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.

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

Bench: or at the time of hearing of this appeal.

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

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

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,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)

section (6) to provide that, with effect from 1-4-2012, the provisions of sub-section shall cease to have effect. Accordingly, a SEZ developer or any entrepreneur carrying on business in an SEZ unit (being a company) would be liable to pay MAT on the profits arising from the development of SEZ or the business carried

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

section 37(1), \nr.w.s. 40(a)(ii) of the Act and therefore, the amount of \nRs.3,06,59,279/- claimed by the assessee as allowable deduction \ndisallowed and added back to the income of the assessee.\n3.3 During the scrutiny proceedings, the case was referred to the \nTPO for determination of Arm’s Length price with reference to all \ninternational

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

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

Bench: This Tribunal Are As Under :

Transfer 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

Bench: This Tribunal Are As Under :

Transfer 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

Bench: This Tribunal Are As Under :

Transfer 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

Bench: This Tribunal Are As Under :

Transfer 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

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)

37(1), the entire amount of CSR expenses has already been added back by the assessment itself in o20 ITA No. 1090, 1097 TO 1099 & 1091/JPR/2024 Chambal Fertilizers and Chemicals Ltd., Kota the computation of the total income, and as such, disallowance of the said amount resulted in double disallowance. In the course of arguments, Ld. DR for the department

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)

37(1), the entire amount of CSR expenses has already been added back by the assessment itself in o20 ITA No. 1090, 1097 TO 1099 & 1091/JPR/2024 Chambal Fertilizers and Chemicals Ltd., Kota the computation of the total income, and as such, disallowance of the said amount resulted in double disallowance. In the course of arguments, Ld. DR for the department

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)

37(1), the entire amount of CSR expenses has already been added back by the assessment itself in o20 ITA No. 1090, 1097 TO 1099 & 1091/JPR/2024 Chambal Fertilizers and Chemicals Ltd., Kota the computation of the total income, and as such, disallowance of the said amount resulted in double disallowance. In the course of arguments, Ld. DR for the department

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

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

Transfer Pricing Officer passed under sub-section (3)\nof section 92CA; and\n(ii) any non-resident not being a company, or any foreign company:\n11. From the bare reading of the above-mentioned provisions of Section\n144C, it is evident that the Assessing Officer must forward a draft of the proposed\nassessment order to the eligible assessee

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

section 115QA of Act and therefore, the company is liable to pay tax \non the distributed income of Rs.71,99,99,211/-. \n\n3.7 Based on these observations, ld. AO prepared the draft order dated \n26/09/2023 proposing the following additions: \n\n\nParticulars \nAddition (Rs.) \nTransfer pricing adjustment u/s 92CA Rs.1,37,27,79,147/- \nLate deposit of PF amount

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

37(1), the entire amount\nof CSR expenses has already been added back by the assessment itself in\n020\nITA No. 1090, 1097 TO 1099 & 1091/JPR/2024\nChambal Fertilizers and Chemicals Ltd., Kota\nthe computation of the total income, and as such, disallowance of the said\namount resulted in double disallowance.\nIn the course of arguments, Ld. DR for the department

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

37(1), the entire amount\nof CSR expenses has already been added back by the assessment itself in\n020\nITA No. 1090, 1097 ΤΟ 1099 & 1091/JPR/2024\nChambal Fertilizers and Chemicals Ltd., Kota\nthe computation of the total income, and as such, disallowance of the said\namount resulted in double disallowance.\nIn the course of arguments, Ld. DR for the department

M/S SHRIRAM GENERAL INSURANCE COMPANY LTD.,E-8, EPIP RIICO INDUSTRIAL AREA, SITAPURA, JAIPUR vs. PCIT, JAIPUR-2, JAIPUR

In the result, this appeal of the assessee is allowed

Bench: HON’BLE SHRI SANDEEP GOSAIN, JM & HON’BLE SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

37 and therefore, disallowance u/s 14A is applicable in the insurance businesses by virtue of Rule 5(a) of the First Schedule read with section 14A. In the financial statement assessee has disclosed the details of expenses in relation to investments earning both taxable and exempt income under note 17 of schedule 16. Therefore, having regards to the accounts

BARMER LIGNITE MINING CO. LTD.,C-SCHEME, JAIPUR vs. DCIT, CIRCLE-6, JAIPUR, JAIPUR

Appeals of the assessee are allowed for statistical purposes in view of our detailed order (supra)

Bench: Dr. S. Seethalakshmi & Shri Gagan Goyal

transferred, before the expiry of the period of ten years specified in sub-section (1), to another Indian company in a scheme of demerger,— (i) no deduction shall be admissible under sub-section (1) in the case of the demerged company for the previous year in which the demerger takes place; and (ii) the provisions of this section shall