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87 results for “transfer pricing”+ Section 69Bclear

Sorted by relevance

Delhi147Jaipur87Mumbai43Bangalore23Chandigarh22Cochin19Chennai15Agra14Ahmedabad13Amritsar11Indore6Pune5Surat5Raipur4Allahabad2Rajkot2Jodhpur2Hyderabad1Ranchi1SC1

Key Topics

Section 143(3)71Section 153A69Addition to Income68Section 6841Section 133A35Section 13232Section 26331Search & Seizure27Section 80I25

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 87 · Page 1 of 5

Survey u/s 133A24
Section 69B23
Unexplained Cash Credit10
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, 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

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

MUJMMEEL ,KOTA vs. ACIT-CENTRAL CIRCLE , KOTA

In the result, appeal of the assessee is allowed

ITA 620/JPR/2024[2020-21]Status: DisposedITAT Jaipur14 Feb 2025AY 2020-21

Bench: SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: Miss. Swatika Jha, AdvFor Respondent: Ms. Alka Gautam, CIT a
Section 115BSection 133ASection 139Section 143(2)Section 143(3)Section 263Section 69Section 69A

69B etc. as they are penal in nature. In present case, the income surrendered was to be classified u/s 68, 69 & 69A of the Act. As per the direction of the Ld. PCIT, however, we find that the Ld. PCIT has nowhere pointed out that the income surrendered by the assessee falls within the provision of section

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

MILESTONE DEWELLERS PVT. LTD.,JAIPUR vs. ITO WARD 6(2), JAIPUR

In the result, appeal of the assessee is allowed

ITA 565/JPR/2023[2017-18]Status: DisposedITAT Jaipur31 Oct 2023AY 2017-18

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

For Appellant: Shri Manish Agarwal (C.A.)For Respondent: Shri Arvind Kumar (CIT) a
Section 143(3)Section 144BSection 147

transferring proportionate cost of units sold during FY 2013-14 to 2016-17 to the profit & loss account whereas the DVO has estimated the fair cost of entire residential project including the sold units. Hence, the appellant's submission on this count is prima facie correct. 4.1.8 The appellant submitted that the DVO has not granted rebate for self- supervision

DCIT, CC-2, JAIPUR vs. M/S. ROYAL JEWELLERS, JAIPUR

In the result, appeal of the assessee in ITA No

ITA 174/JPR/2020[2014-15]Status: DisposedITAT Jaipur07 Jun 2023AY 2014-15

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

For Appellant: Sh. Manish Agarwal (CA)For Respondent: Sh. Sanjay Dhariwal(CIT)&
Section 143Section 143(3)Section 145(3)

69B, 69C or 69D), its taxability cannot be determined in terms of section 115BBE. Under the circumstances, the appellant prays that ld.CIT(A) has rightly held that provisions of section 115BBE are not applicable and such order deserves to be upheld. Without prejudice to our legal submission made above, it is submitted that during the course of search, Shri Manoj

M/S. ROYAL JEWELLERS,JAIPUR vs. DCIT, CENTRAL CIRCLE, JAIPUR

In the result, appeal of the assessee in ITA No

ITA 113/JPR/2020[2014-15]Status: DisposedITAT Jaipur07 Jun 2023AY 2014-15

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

For Appellant: Sh. Manish Agarwal (CA)For Respondent: Sh. Sanjay Dhariwal(CIT)&
Section 143Section 143(3)Section 145(3)

69B, 69C or 69D), its taxability cannot be determined in terms of section 115BBE. Under the circumstances, the appellant prays that ld.CIT(A) has rightly held that provisions of section 115BBE are not applicable and such order deserves to be upheld. Without prejudice to our legal submission made above, it is submitted that during the course of search, Shri Manoj

