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10 results for “transfer pricing”+ Section 92Bclear

Sorted by relevance

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Key Topics

Section 92C16Addition to Income10TP Method6Section 143(3)5Section 92C(2)4Section 2634Comparables/TP4Transfer Pricing3Penalty3

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

In the result of the appeal of the assessee is allowed

ITA 394/JPR/2022[2014-15]Status: DisposedITAT Jaipur22 May 2023AY 2014-15

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

For Appellant: Shri Vijay Goyal, CA &For Respondent: Shri A.K. Bhardwaj, CIT &
Section 92C

transfer pricing adjustment made by the learned assessing officer is not sustainable. (xi) ITAT Delhi in the case of M/S SMR Automotive Systems India Ltd. Versus Addl. CIT Special Range-8, Delhi LTA No.6614/Del/2017 Dated:- 3-4 2021 reported in 021 (6) TMI 449-ITAT DELHI. (Case law Paper Book page 105-112) M/s. Worship Infraprojects Pvt. Ltd., Jaipur. Determination

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

Section 144C(13)2
Section 115Q2
Section 271(1)(c)2
ITA 431/JPR/2022[2014-15]Status: DisposedITAT Jaipur22 May 2023AY 2014-15

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

For Appellant: Shri Vijay Goyal, CA &For Respondent: Shri A.K. Bhardwaj, CIT &
Section 92C

transfer pricing adjustment made by the learned assessing officer is not sustainable. (xi) ITAT Delhi in the case of M/S SMR Automotive Systems India Ltd. Versus Addl. CIT Special Range-8, Delhi LTA No.6614/Del/2017 Dated:- 3-4 2021 reported in 021 (6) TMI 449-ITAT DELHI. (Case law Paper Book page 105-112) M/s. Worship Infraprojects Pvt. Ltd., Jaipur. Determination

VAIBHAV GLOBAL LIMITED,JAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-5, JAIPUR

In the result, the penalty is directed to be deleted and appeal of the assessee is allowed

ITA 731/JPR/2018[2010-11]Status: DisposedITAT Jaipur19 Dec 2018AY 2010-11
For Appellant: Shri Vijay Mehta (C.A.) &For Respondent: Smt. Roli Agarwal (CIT)
Section 143(3)Section 271(1)(c)Section 92C

92B, any amount is added or disallowed in computing the total income under sub-section (4) of section 92C, then, the amount so added or disallowed shall, for the purposes of clause (c) of this sub- section, be deemed to represent the income in respect of which particulars have been concealed or inaccurate particulars have been furnished, unless the assessee

VAIBHAV GLOBAL LIMITED,JAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-5, JAIPUR

In the result, the penalty is directed to be deleted and appeal of the assessee is allowed

ITA 730/JPR/2018[2009-10]Status: DisposedITAT Jaipur19 Dec 2018AY 2009-10
For Appellant: Shri Vijay Mehta (C.A.) &For Respondent: Smt. Roli Agarwal (CIT)
Section 143(3)Section 271(1)(c)Section 92C

92B, any amount is added or disallowed in computing the total income under sub-section (4) of section 92C, then, the amount so added or disallowed shall, for the purposes of clause (c) of this sub- section, be deemed to represent the income in respect of which particulars have been concealed or inaccurate particulars have been furnished, unless the assessee

JAIPUR RUGS COMPANY PVT. LTD.,JAIPUR vs. ACIT, JAIPUR

Appeals are allowed for statistical purposes only

ITA 1125/JPR/2016[2010-11]Status: DisposedITAT Jaipur22 Jan 2019AY 2010-11
For Appellant: Shri Rajiv Sogani (CA)For Respondent: Shri Varinder Mehta (CIT-DR) &
Section 92CSection 92C(2)

transfer pricing is also not acceptable. Hence, we find that the matter has not been properly examined by the TPO or by the ld. CIT(A) to work out the correct methodology for the purpose of computing the arm’s length price and then benchmarking the same with the price of the international transaction. Hence, in the facts and circumstances

JAIPUR RUGS COMPANY PVT. LTD.,JAIPUR vs. DCIT, JAIPUR

Appeals are allowed for statistical purposes only

ITA 1124/JPR/2016[2009-10]Status: DisposedITAT Jaipur22 Jan 2019AY 2009-10
For Appellant: Shri Rajiv Sogani (CA)For Respondent: Shri Varinder Mehta (CIT-DR) &
Section 92CSection 92C(2)

transfer pricing is also not acceptable. Hence, we find that the matter has not been properly examined by the TPO or by the ld. CIT(A) to work out the correct methodology for the purpose of computing the arm’s length price and then benchmarking the same with the price of the international transaction. Hence, in the facts and circumstances

DCIT, JAIPUR vs. M/S JAIPUR RUGS COMPANY PVT. LTD., JAIPUR

Appeals are allowed for statistical purposes only

ITA 738/JPR/2012[2008-09]Status: DisposedITAT Jaipur22 Jan 2019AY 2008-09
For Appellant: Shri Rajiv Sogani (CA)For Respondent: Shri Varinder Mehta (CIT-DR) &
Section 92CSection 92C(2)

transfer pricing is also not acceptable. Hence, we find that the matter has not been properly examined by the TPO or by the ld. CIT(A) to work out the correct methodology for the purpose of computing the arm’s length price and then benchmarking the same with the price of the international transaction. Hence, in the facts and circumstances

DCIT, JAIPUR vs. JAIPUR RUGS COMPANY (P) LTD., JAIPUR

Appeals are allowed for statistical purposes only

ITA 1083/JPR/2016[2009-10]Status: DisposedITAT Jaipur22 Jan 2019AY 2009-10
For Appellant: Shri Rajiv Sogani (CA)For Respondent: Shri Varinder Mehta (CIT-DR) &
Section 92CSection 92C(2)

transfer pricing is also not acceptable. Hence, we find that the matter has not been properly examined by the TPO or by the ld. CIT(A) to work out the correct methodology for the purpose of computing the arm’s length price and then benchmarking the same with the price of the international transaction. Hence, in the facts and circumstances

VAIBHAV GLOBAL LIMITED,JAIPUR vs. DCIT, CC-4, JAIPUR

ITA 1144/JPR/2024[2020-21]Status: DisposedITAT Jaipur30 Jun 2025AY 2020-21
For Appellant: Shri Vinod Kumar Gupta, AdvFor Respondent: Shri Rajesh Ojha, CIT-DR
Section 115JSection 115QSection 143(3)Section 144C(13)Section 36(1)(va)

sections": [ "143(3)", "144C(13)", "144C(5)", "92D", "10D", "92C(3)", "92B", "92C", "115JB", "270A", "36(1)(va)", "115QA", "69C", "115QB", "10B(2)", "10C", "92", "10A" ], "issues": "The key issues involve the appropriateness of the transfer pricing

MANIRATNAM GEMS PVT. LTD.,BEAWAR vs. ACIT,C-2, AJMER

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

ITA 174/JPR/2021[2016-17]Status: DisposedITAT Jaipur13 Jul 2022AY 2016-17
For Appellant: Shri Amit Kothari, CAFor Respondent: Shri Sanjay Dhariwal, CIT
Section 143(3)Section 263Section 92Section 92E

section 92 or 92B with any specified associate concern nor had any transaction with specified person in domestic transactions, as such there was no requirement of any report being furnished in form 3CEB, u/s 92E of the Act. The provisions of Transfer Pricing