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3 results for “transfer pricing”+ Section 35Dclear

Sorted by relevance

Mumbai66Delhi54Chennai36Ahmedabad28Raipur17Bangalore15Cochin9Pune7Kolkata6Rajkot5Hyderabad5Jaipur3Guwahati3Chandigarh3Kerala1Cuttack1

Key Topics

Section 2636Section 405Section 1952Section 143(2)2Section 142(1)2Disallowance2

SHREE CEMENT LIMITED,BEAWAR vs. PR.CIT, , UDAIPUR

In the result, the appeal of the assessee is allowed

ITA 4/JPR/2021[2014-15]Status: DisposedITAT Jaipur23 Jun 2021AY 2014-15

Bench: Shri Sandeep Gosain, Jm & Shri Vikram Singh Yadav, Am Vk;Dj Vihy La-@Ita No. 04/Jp/2021 Assessment Year: 2014-15 Shree Cement Limited, Cuke Pr.Cit, Vs. Bangur Nagar, Post Box No. 33, Udaipur. Beawar. Pan No.: Aaccs 8796 G Vihykfkhz@Appellant Izr;Fkhz@Respondent Fu/Kzkfjrh Dh Vksj Ls@ Assessee By: Shri Dilip Desai (Ca) Shri Vijay Shah (Ca) Shri Mohit Choudhary (Ca) Jktlo Dh Vksj Ls@ Revenue By : Shri B.K. Gupta (Cit-Dr) Lquokbz Dh Rkjh[K@ Date Of Hearing : 01/04/2021 Mn?Kks"K.Kk Dh Rkjh[K@ Date Of Pronouncement : 23/06/2021 Vkns'K@ Order Per: Sandeep Gosain, J.M. The Present Appeal Has Been Filed By The Assessee Against The Order Of Ld. Pcit, Udaipur Dated 03.02.2021 Passed U/S 263 Of The Income Tax Act, 1961 (In Short The Act) For The Assessment Year 2014-15. The Grounds Of Appeal Taken By The Assessee Are As Under: “1. That On The Facts & In The Circumstances Of The Case, The Learned Principal Commissioner Of Income Tax – Udaipur, (Here- In- After Referred To As Ld. Pr. Cit) Was Not Justified In Initiating Proceedings U/S 263 Of The Income Tax Act, 1961 Since The Order Passed By The Assessing Officer (A.O.) Was Neither Erroneous Nor Prejudicial To The Interest Of The Revenue.

For Appellant: Shri Dilip Desai (CA)For Respondent: Shri B.K. Gupta (CIT-DR)
Section 115JSection 142(1)Section 143(2)
Section 143(3)
Section 263

Transfer Pricing proceedings went on for a period of 30 months by 3 different AOs. During this period, four notices u/s 142(1) were issued by the A.O. dated 04-12-2015 raising 12 queries (PB Pg. No. 257), 04-01-2016 raising 29 queries (PB Pg. No. 17-20), 09-11-2016 raising 10 queries

DCIT, C-4, JAIPUR vs. M/S. JLC ELECTROMET PVT. LTD., JAIPUR

In the result, the appeal of the Department is dismissed

ITA 166/JPR/2020[2016-17]Status: DisposedITAT Jaipur12 Apr 2022AY 2016-17
For Appellant: Shri Mahendra GargieyaFor Respondent: Shri A.S. Nehra, Addl. CIT
Section 142(1)Section 143(2)Section 195Section 40Section 9(1)(vii)

Price and hence no adjustment was necessary for assessment year 2010-2011-AO made disallowance of lab analysis fees of Rs.8,92,635/- on account of non deduction of TDS u/s.40(a)(i)- Held, non residents service were availed only for opinion of certifying process- Since services rendered outside India and payments made outside Country and did not attract

RAJASTHAN STATE MINES & MINERALS LTD.,JAIPUR vs. ACIT, JAIPUR

In the result, appeal of the Revenue is partly allowed for statistical purpose

ITA 253/JPR/2015[2007-08]Status: DisposedITAT Jaipur30 May 2017AY 2007-08

35D(2) of the Act. The Ld. DR submitted that in the original assessment proceedings no query was raised in this respect. Therefore, the Assessing Officer had not applied his mind on the issue of allowability of such claim hence non-considering of this issue resulted into the income escaped assessment. Therefore, the Assessing Officer was justified in re-opening