DCIT, CC-2, JAIPUR vs. M/S. ROYAL JEWELLERS, JAIPUR

In the result, appeal of the assessee in ITA No

ITA 175/JPR/2020[2015-16]Status: DisposedITAT Jaipur07 Jun 2023AY 2015-16

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

For Appellant: Sh. Manish Agarwal (CA)For Respondent: Sh. Sanjay Dhariwal(CIT)&
Section 143Section 143(3)Section 145(3)

69B, 69C or 69D), its taxability cannot be determined in terms of section 115BBE. Under the circumstances, the appellant prays that ld.CIT(A) has rightly held that provisions of section 115BBE are not applicable and such order deserves to be upheld. Without prejudice to our legal submission made above, it is submitted that during the course of search, Shri Manoj

M/S. ROYAL JEWELLERS,JAIPUR vs. DCIT, CENTRAL CIRCLE, JAIPUR

In the result, appeal of the assessee in ITA No

ITA 115/JPR/2020[2016-17]Status: DisposedITAT Jaipur07 Jun 2023AY 2016-17

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

For Appellant: Sh. Manish Agarwal (CA)For Respondent: Sh. Sanjay Dhariwal(CIT)&
Section 143Section 143(3)Section 145(3)

69B, 69C or 69D), its taxability cannot be determined in terms of section 115BBE. Under the circumstances, the appellant prays that ld.CIT(A) has rightly held that provisions of section 115BBE are not applicable and such order deserves to be upheld. Without prejudice to our legal submission made above, it is submitted that during the course of search, Shri Manoj

DCIT, CC-2, JAIPUR vs. M/S. ROYAL JEWELLERS, JAIPUR

In the result, appeal of the assessee in ITA No

ITA 176/JPR/2020[2016-17]Status: DisposedITAT Jaipur07 Jun 2023AY 2016-17

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

For Appellant: Sh. Manish Agarwal (CA)For Respondent: Sh. Sanjay Dhariwal(CIT)&
Section 143Section 143(3)Section 145(3)

69B, 69C or 69D), its taxability cannot be determined in terms of section 115BBE. Under the circumstances, the appellant prays that ld.CIT(A) has rightly held that provisions of section 115BBE are not applicable and such order deserves to be upheld. Without prejudice to our legal submission made above, it is submitted that during the course of search, Shri Manoj

M/S. ROYAL JEWELLERS,JAIPUR vs. DCIT, CENTRAL CIRCLE, JAIPUR

In the result, appeal of the assessee in ITA No

ITA 114/JPR/2020[2015-16]Status: DisposedITAT Jaipur07 Jun 2023AY 2015-16

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

For Appellant: Sh. Manish Agarwal (CA)For Respondent: Sh. Sanjay Dhariwal(CIT)&
Section 143Section 143(3)Section 145(3)

69B, 69C or 69D), its taxability cannot be determined in terms of section 115BBE. Under the circumstances, the appellant prays that ld.CIT(A) has rightly held that provisions of section 115BBE are not applicable and such order deserves to be upheld. Without prejudice to our legal submission made above, it is submitted that during the course of search, Shri Manoj

JAGDISH KUMAR ARORA,BHAWANIMANDI vs. DCIT, CENTRAL CIRCLE- KOTA, KOTA

In the result, the appeal of the assessee is allowed

ITA 1195/JPR/2024[2017-18]Status: DisposedITAT Jaipur11 Feb 2025AY 2017-18

Bench: SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: Sh. Shrawan Kumar Gupta, AdvFor Respondent: Mrs. Anita Rinesh, JCIT-Sr. DR
Section 115BSection 143(3)Section 145(3)Section 234ASection 69

transfer of cash to such unexplained advances. If the undisclosed income earned and accumulated over the years is taxed in the year in which it is detected by the Revenue and the same is merely taxed as per normal provisions of the law such an interpretation will place a premium on dishonesty i.e. it tantamounts to rewarding the dishonesty. There

