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

Accordingly, the same is dismissed

34,58,626/- out of the claim u/s. 80-IA on water treatment system on account of transfer pricing adjustment of water, the relevant fact is that the assessee has computed transfer price of water (Rs.3/ltr) for captive consumption. The price has been determined on the basis of a quotation obtained from Bisleri International Private Limited for Rs. 3.50 per/ltr

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.

34,58,626/- out of the claim u/s. 80-IA on water treatment system on account of transfer pricing adjustment of water, the relevant fact is that the assessee has computed transfer price of water (Rs.3/ltr) for captive consumption. The price has been determined on the basis of a quotation obtained from Bisleri International Private Limited for Rs. 3.50 per/ltr

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.

34,58,626/- out of the claim u/s. 80-IA on water treatment system on account of transfer pricing adjustment of water, the relevant fact is that the assessee has computed transfer price of water (Rs.3/ltr) for captive consumption. The price has been determined on the basis of a quotation obtained from Bisleri International Private Limited for Rs. 3.50 per/ltr

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

34,58,626/- out of the claim u/s. 80-IA on water treatment system on account of transfer pricing adjustment of water, the relevant fact is that the assessee has computed transfer price of water (Rs.3/ltr) for captive consumption. The price has been determined on the basis of a quotation obtained from Bisleri International Private Limited for Rs. 3.50 per/ltr

DEPUTY COMMISSIONER OF INCOME TAX, JAIPUR vs. M/S WORSHIP INFRAPROJECTS PVT LTD(PREVIOUSLY KNOWN AS OM METALS SPML INFRAPROJECTS PVT LTD), JAIPUR

In the result of the appeal of the assessee is allowed

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

Section 40A(2) for want of motive of evasion of tax Accordingly on principle, we accept the contention of the learned AR however, the Assessing Officer to directed to verify the rate of tax at which the recipient of interest have paid tax and if the rate of tax paid by the recipient is equivalent to the rate

WORSHIP INFRAPROJECTS PRIVATE LIMITED,JAIPUR vs. DCIT, CEIRCLE-2, JAIPUR

In the result of the appeal of the assessee is allowed

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

Section 40A(2) for want of motive of evasion of tax Accordingly on principle, we accept the contention of the learned AR however, the Assessing Officer to directed to verify the rate of tax at which the recipient of interest have paid tax and if the rate of tax paid by the recipient is equivalent to the rate

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

34,58,626/- out of the\nclaim u/s. 80-IA on water treatment system on account of transfer\npricing adjustment of water, the relevant fact is that the assessee\nhas computed transfer price of water (Rs.3/ltr) for captive\nconsumption. The price has been determined on the basis of a\nquotation obtained from Bisleri International Private Limited for Rs.\n3.50 per/ltr

VAIBHAV GLOBAL LIMITED,JAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-5, JAIPUR

In the result, the penalty is directed to be deleted and appeal of the assessee is allowed

section 92C of the Income Tax Act. 3. During the course of assessment proceedings, the matter was referred by the Assessing officer to the Transfer Pricing Officer (TPO) and the TPO has adopted the CUP method for determination of arm’s length price and has proposed an adjustment of Rs. 18,65,77,973/- determined as the value of interest

VAIBHAV GLOBAL LIMITED,JAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-5, JAIPUR

In the result, the penalty is directed to be deleted and appeal of the assessee is allowed

section 92C of the Income Tax Act. 3. During the course of assessment proceedings, the matter was referred by the Assessing officer to the Transfer Pricing Officer (TPO) and the TPO has adopted the CUP method for determination of arm’s length price and has proposed an adjustment of Rs. 18,65,77,973/- determined as the value of interest

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)

Transfer Pricing. 5. Whether on the facts and circumstances of the case, the learned CIT (A) NFAC Delhi was justified in allowing the appeal of the assessee by deleting the disallowance of Rs. 62,34,41,568/- on account of sales tax subsidy and electricity duty exemptions received by assessee in nature of capital received and the same

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

34,58,626/- out of the \nclaim u/s. 80-IA on water treatment system on account of transfer \npricing adjustment of water, the relevant fact is that the assessee \nhas computed transfer price of water (Rs.3/ltr) for captive \nconsumption. The price has been determined on the basis of a \nquotation obtained from Bisleri International Private Limited for Rs. \n3.50 per/ltr

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)

price is appropriate. It may be mentioned that as pointed out by the appellant, the extinguishment of investments in CTL, owing to its merger with CVL, is not covered under the exceptions provided in section 47 of the Act. Section 47(vii), which exempts capital gain on the hands of shareholder of amalgamating company, as and when its shareholding

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)

price is appropriate. It may be mentioned that as pointed out by the appellant, the extinguishment of investments in CTL, owing to its merger with CVL, is not covered under the exceptions provided in section 47 of the Act. Section 47(vii), which exempts capital gain on the hands of shareholder of amalgamating company, as and when its shareholding

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)

price is appropriate. It may be mentioned that as pointed out by the appellant, the extinguishment of investments in CTL, owing to its merger with CVL, is not covered under the exceptions provided in section 47 of the Act. Section 47(vii), which exempts capital gain on the hands of shareholder of amalgamating company, as and when its shareholding

DCIT, JAIPUR vs. M/S JAIPUR RUGS COMPANY PVT. LTD., JAIPUR

Appeals are allowed for statistical purposes only

Section 92B of the Act. The TPO has already allowed a reasonable credit period of 60 days while computing the arm’s length price of interest to be DCIT Vs. M/s Jaipur Rugs Co. Pvt. Ltd. charged from the AE on abnormal credit period. Hence, he has relied upon the order of the TPO. 6. On the other hand

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

Appeals are allowed for statistical purposes only

Section 92B of the Act. The TPO has already allowed a reasonable credit period of 60 days while computing the arm’s length price of interest to be DCIT Vs. M/s Jaipur Rugs Co. Pvt. Ltd. charged from the AE on abnormal credit period. Hence, he has relied upon the order of the TPO. 6. On the other hand

JAIPUR RUGS COMPANY PVT. LTD.,JAIPUR vs. DCIT, JAIPUR

Appeals are allowed for statistical purposes only

Section 92B of the Act. The TPO has already allowed a reasonable credit period of 60 days while computing the arm’s length price of interest to be DCIT Vs. M/s Jaipur Rugs Co. Pvt. Ltd. charged from the AE on abnormal credit period. Hence, he has relied upon the order of the TPO. 6. On the other hand

JAIPUR RUGS COMPANY PVT. LTD.,JAIPUR vs. ACIT, JAIPUR

Appeals are allowed for statistical purposes only

Section 92B of the Act. The TPO has already allowed a reasonable credit period of 60 days while computing the arm’s length price of interest to be DCIT Vs. M/s Jaipur Rugs Co. Pvt. Ltd. charged from the AE on abnormal credit period. Hence, he has relied upon the order of the TPO. 6. On the other hand

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

price of shares of the first company and\nthe second company on the date of exchange was income chargeable. Hence by\ncorollary, the loss on similar exchange is to be allowed. Thus the allegation of the\n032\nITA No. 1090, 1097 TO 1099 & 1091/JPR/2024\nChambal Fertilizers and Chemicals Ltd., Kota\nassessing officer that there is no transfer within the meaning