Search: transfer pricing

CASTAMET WORKS PRIVATE LIMITED,KHARWA vs. PRINCIPLE COMMISSIONER OF INCOME TAX, UDAIPUR

V. Commissioner of Income Tax, New Delhi [2018] taxmann.com 154 (SC), wherein it has held that: In the first instance, it needs to be recognised that as per section 14A(1), deduction of that expenditure is not to be allowed which has been incurred by the assessee in relation to income which does not form part of the total income

CHAMBAL FERTILISERS AND CHEMICALS LIMITED,KOTA vs. ACIT, KOTA

In the result, appeal of the revenue is dismissed

ITA 291/JPR/2017[2013-14]Status: DisposedITAT Jaipur13 May 2022AY 2013-14

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

CHAMBAL FERTILISERS AND CHEMICALS LIMITED,KOTA vs. DCIT, KOTA

In the result, appeal of the revenue is dismissed

ITA 201/JPR/2017[2012-13]Status: DisposedITAT Jaipur13 May 2022AY 2012-13

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

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

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

ITA 1090/JPR/2024[2010-11]Status: DisposedITAT Jaipur27 Aug 2025AY 2010-11

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

For Appellant: Shri P.J. Pardiwala, AdvFor Respondent: Shri Rajesh Ojha, CIT &

Section 14ASection 36(1)Section 36(1)(iii)

36(1)(iii) of the Act in respect of the amounts said to have been invested in subsidiaries/group companies/associates , and to remit the matter to Learned Assessing Officer for decision afresh so as to record finding as to interest free funds available with the assessee during the assessment years under consideration, after verification of all relevant documents relied on behalf

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

ITA 1097/JPR/2024[2011-12]Status: DisposedITAT Jaipur27 Aug 2025AY 2011-12

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

For Appellant: Shri P.J. Pardiwala, AdvFor Respondent: Shri Rajesh Ojha, CIT &

Section 14ASection 36(1)Section 36(1)(iii)

36(1)(iii) of the Act in respect of the amounts said to have been invested in subsidiaries/group companies/associates , and to remit the matter to Learned Assessing Officer for decision afresh so as to record finding as to interest free funds available with the assessee during the assessment years under consideration, after verification of all relevant documents relied on behalf

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

ITA 1091/JPR/2024[2017-18]Status: DisposedITAT Jaipur27 Aug 2025AY 2017-18

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

For Appellant: Shri P.J. Pardiwala, AdvFor Respondent: Shri Rajesh Ojha, CIT &

Section 14ASection 36(1)Section 36(1)(iii)

36(1)(iii) of the Act in respect of the amounts said to have been invested in subsidiaries/group companies/associates , and to remit the matter to Learned Assessing Officer for decision afresh so as to record finding as to interest free funds available with the assessee during the assessment years under consideration, after verification of all relevant documents relied on behalf

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

ITA 730/JPR/2018[2009-10]Status: DisposedITAT Jaipur19 Dec 2018AY 2009-10

For Appellant: Shri Vijay Mehta (C.A.) &For Respondent: Smt. Roli Agarwal (CIT)

Section 143(3)Section 271(1)(c)Section 92C

v. Manjunatha Cotton and Ginning Factory [2013] 359 ITR 565/218 Taxman 423/35 taxmann.com 250 has held that a person who is accused of the conditions mentioned in section 271 should be made known about the grounds on which they intend imposing penalty on him as section 274 makes it clear that assessee has a right to contest such proceedings

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

ITA 731/JPR/2018[2010-11]Status: DisposedITAT Jaipur19 Dec 2018AY 2010-11

For Appellant: Shri Vijay Mehta (C.A.) &For Respondent: Smt. Roli Agarwal (CIT)

Section 143(3)Section 271(1)(c)Section 92C

v. Manjunatha Cotton and Ginning Factory [2013] 359 ITR 565/218 Taxman 423/35 taxmann.com 250 has held that a person who is accused of the conditions mentioned in section 271 should be made known about the grounds on which they intend imposing penalty on him as section 274 makes it clear that assessee has a right to contest such proceedings