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

SHRI GANGA FOUR WHEELS PRIVATE LIMITED ,SIKAR vs. INCOME TAX OFFICER , SIKAR

In the result, the appeal of the assessee is allowed with no orders to cost

ITA 169/JPR/2024[2015-2016]Status: DisposedITAT Jaipur04 Oct 2024AY 2015-2016

Bench: Hon’ble SHRI SANDEEP GOSAIN (Judicial Member)

For Appellant: Shri Praveen Saraswat, CAFor Respondent: Mrs. Monisha Choudhary, Addl. CIT-DR
Section 142ASection 69B

transfer INB NEFT of Rs. 4500028/- and Rs. 1500028/- respectively. Thus, the appellant has honored the clause as per agreement on the same date itself although the cheque is returned stating some mistake. Hence, the claim of the appellant that the agreement was cancelled due to dishonour of cheque No. 434080 is not valid.” Thus, the Ld. JCIT

SHRI JOHRI LAL SODHANI,JAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, JAIPUR

ITA 1046/JPR/2017[2011-12]Status: DisposedITAT Jaipur20 Jul 2018AY 2011-12
For Appellant: Shri P.C. Parwal, CAFor Respondent: Shri A.S. Nehra, JCIT - DR
Section 143(3)Section 263Section 69

transferred for such rates. These arguments are certainly attractive but the language employed by Section 69B is the first stumbling block which Mr. Sabharwal has to overcome. The section in terms requires that the Assessing Officer has to first “find” that the assessee has “expended” an amount which he has not fully recorded in his books of account

ZARI SILK (INDIA) PRIVATE LIMITED,JAIPUR vs. PRINCIPAL COMMISSIONER OF INCOME TAX (CENTRAL), JAIPUR , JAIPUR

The appeal of the assessee is allowed

ITA 600/JPR/2025[2021-22]Status: DisposedITAT Jaipur15 Sept 2025AY 2021-22

Bench: DR. MITHA LAL MEENA (Accountant Member), DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Shri S.R. Sharma, C.A. &For Respondent: Shri Rajesh Ojha, CIT-DR a
Section 115Section 143(3)Section 148BSection 263Section 69A

Transfer Pricing Officer, as the case may be,] shall be deemed to be erroneous in so far as it is prejudicial to the interests of the revenue, if, in the opinion of the Principal [Chief Commissioner or Chief Commissioner or Principal] Commissioner or Commissioner,— (a) the order is passed without making inquiries or verification which should have been made

ARUN PALAWAT,JAIPUR vs. PRINCIPAL COMMISSIONER OF INCOME TAX, (CENTRAL),, JAIPUR

The appeal of the assessee is allowed

ITA 599/JPR/2025[2021-22]Status: DisposedITAT Jaipur15 Sept 2025AY 2021-22

Bench: DR. MITHA LAL MEENA (Accountant Member), DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Shri S.R. Sharma, C.A. &For Respondent: Shri Rajesh Ojha, CIT-DR a
Section 115Section 143(3)Section 148BSection 263Section 69A

Transfer Pricing Officer, as the case may be,] shall be deemed to be erroneous in so far as it is prejudicial to the interests of the revenue, if, in the opinion of the Principal [Chief Commissioner or Chief Commissioner or Principal] Commissioner or Commissioner,— (a) the order is passed without making inquiries or verification which should have been made

ACIT, CENTRAL CIRCLE, ALWAR vs. SHRI BABU LAL DATA, 2015-16

In the result, appeal of the revenue is dismissed

ITA 1231/JPR/2019[2015-16]Status: DisposedITAT Jaipur05 May 2022AY 2015-16
For Appellant: Sh. P. C. Parwal, CAFor Respondent: S. Naiyer Ali Najmi, CIT
Section 127Section 132Section 139Section 153A

69B of the Act Hence, in our considered opinion, only commission income has to be determined in this case and nothing more. Accordingly, we reverse the findings of the Ld. CIT(A) and order to delete the entire addition so made. Thus Ground Nos. 3 and 4 of the assessee are allowed DCIT Vs. Smt. Manishaben N. Mashru ITA No.958/RJT/2010