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248 results for “transfer pricing”+ Section 35(1)(iv)clear

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Delhi1,850Mumbai1,589Bangalore823Ahmedabad350Karnataka340Chennai270Jaipur248Hyderabad243Kolkata240Chandigarh197Indore151Pune142Surat137Cochin132Rajkot75Calcutta55Visakhapatnam44SC41Telangana39Raipur38Lucknow37Cuttack27Guwahati20Nagpur20Jodhpur17Agra16Varanasi9Ranchi8Amritsar8Rajasthan7Panaji6Patna6Kerala5Orissa4A.K. SIKRI ROHINTON FALI NARIMAN4Allahabad3Andhra Pradesh1T.S. THAKUR ROHINTON FALI NARIMAN1A.K. SIKRI N.V. RAMANA1Punjab & Haryana1

Key Topics

Section 143(3)92Addition to Income75Section 153A63Section 6848Section 13233Search & Seizure29Section 133A28Section 80I25Section 14819

SAKET AGARWAL,JAIPUR vs. ITO WARD 2(3) JAIPUR, JAIPUR

In the result appeal filed by the assessee is allowed

ITA 646/JPR/2024[2014-15]Status: DisposedITAT Jaipur01 Oct 2024AY 2014-15

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

For Appellant: Ms. Satwika Jhan, AdvFor Respondent: Ms. Alka Gautam (CIT) a
Section 143(2)Section 143(3)Section 271(1)(c)Section 41(1)

price through fictitious invoices in the name of the parties mentioned in the letter. 3.4 In response to the Final Show cause notice the A/R of the assessee filed written submission on 23rd Dec., 2016. The assessee contended that the address taken from purchase bills has been supplied, further, during the year in some of the cases the amount

Showing 1–20 of 248 · Page 1 of 13

...
Section 8019
Disallowance18
Survey u/s 133A13

RASHLEELA ENTERPRISES PRIVATE LIMITED, JAIPUR,JAIPUR vs. ACIT CEN CIR 3, JAIPUR, JAIPUR

In the result, the appeal of the assessee is allowed

ITA 1/JPR/2025[2012-13]Status: DisposedITAT Jaipur25 Mar 2025AY 2012-13

Bench: Dr. S. Seethalakshmi & Shri Gagan Goyalrashleela Enterprises Pvt. Ltd., C-5, Krishna Balram, Calgiri Road, Malviya Nagar, Jaipur 302017. Pan No.: Aadcr2594J ...... Appellant Vs.

For Appellant: Mr. Rajeev Sogani, CA, Ld. AR &For Respondent: Mrs. Anita Rinesh, JCIT- Ld. DR
Section 143(3)Section 147Section 148Section 151Section 250Section 35Section 35(1)Section 35(1)(ii)

price falls short of the value of the asset taken into account at the time of cessation, an amount equal to the deficiency shall be allowed as a deduction for the previous year in which the sale took place ; (iv) where a deduction is allowed for any previous year under this section in respect of expenditure represented wholly or partly

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

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

ITA 508/JPR/2025[2020-21]Status: DisposedITAT Jaipur12 Nov 2025AY 2020-21

Bench: This Tribunal Are As Under :

For Appellant: Sh. Mukesh Soni, AdvFor Respondent: Mrs. Anita Rinesh, JCIT-DR
Section 144CSection 153CSection 153DSection 250

Pricing Officer passed under sub-section (3) of section 92CA; and (ii) any non-resident not being a company, or any foreign company: 11. From the bare reading of the above-mentioned provisions of Section 144C, it is evident that the Assessing Officer must forward a draft of the proposed assessment order to the eligible assessee if any variation

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

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

ITA 507/JPR/2025[A.Y. 2018-19]Status: DisposedITAT Jaipur12 Nov 2025

Bench: This Tribunal Are As Under :

For Appellant: Sh. Mukesh Soni, AdvFor Respondent: Mrs. Anita Rinesh, JCIT-DR
Section 144CSection 153CSection 153DSection 250

Pricing Officer passed under sub-section (3) of section 92CA; and (ii) any non-resident not being a company, or any foreign company: 11. From the bare reading of the above-mentioned provisions of Section 144C, it is evident that the Assessing Officer must forward a draft of the proposed assessment order to the eligible assessee if any variation

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

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

ITA 505/JPR/2025[2015-16]Status: DisposedITAT Jaipur12 Nov 2025AY 2015-16

Bench: This Tribunal Are As Under :

