VAIBHAV GLOBAL LIMITED,JAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, JAIPUR, JAIPUR

In the result, the appeal of the assessee is allowed and disposed off in light of aforesaid directions

Bench: Shri Sandeep Gosain & Shri Vikram Singh Yadavvaibhav Global Limited, Deputy Commissioner Of बनाम Jaipur. Income Tax, Central Circle-4, Jaipur. "थायी लेखा सं./Pan No: Aaacv4679F

transfer pricing adjustment, and the Hon'ble DRP further erred in rejecting the Appellant's objections on this ground without appreciating the facts of the case thereby denying the Appellant the principle of natural justice. 10. On the facts and in the circumstances of the case, the Ld. AO erred in levying interest under section 234A/234B/234C

NARAYAN HEIGHTS & TOWERS,JAIPUR vs. ITO, JAIPUR

In the result, the appeal of the assessee is allowed

Bench: The Hearing Of Appeal.”

271(1)(c) is not automatic. He submitted that there is no positive material to demonstrate that the assessee has made willful attempt to conceal the income and furnish the inaccurate particular of income. He submitted that there must be an independent finding to this effect as held by the Hon’ble Calcutta High Court, in the case of Durga

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

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

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

In the result, the appeal of the Revenue in ITA No

Bench: or at the time of hearing of this appeal.

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

Bench: or at the time of hearing of this appeal.

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

ASSISSTANT COMMISSIONER OF INCOME TAX, AJMER vs. SHREE CEMENT LTD, BEAWAR

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

Bench: HON’BLE SHRI SANDEEP GOSAIN, JM & HON’BLE SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

section (6) to provide that, with effect from 1-4-2012, the provisions of sub-section shall cease to have effect. Accordingly, a SEZ developer or any entrepreneur carrying on business in an SEZ unit (being a company) would be liable to pay MAT on the profits arising from the development of SEZ or the business carried

KANHIAYA LAL SAIN,JAIPUR vs. JCIT RANGE-7 JAIPUR, JAIPUR

In the result, the Appeals of the appellant stands allowed with no orders as to costs

Bench: SHRI SANDEEP GOSAIN (Judicial Member)

271(1)(c) of the Act, subsequently, reference was made to Addl. CIT to initiate penalty proceedings under section 271D of the Act, the Assessing Officer ought to have been recorded his satisfaction. However, Ld. AO has failed to do so. The same is in violation of CBDT Circular no. 09/DV/2016 dated 26.04.2016 advising Assessing Officer to make a reference

SONU DUSAD,JAIPUR vs. DCIT CENTRAL CIRCLE, 1, JAIPUR, JAIPUR

In the results, the appeal of the assessee in ITA no

Bench: This Tribunal Are As Under :

271(1)(c) of the Act 13. The appellant craves leave to add, amend, alter, revise and modify any of the grounds of appeal on, before or in the course of hearing of the appeal. 4. Succinctly, the facts as culled out from the records are that a Search & Seizure action u/s 132 of the Income

SONU DUSAD,JAIPUR vs. DCIT CENTRAL CIRCLE, 1, JAIPUR, JAIPUR

In the results, the appeal of the assessee in ITA no

Bench: This Tribunal Are As Under :

271(1)(c) of the Act 13. The appellant craves leave to add, amend, alter, revise and modify any of the grounds of appeal on, before or in the course of hearing of the appeal. 4. Succinctly, the facts as culled out from the records are that a Search & Seizure action u/s 132 of the Income

SONU DUSAD,JAIPUR vs. DCIT CENTRAL CIRCLE, 1, JAIPUR, JAIPUR

In the results, the appeal of the assessee in ITA no

Bench: This Tribunal Are As Under :

271(1)(c) of the Act 13. The appellant craves leave to add, amend, alter, revise and modify any of the grounds of appeal on, before or in the course of hearing of the appeal. 4. Succinctly, the facts as culled out from the records are that a Search & Seizure action u/s 132 of the Income

SONU DUSAD,JAIPUR vs. DCIT CENTRAL CIRCLE, 1, JAIPUR, JAIPUR

In the results, the appeal of the assessee in ITA no

Bench: This Tribunal Are As Under :

271(1)(c) of the Act 13. The appellant craves leave to add, amend, alter, revise and modify any of the grounds of appeal on, before or in the course of hearing of the appeal. 4. Succinctly, the facts as culled out from the records are that a Search & Seizure action u/s 132 of the Income

SONU DUSAD,JAIPUR vs. DCIT CENTRAL CIRCLE, 1, JAIPUR, JAIPUR

In the results, the appeal of the assessee in ITA no

271(1)(c) of the Act\n13. The appellant craves leave to add, amend, alter, revise and modify any of\nthe grounds of appeal on, before or in the course of hearing of the appeal.\n4. Succinctly, the facts as culled out from the records are that a Search\n& Seizure action u/s 132 of the Income

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

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

271(1)(c) are also initiated against the assessee since I am satisfied that the assessee has furnished inaccurate particulars of income by claiming wrong deduction on account of interest paid on borrowed funds u/s 36(1)(iii) of the Act.” o13 ITA No. 1090, 1097 TO 1099 & 1091/JPR/2024 Chambal Fertilizers and Chemicals Ltd., Kota 28. As regards other assessment

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

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

271(1)(c) are also initiated against the assessee since I am satisfied that the assessee has furnished inaccurate particulars of income by claiming wrong deduction on account of interest paid on borrowed funds u/s 36(1)(iii) of the Act.” o13 ITA No. 1090, 1097 TO 1099 & 1091/JPR/2024 Chambal Fertilizers and Chemicals Ltd., Kota 28. As regards other assessment

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

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

271(1)(c) are also initiated against the assessee since I am satisfied that the assessee has furnished inaccurate particulars of income by claiming wrong deduction on account of interest paid on borrowed funds u/s 36(1)(iii) of the Act.” o13 ITA No. 1090, 1097 TO 1099 & 1091/JPR/2024 Chambal Fertilizers and Chemicals Ltd., Kota 28. As regards other assessment

DCIT, JAIPUR vs. JAIPUR RUGS COMPANY (P) LTD., JAIPUR

In the result, the appeal filed by the assessee is partly allowed and appeal filed by the Revenue stands dismissed

Transfer Pricing Officer passed under sub-section (3) of section 92CA; and (ii) any foreign company. 15. The scheme of section 144C is unambiguous and sub-section (1) of section 144C clearly provides for issuance of a draft order which is a sine qua non before the Assessing Officer can pass a regular assessment order

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

271(1)(c) are also\ninitiated against the assessee since I am satisfied that the assessee has\nfurnished inaccurate particulars of income by claiming wrong deduction on\naccount of interest paid on borrowed funds u/s 36(1)(iii) of the Act.\n013\nITA No. 1090, 1097 TO 1099 & 1091/JPR/2024\nChambal Fertilizers and Chemicals Ltd., Kota\n28. As regards other assessment