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

In the result, the appeal of the assessee in ITA no

Transfer Pricing provisions, On facts, charging interest on a loan granted, is different from charging interest on bills raised for services rendered. Both are not comparable. Thus, we agree with the submissions of the learned counsel for the assessee and delete these additions both on law as well as on merits" 4. In view of these facts and circumstances

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 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

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 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

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

Appeals are allowed for statistical purposes only

1,63,68,461.30. Accordingly, the TPO has proposed the total adjustment U/s 92CA of Rs. 2,60,74,702/-. 4. The assessee challenged the action of the TPO/A.O. before the ld. CIT(A). The ld. CIT(A) has accepted the method applied by the assessee for benchmarking of international transaction and held that the price of DCIT

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

Appeals are allowed for statistical purposes only

1,63,68,461.30. Accordingly, the TPO has proposed the total adjustment U/s 92CA of Rs. 2,60,74,702/-. 4. The assessee challenged the action of the TPO/A.O. before the ld. CIT(A). The ld. CIT(A) has accepted the method applied by the assessee for benchmarking of international transaction and held that the price of DCIT

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

Appeals are allowed for statistical purposes only

1,63,68,461.30. Accordingly, the TPO has proposed the total adjustment U/s 92CA of Rs. 2,60,74,702/-. 4. The assessee challenged the action of the TPO/A.O. before the ld. CIT(A). The ld. CIT(A) has accepted the method applied by the assessee for benchmarking of international transaction and held that the price of DCIT

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

Appeals are allowed for statistical purposes only

1,63,68,461.30. Accordingly, the TPO has proposed the total adjustment U/s 92CA of Rs. 2,60,74,702/-. 4. The assessee challenged the action of the TPO/A.O. before the ld. CIT(A). The ld. CIT(A) has accepted the method applied by the assessee for benchmarking of international transaction and held that the price of DCIT

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

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

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 were not applicable, and there was no requirement of any reference to TPO. The appellant also referred