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19 results for “transfer pricing”+ Section 55(2)(aa)clear

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Delhi91Mumbai46Bangalore21Jaipur19Visakhapatnam17Raipur17Ahmedabad7Chennai7Pune7Hyderabad6Cochin5Surat5Lucknow2Indore2Chandigarh1

Key Topics

Addition to Income19Section 153A16Section 234A14Business Income13Section 689Disallowance9Section 69C8Section 2507Section 94E7

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)

ITA 461/JPR/2023[2017-18]Status: DisposedITAT Jaipur16 Dec 2024AY 2017-18

Bench: Dr. S. Seethalakshmi & Shri Gagan Goyal

For Appellant: Mr. P. C. Parwal, CA, Ld. ARFor Respondent: MS. Alka Gautam, CIT, Ld. DR
Section 234ASection 250Section 94E

aa) of section 139(1) of the Act is 30th November of that assessment year. The Ld. CIT(A), however, at Pg 39, Para 11 held that except making general claim assessee could not submit any statutory compliance involving such audit report and its filing as per law and thus upheld the levy of interest 21. It is submitted that

DCIT, CIRCLE 6, JAIPUR, NCRB, JPR vs. BARMER LIGNITE MINING COMPANY LIMITED, UDYOG BHAWAN JAIPUR

Depreciation7
Set Off of Losses7
Section 143(3)6

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

ITA 453/JPR/2023[2017-18]Status: DisposedITAT Jaipur16 Dec 2024AY 2017-18

Bench: Dr. S. Seethalakshmi & Shri Gagan Goyal

For Appellant: Mr. P. C. Parwal, CA, Ld. ARFor Respondent: MS. Alka Gautam, CIT, Ld. DR
Section 234ASection 250Section 94E

aa) of section 139(1) of the Act is 30th November of that assessment year. The Ld. CIT(A), however, at Pg 39, Para 11 held that except making general claim assessee could not submit any statutory compliance involving such audit report and its filing as per law and thus upheld the levy of interest 21. It is submitted that

DCIT, CIRCLE-6, JAIPUR, NCRB, JAIPUR vs. BARMER LIGNITE MINING COMPANY LIMITED, UDYOG BHAWAN, JAIPUR

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

ITA 454/JPR/2023[2018-19]Status: DisposedITAT Jaipur16 Dec 2024AY 2018-19

Bench: Dr. S. Seethalakshmi & Shri Gagan Goyal

For Appellant: Mr. P. C. Parwal, CA, Ld. ARFor Respondent: MS. Alka Gautam, CIT, Ld. DR
Section 234ASection 250Section 94E

aa) of section 139(1) of the Act is 30th November of that assessment year. The Ld. CIT(A), however, at Pg 39, Para 11 held that except making general claim assessee could not submit any statutory compliance involving such audit report and its filing as per law and thus upheld the levy of interest 21. It is submitted that

DCIT, CIRCLE-6, JAIPUR, NCRB, JAIPUR vs. BARMER LIGNITE MINING COMPANY LIMITED, UDYOG BHAWAN, JAIPUR

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

ITA 455/JPR/2023[2020-21]Status: DisposedITAT Jaipur16 Dec 2024AY 2020-21

Bench: Dr. S. Seethalakshmi & Shri Gagan Goyal

For Appellant: Mr. P. C. Parwal, CA, Ld. ARFor Respondent: MS. Alka Gautam, CIT, Ld. DR
Section 234ASection 250Section 94E

aa) of section 139(1) of the Act is 30th November of that assessment year. The Ld. CIT(A), however, at Pg 39, Para 11 held that except making general claim assessee could not submit any statutory compliance involving such audit report and its filing as per law and thus upheld the levy of interest 21. It is submitted that

