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

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

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)

801A of the Act. The Transfer Pricing Officer merely relied on extraneous factors (which are without any basis) to conclude that the cost at which the Appellant purchase/s electricity from SEBs cannot be taken as a comparable. The Transfer Pricing Officer failed to appreciate that in terms of the Electricity Act and RERC/ CSERC guidelines, Appellant is restrained from directly

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

4,84,39,49,080/-). The case was selected for Limited Scrutiny\nunder the E-assessment Scheme, 2019 on the following flagged \nissues:-\nSr. No.\nIssues\ni.\nii.\niii.\niv.\nv.\nvi.\nvii.\nviii.\nix.\nx.\nx1.\nxii.\nxiii.\nStock valuation\nIncome/Capital Gain on sale of land or building\nOutward Foreign Remittance\nDepreciation Claim\nSales Turnover Mismatch\nOther Deduction claimed

SHREE CEMENT LIMITED,BANGUR NAGAR vs. ACIT, CENTRAL CIRCLE, AJMER

In the result, the appeal of the assessee - appellant in ITA No

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

801A, in terms of Sec. 80-1A(8) and 80A(6) r.w.s 92F of the Act, the Arm's Length Price (ALP) of the power transferred was determined by considering the Average Annual Landed Cost (AALC) of power sold by the Grid during the year to the assessee and/or similarly placed nearby manufacturing units of independent assessee

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

801A(8) when a basket market value is available, it is the discretion of the assessee to adopt any one of these as market 4 value without appreciating that for comparability under CUP, there needs to be strict comparability of economic factors in transactions and such comparison renders the market value taken by the assessee as non-comparable price since

PINK CITY JEWEL HOUSE PRIVATE LIMITED ,JAIPUR vs. PRINCIPAL COMMISSIONER OF INCOME TAX (CENTRAL), JAIPUR

Section 14A of the Act can\nbe made if the assessee had not earned any exempt income? - HELD THAT:- A\nperusal of the Memorandum of the Finance Bill, 2022 reveals that it explicitly stipulates\nthat the amendment made to Section 14A will take effect from 1st April, 2022 and will\napply in relation to the assessment year