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14 results for “transfer pricing”+ Section 36(1)(va)clear

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Mumbai82Chandigarh64Delhi55Chennai27Ahmedabad26Hyderabad18Jaipur14Jodhpur10Kolkata7Raipur6Bangalore6Pune4Surat3Lucknow3Cuttack2Cochin1Indore1Visakhapatnam1

Key Topics

Section 143(3)19Section 36(1)(iii)17Section 36(1)12Disallowance11Section 26310Section 14A10Addition to Income6Section 143(2)5Section 36(1)(va)4Section 115Q

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) on account of delayed contribution to provident fund. Apart from this, the assessee also raised additional grounds, mentioned as below: a) Inclusion of Reliability Charge while computing Transfer Price for Power undertaking u/s 80IA b) Claim of deduction u's 80IA on eligible Solid Waste Management System as per Form 10CCB filed alongwith return of income

4
Deduction4

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)

Va. CIT (288 ITR 1) (since the assessee has failed to prove any commercial expediency for utilizing interest-bearing borrowed funds for making investment in Units of Mutual Funds) as well as in view of the decision of Hon'ble Punjab & Haryana High Court in the case of M/s Abhishek Industries Ltd. (286 ITR 1) (since the funds borrowed from

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)

Va. CIT (288 ITR 1) (since the assessee has failed to prove any commercial expediency for utilizing interest-bearing borrowed funds for making investment in Units of Mutual Funds) as well as in view of the decision of Hon'ble Punjab & Haryana High Court in the case of M/s Abhishek Industries Ltd. (286 ITR 1) (since the funds borrowed from

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)

Va. CIT (288 ITR 1) (since the assessee has failed to prove any commercial expediency for utilizing interest-bearing borrowed funds for making investment in Units of Mutual Funds) as well as in view of the decision of Hon'ble Punjab & Haryana High Court in the case of M/s Abhishek Industries Ltd. (286 ITR 1) (since the funds borrowed from

RAJESH CHOUDHARY,GURGAON vs. ACIT CENTRAL CIRCLE, ALWAR, ALWAR

In the result, the appeal of the assessee is allowed

ITA 597/JPR/2024[2019-20]Status: DisposedITAT Jaipur01 Jan 2025AY 2019-20

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

For Appellant: Shri R.S. Poonia, CAFor Respondent: Ms. Alka Gautam, CIT-DR
Section 127Section 133ASection 139Section 142(1)Section 143(2)Section 143(3)Section 263

Transfer Pricing Officer" shall have the same meaning as assigned to it in the Explanation to section 92CA.] (2) No order shall be made under sub-section (1) after the expiry of two years from the end of the financial year in which the order sought to be revised was passed. (3) Notwithstanding anything contained in sub-section

MAGENDRA SINGH RATHORE,ALWAR vs. DCIT CENTRAL CIRCLE-2, JAIPUR

In the result the appeal of the assessee is partly allowed

ITA 483/JPR/2024[2017-18]Status: DisposedITAT Jaipur23 Sept 2024AY 2017-18

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

For Appellant: Shri Mahendra Gargiya (Adv.) &For Respondent: Shri Anup Singh (Addl. CIT)
Section 143(3)Section 234ASection 36(1)(iii)Section 57

price of property. Sh. Magendra Singh Rathore 5. Aggrieved by the above order of the Assessing Officer the assessee preferred an appeal before the ld. CIT(A). Apropos to the grounds so raised by the assessee, the relevant finding of the ld. CIT(A) is as under:- “In this case the search action took place on 02.08.2017. Appellant had filed

MAGENDRA SINGH RATHORE,ALWAR vs. ACIT CENTRAL CIRCLE-2, JAIPUR

ITA 460/JPR/2024[2016-17]Status: DisposedITAT Jaipur23 Sept 2024AY 2016-17
For Appellant: Shri Mahendra Gargiya (Adv.) &For Respondent: Shri Anup Singh (Addl. CIT)
Section 143(3)Section 234ASection 57

price of property.\n5. Aggrieved by the above order of the Assessing Officer the\nassessee preferred an appeal before the Id. CIT(A). Apropos to the\ngrounds so raised by the assessee, the relevant finding of the Id.\nCIT(A) is as under:-\n\"In this case the search action took place on 02.08.2017. Appellant had\nfiled his original return

GILLETTE INDIA LIMITED,SPA-65A, INDUSTRIAL AREA, BHIWADI, DISTRICT- ALWAR vs. PCIT, JAIPUR-1, JAIPUR

In the result, the appeal of the assessee is partly allowed

ITA 313/JPR/2023[2016-17]Status: DisposedITAT Jaipur27 Sept 2023AY 2016-17

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

For Appellant: Sh. P. C. ParwalFor Respondent: Sh. Ajay Malik (CIT) a
Section 143(3)Section 192Section 194Section 195Section 263Section 36(1)(va)Section 40

36(1)(va). (b) appreciating that the employee contribution to provident fund amounting to Rs.2,14,97,991/- was paid by the assessee within the grace period as extended by EPFO Circular issued vide No. WSU/9(1) 2013/ Settlement/35631 dt. 08.01.2016. (c) considering that the payment of PF for the month of March of Rs.44,73,579/- was deposited