DCIT, CIRCLE-6 JAIPUR, NCRB, JAIPUR vs. BARMER LIGNITE MINING COMPANY LIMITED, UDYOG BHAWAN, TILAK NAGAR JPR

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

ITA 452/JPR/2023[2016-17]Status: DisposedITAT Jaipur16 Dec 2024AY 2016-17

Bench: Dr. S. Seethalakshmi & Shri Gagan Goyal

For Appellant: Mr. P. C. Parwal, CA, Ld. ARFor Respondent: MS. Alka Gautam, CIT, Ld. DR
Section 234ASection 250Section 94E

aa) of section 139(1) of the Act is 30th November of that assessment year. The Ld. CIT(A), however, at Pg 39, Para 11 held that except making general claim assessee could not submit any statutory compliance involving such audit report and its filing as per law and thus upheld the levy of interest 21. It is submitted that

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)

ITA 462/JPR/2023[2018-19]Status: DisposedITAT Jaipur16 Dec 2024AY 2018-19

Bench: Dr. S. Seethalakshmi & Shri Gagan Goyal

For Appellant: Mr. P. C. Parwal, CA, Ld. ARFor Respondent: MS. Alka Gautam, CIT, Ld. DR
Section 234ASection 250Section 94E

aa) of section 139(1) of the Act is 30th November of that assessment year. The Ld. CIT(A), however, at Pg 39, Para 11 held that except making general claim assessee could not submit any statutory compliance involving such audit report and its filing as per law and thus upheld the levy of interest 21. It is submitted that

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)

ITA 463/JPR/2023[2020-21]Status: DisposedITAT Jaipur16 Dec 2024AY 2020-21

Bench: Dr. S. Seethalakshmi & Shri Gagan Goyal

For Appellant: Mr. P. C. Parwal, CA, Ld. ARFor Respondent: MS. Alka Gautam, CIT, Ld. DR
Section 234ASection 250Section 94E

aa) of section 139(1) of the Act is 30th November of that assessment year. The Ld. CIT(A), however, at Pg 39, Para 11 held that except making general claim assessee could not submit any statutory compliance involving such audit report and its filing as per law and thus upheld the levy of interest 21. It is submitted that

DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-3, JAIPUR vs. KARNANI SOLVEX PRIVATE LIMITED, JAIPUR

In the result, the appeals of the revenue in ITA No

ITA 480/JPR/2025[2014-15]Status: DisposedITAT Jaipur13 Oct 2025AY 2014-15
For Appellant: Shri Deepak Sharma, CAFor Respondent: MS. Alka Gautam, CIT
Section 132(4)Section 153ASection 68

transferred via cheques or bank transfers, ensuring a transparent\naudit trail. Importantly, there were no outstanding balances associated\nwith these transactions at any point, indicating that loans were duly\nrepaid in subsequent years. This factor is pivotal in establishing the\ngenuneness of the transactions, as it reflects a legitimate business\npractice rather than an attempt to camouflage undisclosed income

RADHAKISHAN BENIWAL,JAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 1, JAIPUR, JAIPUR

In the result, the appeal filed by the assessee in ITA no

ITA 695/JPR/2025[2016-17]Status: DisposedITAT Jaipur10 Sept 2025AY 2016-17

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Shri P. C. Parwal, CA &For Respondent: Shri Gorav Avasthi, JCIT
Section 139Section 144Section 147rSection 148Section 148ASection 194CSection 251Section 68

transfer upon Principal Chief Commissioner or Principal Director General of National e- Assessment Centre and not upon any other Principal Director General or Director General or Principal Chief Commissioner or Chief Commissioner or Principal Commissioner or Commissioner. As is evident from the above, the Court came to the firm conclusion that irrespective of the system of faceless assessment that

RADHAKISHNA BENIWAL,JAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 1, JAIPUR, JAIPUR

In the result, the appeal filed by the assessee in ITA no

ITA 694/JPR/2025[2015-16]Status: DisposedITAT Jaipur10 Sept 2025AY 2015-16

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Shri P. C. Parwal, CA &For Respondent: Shri Gorav Avasthi, JCIT
Section 139Section 144Section 147rSection 148Section 148ASection 194CSection 251Section 68

transfer upon Principal Chief Commissioner or Principal Director General of National e- Assessment Centre and not upon any other Principal Director General or Director General or Principal Chief Commissioner or Chief Commissioner or Principal Commissioner or Commissioner. As is evident from the above, the Court came to the firm conclusion that irrespective of the system of faceless assessment that

DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-3, JAIPUR vs. SAPNA KARNANI, TONK PHATAK

In the result, the appeals of the revenue in ITA No

ITA 712/JPR/2025[2017-18]Status: DisposedITAT Jaipur14 Oct 2025AY 2017-18
For Appellant: Shri Deepak Sharma, CAFor Respondent: Ms. Alka Gautam, CIT, DR
Section 139(1)Section 153ASection 153CSection 68Section 69C

transferred from the lenders' respective bank accounts,\nwhich is a significant factor in establishing their capacity to lend.\n13.2 The Income Tax Appellate Tribunal (ITAT) in Gopal Krishan v. ACIT, ITA\nNo. 892/JP/2019, underscores this principle by affirming that when the source of\nfunds can be traced back to the bank accounts of the lenders, the onus of\nproving their

DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-3, JAIPUR vs. SAPNA KARNANI, TONK PHATAK

In the result, the appeals of the revenue in ITA No

ITA 710/JPR/2025[2014-15]Status: DisposedITAT Jaipur14 Oct 2025AY 2014-15
For Appellant: Shri Deepak Sharma, CAFor Respondent: Ms. Alka Gautam, CIT, DR
Section 139(1)Section 153ASection 153CSection 68Section 69C

transferred from the lenders' respective bank accounts,\nwhich is a significant factor in establishing their capacity to lend.\n\n13.2 The Income Tax Appellate Tribunal (ITAT) in Gopal Krishan v. ACIT, ITA\nNo. 892/JP/2019, underscores this principle by affirming that when the source of\nfunds can be traced back to the bank accounts of the lenders, the onus of\nproving

SH. MAHENDRA KUMAR GOYAL,SIKAR vs. ACIT, CENTRAL CIRCLE-3, JAIPUR, JAIPUR

In the result of the appeal of the assessee are disposed off as under

ITA 497/JPR/2025[2019-20]Status: DisposedITAT Jaipur15 Sept 2025AY 2019-20

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, आंकड़ुठरधारी आइटीएए सं.र@ITA Nos.493, 495 to 498, 500/JP/2025 निर्धारण वर्ष@Assessment Years : 2014-15 to 2016-17, 2018-19 to 2020-21 Mahendra Kumar Goyal चुके Vs. ACIT/DCIT Ward No. 2, Shahpura Road Neem Ka Thana, Sikar Central Circle-03, Jaipur लेखा संख्याल्लेय सं.जीआइआर सं.पान@PAN/GIR No.: ACFPG0306G अपीलार्थी@Appellant प्रत्यार्थी@Respondent निर्धारीती की आर से@ Assessee by : Shri P. C. Parwal, CA राजस्व की आर से@ R

For Appellant: Shri P. C. Parwal, CAFor Respondent: Mrs. Anita Rinesh, JCIT, Sr. DR
Section 127Section 143(2)Section 143(3)Section 153ASection 69

aa) in an appeal against the order of assessment in respect of which the proceeding before the Settlement Commission abates under section 245HA, he may, after taking into consideration all the material and other information produced by the assessee before, or the results of the inquiry held or evidence recorded by, the Settlement Commission, in the course of the proceeding

SH. MAHENDRA KUMAR GOYAL,SIKAR vs. ACIT, CENTRAL CIRCLE-3, JAIPUR, JAIPUR

In the result of the appeal of the assessee are disposed off as under

ITA 500/JPR/2025[2015-16]Status: DisposedITAT Jaipur15 Sept 2025AY 2015-16

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Shri P. C. Parwal, CAFor Respondent: Mrs. Anita Rinesh, JCIT, Sr. DR
Section 127Section 143(2)Section 143(3)Section 153ASection 69

aa) in an appeal against the order of assessment in respect of which the proceeding before the Settlement Commission abates under section 245HA, he may, after taking into consideration all the material and other information produced by the assessee before, or the results of the inquiry held or evidence recorded by, the Settlement Commission, in the course of the proceeding