For Appellant: Sh. Mukesh Soni, AdvFor Respondent: Mrs. Anita Rinesh, JCIT-DR
Section 144CSection 153CSection 153DSection 250

Pricing Officer passed under sub-section (3) of section 92CA; and (ii) any non-resident not being a company, or any foreign company: 11. From the bare reading of the above-mentioned provisions of Section 144C, it is evident that the Assessing Officer must forward a draft of the proposed assessment order to the eligible assessee if any variation

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

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

ITA 506/JPR/2025[2016-17]Status: DisposedITAT Jaipur12 Nov 2025AY 2016-17

Bench: This Tribunal Are As Under :

For Appellant: Sh. Mukesh Soni, AdvFor Respondent: Mrs. Anita Rinesh, JCIT-DR
Section 144CSection 153CSection 153DSection 250

Pricing Officer passed under sub-section (3) of section 92CA; and (ii) any non-resident not being a company, or any foreign company: 11. From the bare reading of the above-mentioned provisions of Section 144C, it is evident that the Assessing Officer must forward a draft of the proposed assessment order to the eligible assessee if any variation

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

ITA 97/JPR/2021[2016-17]Status: DisposedITAT Jaipur07 Feb 2022AY 2016-17

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

For Appellant: Shri Vijay Mehta, C.AFor Respondent: Shri B.K. Gupta, Pr.CIT
Section 143(3)Section 144C(13)Section 234ASection 92CSection 92D

section 144C(13) of the Act was passed by the Assessing officer on 13.11.2019 wherein adjustment on account of transfer pricing as proposed by the Transfer Pricing Officer was made and the assessed income was determined at Rs.57,36,47,429/-. 3. Against the draft assessment order, the assessee filed its objections before the Dispute Resolution Panel and after considering

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

Accordingly, the same is dismissed

ITA 490/JPR/2023[2016-17]Status: DisposedITAT Jaipur21 Feb 2024AY 2016-17
Section 115JSection 143Section 143(3)Section 144B(1)(xvi)Section 80Section 80I

transfer power directly to the ultimate industrial consumer i.e. the manufacturing units of assessee. 30.13. 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

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

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

ITA 497/JPR/2023[2017-18]Status: DisposedITAT Jaipur21 Feb 2024AY 2017-18
Section 115JSection 143Section 143(3)Section 144B(1)(xvi)Section 80Section 80I

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

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

ITA 431/JPR/2022[2014-15]Status: DisposedITAT Jaipur22 May 2023AY 2014-15

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

For Appellant: Shri Vijay Goyal, CA &For Respondent: Shri A.K. Bhardwaj, CIT &
Section 92C

35,777 Other Income 1,59,946 1,59,946 Total Income 4,66,08,850 3,09,80,623 Expenses Employee Cost 24,71,155 24,71,155 Financial Cost 29,16,785 29,16,785 Other expenses 68,614 Audit fees 50,000 50,000 Preliminary 5,440 5,440 expenses written off Misc. Expenses

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

In the result of the appeal of the assessee is allowed

ITA 394/JPR/2022[2014-15]Status: DisposedITAT Jaipur22 May 2023AY 2014-15

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

For Appellant: Shri Vijay Goyal, CA &For Respondent: Shri A.K. Bhardwaj, CIT &
Section 92C

35,777 Other Income 1,59,946 1,59,946 Total Income 4,66,08,850 3,09,80,623 Expenses Employee Cost 24,71,155 24,71,155 Financial Cost 29,16,785 29,16,785 Other expenses 68,614 Audit fees 50,000 50,000 Preliminary 5,440 5,440 expenses written off Misc. Expenses

ANSHU SAHAI (HUF),JAIPUR vs. ACIT, CENTRAL CIRCLE, CENTRAL CIRCLE

ITA 468/JPR/2025[2018-19]Status: DisposedITAT Jaipur03 Nov 2025AY 2018-19
For Appellant: Sh. Rajeev Sogani, CA &For Respondent: Sh. Sanjay Dhariwal, CIT-DR
Section 115BSection 132Section 133ASection 153CSection 153D

iv) In case the search and seizure action takes place in last week of March 2021 \nand the seized material is transferred by the AO of the search the assessee to the \nAO of the other assessee in the month of April 2021 apparently in the case of the \nother person on the date of search would be treated

