धारिती की ओर से / Assessee by :Shri Tarun Mittal, CA राजस्व की ओर से /Revenue by: Shri Ajey Malik, CIT (Th. V.C)

Section 194 and 200 were challenged. It was noted in P. RatnakarRao and others V. Govt. Of A.P. and others (1996 (5) SCC 359) that the discretion given under Section 200(1) to the State Government to prescribe maximum rates for compounding the offence is not unguided, uncanalised and arbitrary. It was, inter alia, held as follows: ……………….. ………………. It is indisputable

SUNIL KUMAR AGARWAL,JAIPUR vs. ACIT, CEN. CIR-2, JAIPUR

In the result the appeal of the assessee in ITA no

2, 3 , 6, 20 & 26. However, the perusal of the statement of Shri Nikhil Kr.Goyal reveals that in the entire statement, Shri Nikhil Kumar Goyal has no where alleged that he made any unaccounted purchases from the assessee. He also expressed his inability in furnishing the addresses of the persons appearing in the loose papers on the ground that these

INCOME TAX OFFICER, WARD-6(2), JAIPUR, NCR BUILDING, STATUE CIRCLE JAIPUR vs. VASUDEV HEMRAJANI, ARJUN NAGAR, JAIPUR

The appeal of the revenue stands dismissed

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

270A(9) of the Income Tax Act, 1961 were initiated separately. Being aggrieved by the same the appellant has preferred instant appeal. 19 ITO vs. Vasudev Hemrajani The AO stated that the case was selected for Complete Scrutiny under CASS due to 'Low income compared to large commission receipts' and 'Large cash deposits in bank account(s)'. The appellant derived

KIRAN YADAV,JAIPUR vs. INCOME TAX OFFICER, WARD-1(3), JAIPUR, JAIPUR

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

Bench: BEFORE: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

270A were initiated as the AO opined that the appellant had unreported/misreported the income. Since the penalty proceedings initiated were backed by valid reasons, this ground of appeal is dismissed. Further, Penalty proceedings were initiated and penalty if any will be levied by the AO by a separate order. Therefore, this ground is premature, not sustainable and hence, dismissed