SH. MAHENDRA KUMAR GOYAL,SIKAR vs. ACIT, CENTRAL CIRCLE-3, JAIPUR, JAIPUR

In the result of the appeal of the assessee are disposed off as under

ITA 496/JPR/2025[2018-19]Status: DisposedITAT Jaipur15 Sept 2025AY 2018-19

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Shri P. C. Parwal, CAFor Respondent: Mrs. Anita Rinesh, JCIT, Sr. DR
Section 127Section 143(2)Section 143(3)Section 153ASection 69

aa) in an appeal against the order of assessment in respect of which the proceeding before the Settlement Commission abates under section 245HA, he may, after taking into consideration all the material and other information produced by the assessee before, or the results of the inquiry held or evidence recorded by, the Settlement Commission, in the course of the proceeding

SH. MAHENDRA KUMAR GOYAL,SIKAR vs. ACIT, CENTRAL CIRCLE-3, JAIPUR, JAIPUR

In the result of the appeal of the assessee are disposed off as under

ITA 493/JPR/2025[2014-15]Status: DisposedITAT Jaipur15 Sept 2025AY 2014-15

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Shri P. C. Parwal, CAFor Respondent: Mrs. Anita Rinesh, JCIT, Sr. DR
Section 127Section 143(2)Section 143(3)Section 153ASection 69

aa) in an appeal against the order of assessment in respect of which the proceeding before the Settlement Commission abates under section 245HA, he may, after taking into consideration all the material and other information produced by the assessee before, or the results of the inquiry held or evidence recorded by, the Settlement Commission, in the course of the proceeding

DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-3, JAIPUR vs. SAPNA KARNANI, TONK PHATAK

In the result, the appeals of the revenue in ITA No

ITA 709/JPR/2025[2013-14]Status: DisposedITAT Jaipur14 Oct 2025AY 2013-14
For Appellant: Shri Deepak Sharma, CAFor Respondent: Ms. Alka Gautam, CIT, DR
Section 139(1)Section 153ASection 153CSection 68Section 69C

transferred from the lenders' respective bank accounts,\nwhich is a significant factor in establishing their capacity to lend.\n13.2 The Income Tax Appellate Tribunal (ITAT) in Gopal Krishan v. ACIT, ITA\nNo. 892/JP/2019, underscores this principle by affirming that when the source of\nfunds can be traced back to the bank accounts of the lenders, the onus of\nproving their

DCIT, JAIPUR vs. AMRAPALI JEWELS PVT. LTD. , JAIPUR

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

ITA 740/JPR/2024[2021]Status: DisposedITAT Jaipur19 Feb 2025

Bench: Him.

For Appellant: Sh. Sanjay Jhanwar, Sr. AdvFor Respondent: Mrs. Alka Gautam, CIT-DR
Section 143(3)Section 145(3)Section 153DSection 251Section 69B

pricing etc. and item quantitative control on staff. In the tax audit report no quantitative details are mentioned. This list is in the nature of undisclosed records or incriminating material unearthed during the survey. (xiv) The appellant has claimed that the valuation should have been by the official valuers for each item separately of the taking into consideration the exact

DINESH HALDIA,JAIPUR vs. DCIT CIRCLE 1, JAIPUR, JAIPUR

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

ITA 384/JPR/2024[2007-08]Status: DisposedITAT Jaipur30 Jul 2024AY 2007-08

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Sh. Dheeraj Borad, CAFor Respondent: Sh. Arvind Kumar, CIT
Section 132(1)Section 133ASection 139(1)Section 153ASection 260ASection 69C

transfer by Vinayak overseas and they were absconding. The Tribunal only on the statement of M.P. Sharma who was power of attorney holder of Vinayak overseas has given the finding. In our view, the finding is perverse. The view taken by the Tribunal is required to be reversed. 8. Apart from that merely voucher of the import export chanals