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

DEPUTY COMMISSIONER OF INCOME TAX, JAIPUR vs. M/S WORSHIP INFRAPROJECTS PVT LTD(PREVIOUSLY KNOWN AS OM METALS SPML INFRAPROJECTS PVT LTD), JAIPUR

In the result of the appeal of the assessee is allowed

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

Transfer Pricing Officer TPO under section 92CA could be invalid and bad in law. (v) ITAT Bangalore in the case of M/S Nava Karnataka Steels Pvt. Ltd. Versus The Dy. Commissioner of Income Tax, Circle-5 (1) (1), Bengaluru 2022 (6

WORSHIP INFRAPROJECTS PRIVATE LIMITED,JAIPUR vs. DCIT, CEIRCLE-2, JAIPUR

In the result of the appeal of the assessee is allowed

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

Transfer Pricing Officer TPO under section 92CA could be invalid and bad in law. (v) ITAT Bangalore in the case of M/S Nava Karnataka Steels Pvt. Ltd. Versus The Dy. Commissioner of Income Tax, Circle-5 (1) (1), Bengaluru 2022 (6

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. NATIONAL FACELESS ASSESSMENT CENTRE, DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE -2, AJMER, AJMER

Section 144B(1)(xvi)(b) of the Act.\n2. That on the facts and in the circumstances of the case, the Ld. \nCIT(Appeals) was not justified and erred in rejecting the appellant’s \nclaim of allowing reliability charge of Rs. 1.5/unit in computing Transfer \nPrice of Power for the purpose of Deduction u/s 80-IA in respect

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)

6,96,12,33,525/- under provisions of section 115JB of the Act. The case was taken up for scrutiny. In view of specified domestic transactions, a Shree Cement Limited, Beawar. reference under section 92CA was made to the Transfer Pricing

ACIT, CENTRAL CIRCLE, AJMER, AJMER vs. WONDER CEMENT LTD, MADANGANJ-KISHANGARH

In the result Ground No. 2 raised by the assessee is allowed

Bench: Shri Gagan Goyal & Shri Narinder Kumar

6) of the Act, inserted by Finance Act, 2012 (with effect from 1 April 2013) is applicable wherein the 'market value' has been defined to mean the arm's length price as defined in clause (ii) of section 92F of the Act which means 'price which is applied or proposed to be applied in a transaction between persons other than

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 :

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 :

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 :

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 :

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

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 if any variation

DEVIKA BUILDESTATE PRIVATE LIMITED,JAIPUR vs. INCOME TAX OFFICER, JAIPUR

In the result, the appeal of the assessee is allowed

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

transfer of land in specified areas. Since incorporation, the company had purchased land on behalf of RLHL. 2. During the year appellant procured the professional services in relation to development and acquisition related issues of land from three entities namely Nimbus Industries Limited, M/s Arena Trading (P) Ltd and M/s Hetu Investment & Trading Limited, making payments

GUNMALA JAIN,AJMER vs. INCOME TAX OFFICER, WD-2(2), AJMER, AJMER

Appeal of the assessee is dismissed

Bench: SMT. ANNAPURNA GUPTA, AM आयकर अपील सं. / ITA No.1262/JPR/2025 निर्धारणवर्ष / AssessmentYears :2019-20 Gunmala Jain, बनाम 28 Abhi Lash Nikunj, Kalyan Vs. Income Tax Officer, Ward-2(2) Colony, Ajmer Road Kekri, Ajmer स्थायीलेखा सं. / जीआईआर सं./ PAN/GIR No.: ABRPJ 4764E Ajmer अपीलार्थी / Appellant प्रत्यर्थी / Respondent निर्धारिती की ओर से/Assesseeby :Sh. Sunil Porwal, CA (Thr.V.C.) राजस्व की ओर से / Revenue by : Sh. Gautam Singh Choudhary (Addl. CIT) सुनवाई की तारीख / Date of Hearing : 18/1

section (6) in any case are not applicable in the facts of the present case since they relate to additions made on account of estimation or on account of transfer pricing

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)

transfer under section 2(47) of the I.T. Act, 1961. 4. The valuation report of CVL (CFCL Ventures Limited, Cayman Islands) is prepared by the Price Water House & Co LLP. It has prepared projected financial performance. The CFCL Ventures Limited, Cayman Islands has o34 ITA No. 1090, 1097 TO 1099 & 1091/JPR/2024 Chambal Fertilizers and Chemicals Ltd., Kota declared net profit

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)

transfer under section 2(47) of the I.T. Act, 1961. 4. The valuation report of CVL (CFCL Ventures Limited, Cayman Islands) is prepared by the Price Water House & Co LLP. It has prepared projected financial performance. The CFCL Ventures Limited, Cayman Islands has o34 ITA No. 1090, 1097 TO 1099 & 1091/JPR/2024 Chambal Fertilizers and Chemicals Ltd., Kota declared net profit

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)

transfer under section 2(47) of the I.T. Act, 1961. 4. The valuation report of CVL (CFCL Ventures Limited, Cayman Islands) is prepared by the Price Water House & Co LLP. It has prepared projected financial performance. The CFCL Ventures Limited, Cayman Islands has o34 ITA No. 1090, 1097 TO 1099 & 1091/JPR/2024 Chambal Fertilizers and Chemicals Ltd., Kota declared net profit