VAIBHAV GLOBAL LIMITED,JAIPUR vs. DCIT, CC-4, JAIPUR

ITA 1485/JPR/2024[2021-22]Status: DisposedITAT Jaipur30 Jun 2025AY 2021-22
For Appellant: Shri Vinod Kumar Gupta, AdvFor Respondent: Shri Rajesh Ojha, CIT-DR
Section 115JSection 115QSection 143(3)Section 36(1)(va)

36(1)(va) of Rs.19,68,509 without considering \nthat the due date for depositing PF was a public holiday. \n\n5 Under the facts and circumstances of the case the Ld. AO has erred by invoking \nsection 115QA of the Act and further erred by charging additional tax of distributed \nincome in relation to buy back of shares

ASSISTANT COMMISSIONER OF INCOME TAX,EXEMPTIONS,CIRCLE,JAIPUR, JAIPUR vs. GLOBAL INSTITUTE OF TECHNOLOGY SOCIETY, JAIPUR RAJASTHAN

In the results the appeal of the revenue stands dismissed

ITA 175/JPR/2024[2013-14]Status: DisposedITAT Jaipur27 Jun 2024AY 2013-14

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

For Appellant: Sh. S. L. Poddar, AdvFor Respondent: Sh. Anoop Singh, (Addl.CIT)
Section 11Section 12ASection 13(1)Section 13(3)Section 143(3)Section 147

36(1)(va) of the Act. The learned AO has also not allowed the benefit of registration u/s 12AA of the Income Tax Act and not granted the exemption u/s 11 & 12 of the Income Tax Act 1961. Copy of order is placed on paper book page no. 1 to 5. Aggrieved with the order of the Learned Assessing Officer

PROFESSIONAL AUTOMOTIVES PRIVATE LIMITED,JAMMU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, JAIPUR

In the result the appeal of the assessee in ITA no

ITA 812/JPR/2025[2016-17]Status: DisposedITAT Jaipur23 Jul 2025AY 2016-17

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, आयकर अपील /ITA Nos.809 to 815/JP/2025 निर्धारण वर्ष /Assessment Years :2013-14 to 2019-20 Professional Automotives Pvt. बनाम ACIT, Ltd. Bahu Plaza, Bahu Plaza, Jammu Vs. Central Circle- 1, and Kashmir Jaipur स्थायी लेखा सं./जी.आई.आर. सं./PAN/GIR No.:AAACP9608E अपीलार्थी/Appellant प्र]त्यर्थी/Respondent निर्धारिती की ओर से / Assessee by :Shri Tarun Mittal, CA राजस्व की ओर से /Revenue by: Shri Ajey Malik, CIT (Th. V.C)

For Appellant: Shri Tarun Mittal, CAFor Respondent: Shri Ajey Malik, CIT (Th. V.C)
Section 143(3)Section 37(1)

1), bei Vehicle rating of the gross vehicle weight and axel weight respectively as duly certified by the testing agencies for compliance of the rule 126, or in the maximum vehicle weight and maximum safe axle weight of each vehicle respectively as notified by the Central Government, or ill the maximum total load permitted to be carned by the tyre

PINK CITY JEWEL HOUSE PRIVATE LIMITED ,JAIPUR vs. PRINCIPAL COMMISSIONER OF INCOME TAX (CENTRAL), JAIPUR

ITA 598/JPR/2024[2018-2019]Status: DisposedITAT Jaipur26 Dec 2024AY 2018-2019
For Appellant: Sh. Siddharth Ranka, AdvFor Respondent: \nSh. Saurav Harsh, Adv.&
Section 142(1)Section 143(2)Section 144oSection 14ASection 263Section 69

Section 14A of the Act can\nbe made if the assessee had not earned any exempt income? - HELD THAT:- A\nperusal of the Memorandum of the Finance Bill, 2022 reveals that it explicitly stipulates\nthat the amendment made to Section 14A will take effect from 1st April, 2022 and will\napply in relation to the assessment year

VAIBHAV GLOBAL LIMITED,JAIPUR vs. DCIT, CC-4, JAIPUR

ITA 1144/JPR/2024[2020-21]Status: DisposedITAT Jaipur30 Jun 2025AY 2020-21
For Appellant: Shri Vinod Kumar Gupta, AdvFor Respondent: Shri Rajesh Ojha, CIT-DR
Section 115JSection 115QSection 143(3)Section 144C(13)Section 36(1)(va)

sections": [ "143(3)", "144C(13)", "144C(5)", "92D", "10D", "92C(3)", "92B", "92C", "115JB", "270A", "36(1)(va)", "115QA", "69C", "115QB", "10B(2)", "10C", "92", "10A" ], "issues": "The key issues involve the appropriateness of the transfer pricing

AMAR PRATAP STEELS PRIVATE LIMITED,JAIPUR vs. ITO, WARD-7(2), JAIPUR, JAIPUR

In the result, appeal of the assessee is partly allowed

ITA 108/JPR/2024[2013-14]Status: DisposedITAT Jaipur03 Oct 2024AY 2013-14

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Sh. Rohan Sogani, CAFor Respondent: Sh. Monisha Choudhary, Addl. CIT
Section 143(2)Section 143(3)Section 36Section 68

36(i) (va) of the Act paid for employees' contribution to PF and ESI respectively. The action of the Id. CIT(A)/ NFAC is illegal, unjustified, arbitrary and against the facts of the case. Relief may please be granted by quashing the said disallowance of Rs. 4,71,202. 4. The assessee company craves its rights to add, amend