SHRI KRISHNARAJ BUILDHOME PVT LTD,JAIPUR vs. INCOME TAX OFFICER, JAIPUR

ITA 753/JPR/2023[2014-15]Status: DisposedITAT Jaipur14 Feb 2024AY 2014-15
For Appellant: Sh. Mukesh Kumar Sharma (Adv.)For Respondent: Sh. Monisha Choudhary (Addl.CIT)
Section 143(3)Section 271(1)(c)Section 43CSection 50

35 and section 37 of the Wealth-tax Act, 1957 (27\nof 1957), shall, with necessary modifications, apply in relation to such\nreference as they apply in relation to a reference made by the Assessing\nOfficer under sub-section (1) of section 16A of that Act.\n[Explanation 1]. —For the purposes of this section, \"Valuation Officer\" shall\nhave

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

ITA 489/JPR/2023[2015-16]Status: DisposedITAT Jaipur21 Feb 2024AY 2015-16
For Appellant: Sh. Dilip B Desai(C.A.)For Respondent: Sh. Alka Gautam (CIT) (V.H) &
Section 115JSection 143Section 143(3)Section 144B(1)(xvi)Section 80Section 80I

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,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

35,61,273/- on 43 Shree Cement Limited vs. ACIT account of profit of Water Treatment Systems and Rs. 85,43,30,848/- on account of profit of New India Power Undertaking (NIPU). 5.1 During the survey, it was found out that there was no Solid Waste Management System and Water Treatment System as envisaged under section

INCOME TAX OFFICER , SIKAR vs. BHASKAR CHAUHAN, JAIPUR

In the result the appeal of the revenue in ITA no

ITA 868/JPR/2024[2017-18]Status: DisposedITAT Jaipur24 Jul 2025AY 2017-18

Bench: Him.

For Appellant: Shri S.L.Poddar, AdvFor Respondent: Mrs Alka Gautam, CIT-DR a
Section 143(3)Section 144Section 153CSection 251Section 69Section 69ASection 69C

35 ITR 416 held that, amount credited in business books can normally be presumed as related to business. Payments received from various customers cannot be doubted until contrary material is brought on record. To treat a receipt as unexplained income the AO needs to be in possession of some material indicating that the assessee has received certain amounts which have

LOVELY PROMOTERS PRIVATE LIMITED,KOLKATA vs. ACIT, CENTRAL CIRCLE, AJMER, AJMER

In the result, the appeal filed by the assessee is allowed

ITA 770/JPR/2023[2013-14]Status: DisposedITAT Jaipur08 Feb 2024AY 2013-14

Bench: him regarding non mentioning of Document Identification Number (DIN) in the body of the order u/s. 127 of the Act dated 08-09-2021 and various other technical pleas raised in grounds of appeal regarding validity of notice u/s. 148 of the Act, thereby appellate order passed by the CIT(A) is non-speaking order and deserves to be quashed. 4. On the facts and in circumstances of the case and in law, the AO erred in issuing notice u/s. 148 of the Act as it was a search related case u/s. 132 r/w

For Appellant: Shri Mayank Taparia (Adv.)For Respondent: Shri A.S. Nehra (Addl.CIT) a
Section 127Section 127(1)Section 132Section 147Section 148Section 148ASection 151Section 153C

transfer of jurisdiction from Kolkata to ACIT, central Circle, Ajmer (Rajsthan) was duly passed by the PCIT-5, Kolkata and the current AO was having jurisdiction on the date of passing the reassessment order. Thus the grounds in which the appellant had raised the objection of jurisdiction is duly dismissed. 9 Lovely promoters Pvt. Ltd. vs. ACIT Further, the appellant

M/S. CHAMBAL FERTILIZERS AND CHEMICALS LIMITED,KOTA vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2, KOTA

In the result, appeal of the revenue is dismissed

ITA 744/JPR/2018[2014-15]Status: DisposedITAT Jaipur13 May 2022AY 2014-15
For Appellant: Shri Percy PardiwallaFor Respondent: Shri Sanjay Dhariwal (CIT)
Section 40A(2)(b)

Transfer of Property Act and Registration Act etc. but nevertheless is entitled to hold the property to the exclusion of all others.” 12 ITA NO. 201(6)/JP/2017 M/s. Chambal Fertilizers & Chemicals Ltd. 70. In the present case, applying the ratio so laid down by the Hon’ble Supreme Court in case of Mysore Minerals, we agree with the findings