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116 results for “transfer pricing”+ Section 65clear

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Key Topics

Section 143(3)73Addition to Income72Section 6851Section 153A38Section 80I36Section 14832Section 25030Disallowance25Section 14323

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

Accordingly, the same is dismissed

ITA 490/JPR/2023[2016-17]Status: DisposedITAT Jaipur21 Feb 2024AY 2016-17
Section 115JSection 143Section 143(3)Section 144B(1)(xvi)Section 80Section 80I

transfer power directly to the ultimate industrial consumer i.e. the manufacturing units of assessee. 30.13. Further, the aspect as to why rate at which power is sold to 3rd parties including Power distribution companies should not be considered as internal CUP and hence considered for computing arm's length price under the Transfer Pricing regulations, needs to be dealt with

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

Showing 1–20 of 116 · Page 1 of 6

Section 234A23
Deduction15
Unexplained Cash Credit12
ITA 497/JPR/2023[2017-18]Status: DisposedITAT Jaipur21 Feb 2024AY 2017-18
Section 115JSection 143Section 143(3)Section 144B(1)(xvi)Section 80Section 80I

transfer power directly to the ultimate industrial consumer i.e. the manufacturing units of assessee.\n30.13. Further, the aspect as to why rate at which power is sold to 3rd parties including Power distribution companies should not be considered as internal CUP and hence considered for computing arm's length price under the Transfer Pricing regulations, needs to be dealt with

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

ITA 496/JPR/2023[2016-17]Status: DisposedITAT Jaipur21 Feb 2024AY 2016-17

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

For Appellant: Sh. Dilip B Desai(C.A.)For Respondent: Sh. Alka Gautam (CIT) (V.H) &
Section 115JSection 143Section 143(3)Section 144BSection 144B(1)(xvi)Section 80Section 80I

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, DELHI

In the result, the appeal of the Revenue in ITA No

ITA 500/JPR/2023[215-16]Status: DisposedITAT Jaipur21 Feb 2024

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

For Appellant: Sh. Dilip B Desai(C.A.)For Respondent: Sh. Alka Gautam (CIT) (V.H) &
Section 115JSection 143Section 143(3)Section 144BSection 144B(1)(xvi)Section 80Section 80I

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

ITA 489/JPR/2023[2015-16]Status: DisposedITAT Jaipur21 Feb 2024AY 2015-16
For Appellant: Sh. Dilip B Desai(C.A.)For Respondent: Sh. Alka Gautam (CIT) (V.H) &
Section 115JSection 143Section 143(3)Section 144B(1)(xvi)Section 80Section 80I

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

ITA 152/JPR/2023[2014-15]Status: DisposedITAT Jaipur07 Aug 2023AY 2014-15

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

For Appellant: Shri Vijay Shah, CAFor Respondent: Shri Arvind Kumar, CIT
Section 115JSection 250Section 32(1)(ii)Section 80Section 80I

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

ITA 498/JPR/2023[2018-19]Status: DisposedITAT Jaipur21 Feb 2024AY 2018-19
For Appellant: Sh. Dilip B Desai(C.A.)For Respondent: Sh. Alka Gautam (CIT) (V.H) &
Section 115JSection 143Section 143(3)Section 144B(1)(xvi)Section 80Section 80I

65,450/- out of \nclaim u/s 80IA of Rail System due to the adjustment of transfer pricing.\n5. That the appellant craves to add, amend, alter, delete or modify any or \nall the above grounds of appeal before or at the time of hearing.\n Assessment Year 2016-17 \nITA NO. 496/JPR/2023(ASSESSEE) \n1. That on the facts

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

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 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 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 509/JPR/2025[2021-22]Status: DisposedITAT Jaipur12 Nov 2025AY 2021-22
For Appellant: Sh. Mukesh Soni, AdvFor Respondent: Mrs. Anita Rinesh, JCIT-DR
Section 144CSection 153CSection 153DSection 250

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

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)

65,553/-, made by the Assessing Officer on account of disallowance of interest u/s 36(1)(iii) of the Act. ITA No. 1098/JPR/2024, A.Y.2015-16 Disallowance of interest 6. By way of this appeal, department has challenged, impugned order passed by Learned CIT(A) dated 25.06.2024, whereby Learned CIT(A) deleted addition of Rs. 56,08,94,534/-, made

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)

65,553/-, made by the Assessing Officer on account of disallowance of interest u/s 36(1)(iii) of the Act. ITA No. 1098/JPR/2024, A.Y.2015-16 Disallowance of interest 6. By way of this appeal, department has challenged, impugned order passed by Learned CIT(A) dated 25.06.2024, whereby Learned CIT(A) deleted addition of Rs. 56,08,94,534/-, made

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)

65,553/-, made by the Assessing Officer on account of disallowance of interest u/s 36(1)(iii) of the Act. ITA No. 1098/JPR/2024, A.Y.2015-16 Disallowance of interest 6. By way of this appeal, department has challenged, impugned order passed by Learned CIT(A) dated 25.06.2024, whereby Learned CIT(A) deleted addition of Rs. 56,08,94,534/-, made

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)

65,553/-, made by the Assessing Officer on\naccount of disallowance of interest u/s 36(1)(iii) of the Act.\nITA No. 1098/JPR/2024, Α.Υ.2015-16\nDisallowance of interest\n6.\nBy way of this appeal, department has challenged, impugned order\npassed by Learned CIT(A) dated 25.06.2024, whereby Learned CIT(A)\ndeleted addition of Rs.56,08,94,534/-, made

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)

65,553/-, made by the Assessing Officer on\naccount of disallowance of interest u/s 36(1)(iii) of the Act.\nITA No. 1098/JPR/2024, Α.Υ.2015-16\nDisallowance of interest\n6. By way of this appeal, department has challenged, impugned order\npassed by Learned CIT(A) dated 25.06.2024, whereby Learned CIT(A)\ndeleted addition of Rs.56,08,94,534/-, made

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

65,210 the appellant has claimed a refund of Rs. 16,99,26,055 in the original return of income filed on 30.11.2019. 9 Shree Cement Limited vs. ACIT The above return was processed vide intimation as per provision of section 143(1) of the Act on 15.01.2021. While processing that ITR learned Assistant Director of Income Tax CPC Bangalore

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

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

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

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