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

36(1)(va) of the Act on account of delayed contribution to Provident Fund by 1 day due to technical issue in the website of State Bank of India (SBI) which was not attributable to the appellant. 2. That on the facts and in the circumstances of the case, the Ld. CIT(Appeals) was not justified and erred in confirming

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 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 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

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

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

ITA 1098/JPR/2024[2015-16]Status: DisposedITAT Jaipur27 Aug 2025AY 2015-16

Section 14ASection 36(1)Section 36(1)(iii)

36(1)(iii) of the Act\nin respect of the amounts said to have been invested in subsidiaries/group\ncompanies/associates\nand to remit the matter to Learned Assessing\nOfficer for decision afresh so as to record finding as to interest free funds\navailable with the assessee during the assessment years under\nconsideration, after verification of all relevant documents relied on behalf

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

ITA 1099/JPR/2024[2016-17]Status: DisposedITAT Jaipur27 Aug 2025AY 2016-17

For Appellant: Shri P.J. Pardiwala, AdvFor Respondent: Shri Rajesh Ojha, CIT &

Section 14ASection 36(1)Section 36(1)(iii)

36(1)(iii) of the Act\nin respect of the amounts said to have been invested in subsidiaries/group\ncompanies/associates\nand to remit the matter to Learned Assessing\nOfficer for decision afresh so as to record finding as to interest free funds\navailable with the assessee during the assessment years under\nconsideration, after verification of all relevant documents relied on behalf

M/S SUMERU ENTERPROSES,JAIPUR vs. INCOME TAX OFFICER, WARD-6-4, JAIPUR

In the result, the ground of appeal is partly allowed for statistical purposes

ITA 887/JPR/2019[2013-14]Status: DisposedITAT Jaipur20 Jan 2021AY 2013-14

For Appellant: Shri Manish Agrarwal (C.A.)For Respondent: Shri B.K. Gupta (CIT) a

Section 143(3)Section 36(1)(vii)Section 37(1)

transferred in lieu of part sale consideration and interest is worked out on the on the outstanding liabilities (loan taken). During the year interest paid on loans including financial brokerage and bank commission is Rs.4,77,36,535/-. 3. As per point No.28(b) of form No.3CD reflecting finished and work in progress the opening stock in respect of 'commercial

M/S SUMERU ENTERPROSES,JAIPUR vs. INCOME TAX OFFICER, WARD-6-4, JAIPUR

In the result, the ground of appeal is partly allowed for statistical purposes

ITA 886/JPR/2019[2012-13]Status: DisposedITAT Jaipur20 Jan 2021AY 2012-13

For Appellant: Shri Manish Agrarwal (C.A.)For Respondent: Shri B.K. Gupta (CIT) a

Section 143(3)Section 36(1)(vii)Section 37(1)

transferred in lieu of part sale consideration and interest is worked out on the on the outstanding liabilities (loan taken). During the year interest paid on loans including financial brokerage and bank commission is Rs.4,77,36,535/-. 3. As per point No.28(b) of form No.3CD reflecting finished and work in progress the opening stock in respect of 'commercial

M/S SUMERU ENTERPROSES,JAIPUR vs. INCOME TAX OFFICER, WARD-6-4, JAIPUR

In the result, the ground of appeal is partly allowed for statistical purposes

ITA 888/JPR/2019[2014-15]Status: DisposedITAT Jaipur20 Jan 2021AY 2014-15

For Appellant: Shri Manish Agrarwal (C.A.)For Respondent: Shri B.K. Gupta (CIT) a

Section 143(3)Section 36(1)(vii)Section 37(1)

transferred in lieu of part sale consideration and interest is worked out on the on the outstanding liabilities (loan taken). During the year interest paid on loans including financial brokerage and bank commission is Rs.4,77,36,535/-. 3. As per point No.28(b) of form No.3CD reflecting finished and work in progress the opening stock in respect of 'commercial