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139 results for “transfer pricing”+ Undisclosed Incomeclear

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Key Topics

Addition to Income81Section 143(3)69Section 6857Section 153A53Section 26331Section 10(38)30Section 153C29Section 14825Section 14724

SURYA SINGHAL,KOTA vs. ASSTT. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, JAIPUR, JAIPUR

In the result, the appeal of the assessee is allowed

ITA 928/JPR/2025[2019-20]Status: DisposedITAT Jaipur17 Sept 2025AY 2019-20
For Appellant: Shri Vijay Goyal, C.AFor Respondent: Sh. Gaurav Awasthi, JCIT-DR
Section 115BSection 132(4)Section 143(3)Section 250Section 69

undisclosed income but from\naccounted sources. Accordingly, the appellant did not include the amount of\nRs.11,00,000/- as income in the return of income filed for the relevant\n assessment year, effectively retracting the earlier surrender made under a\nmistaken belief. The department cannot take the benefit of this mistake of\nthe assessee. In this regard it is relevant

Showing 1–20 of 139 · Page 1 of 7

Survey u/s 133A18
Bogus/Accommodation Entry13
Unexplained Cash Credit13

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

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, KOTA vs. SH. NAVAL KISHORE, KOTA

ITA 456/JPR/2024[2015-16]Status: DisposedITAT Jaipur27 Sept 2024AY 2015-16
For Appellant: Sh. Mahendra Gargieya (Adv.) &For Respondent: Sh. Anil Dhaka (CIT)
Section 139Section 143Section 153ASection 234ASection 68

transferred \nthe profit even then, there is absolutely no evidence brought in record \nas to when and in what mariner such profit was paid to the appellant. \nSince the onus is on the Revenue, hence it is bound to prove the \nreceipt of income. \nThe argument of the appellant are considered. The claim of the \nappellant is contradictory

NAVAL KISHORE ,KOTA vs. ACIT DCIT, CENTRAL CIRCLE, KOTA, KOTA

ITA 205/JPR/2024[2015-16]Status: DisposedITAT Jaipur27 Sept 2024AY 2015-16
For Appellant: Sh. Mahendra Gargieya (Adv.) &For Respondent: Sh. Anil Dhaka (CIT)
Section 139Section 143Section 153ASection 234ASection 68

transferred\n\nthe profit even then, there is absolutely no evidence brought in record\nas to when and in what mariner such profit was paid to the appellant.\nSince the onus is on the Revenue, hence it is bound to prove the\nreceipt of income.\nThe argument of the appellant are considered. The claim of the\nappellant is contradictory

SHRI MADHO LAL SAINI,JAIPUR vs. ITO, WARD-2(3), JAIPUR

In the result, the appeals of the assessees are allowed

ITA 238/JPR/2020[2007-08]Status: DisposedITAT Jaipur06 Mar 2023AY 2007-08

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

For Appellant: Shri Rajeev Sogani (CA) &For Respondent: Shri S. Najmi (CIT)
Section 139(1)Section 147Section 148Section 151Section 250Section 54BSection 54FSection 69

undisclosed income would also be included, but in cases where the assessment or reassessment proceedings have already been completed and assessment orders have been passed determining the assessee s total income and such orders are subsisting at the time when the search or the requisition is made, there is no question of any abatement since no proceedings are pending

KAILASH CHAND MAHESHWARI,JAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX , JAIPUR

ITA 1463/JPR/2024[2015-16]Status: DisposedITAT Jaipur20 May 2025AY 2015-16

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Shri S. L. Poddar, AdvFor Respondent: Shri Rajesh Ojha, CIT-DR
Section 127Section 132Section 133ASection 144Section 153ASection 57Section 68Section 69C

income was not filed by the appellant. The assessment order had to be passed as per the above judgement. No application for filing and admission of additional evidences has been filed by the appellant along with any justification etc. The issue raised by the appellant regarding the contention that no incriminating material was unearthed in the course of search

SHRI AMBICA GARMENTS, JODHPUR,JODHPUR vs. ACIT, CENTAL CIRCLE-3, JAIPUR, JODHPUR

In the result, all appeals of the assessee are disposed off in terms of

ITA 59/JPR/2025[2017-18]Status: DisposedITAT Jaipur15 Oct 2025AY 2017-18
For Appellant: Shri Deepak Sharma, AdvFor Respondent: Mrs. Alka Gautam, CIT
Section 153ASection 250Section 68

Income-tax Act, 1961 1.1 As per the explicit and mandatory provisions enshrined under Section 153D of the Income-tax Act, 1961 (“the Act”), any Assessing Officer (“AO”) who is below Shri Ambika Garments vs. ACIT the rank of the Joint Commissioner of Income Tax (“JCIT”) is required to obtain prior approval u/s 153D by forwarding the draft assessment order

SANJAY KUMAR KARNANI,JAIPUR vs. ACIT, CENTRAL CIRCLE-3, JAIPUR, JAIPUR

In the result, all appeals of the assessee are disposed off in terms of

ITA 673/JPR/2025[2016-17]Status: DisposedITAT Jaipur15 Oct 2025AY 2016-17

Bench: AO on 12-04-2021 18. Reply filed before AO on 15-07-2021 19. Additional Written Submissions filed before CIT(A) for AY 2014-15 on 11-11-2024 20. Written Submissions filed before CIT(A) for AY 2014-15 21. Written Submissions filed before CIT(A) for AY 2015-16 on 10-10-2024 22. Written Submissions filed before CIT(A) for AY 2016-17 on 10-10-2024 23. Written Submissions filed before CIT(A) for AY 2017-18 on 15-10-2024 24. Written Submissions filed before CIT(A) for AY 2018-19 on 15-10-2024 25.

For Appellant: Shri Deepak Sharma, AdvFor Respondent: Mrs. Alka Gautam, CIT
Section 153ASection 250Section 68

Income-tax Act, 1961 1.1 As per the explicit and mandatory provisions enshrined under Section 153D of the Income-tax Act, 1961 (“the Act”), any Assessing Officer (“AO”) who is below Shri Ambika Garments vs. ACIT the rank of the Joint Commissioner of Income Tax (“JCIT”) is required to obtain prior approval u/s 153D by forwarding the draft assessment order

SHRI AMBICA GARMENTS, JODHPUR,JODHPUR vs. ACIT, CENTAL CIRCLE-3, JAIPUR, JAIPUR

In the result, all appeals of the assessee are disposed off in terms of

ITA 57/JPR/2025[2015-16]Status: DisposedITAT Jaipur15 Oct 2025AY 2015-16
For Appellant: Shri Deepak Sharma, AdvFor Respondent: Mrs. Alka Gautam, CIT
Section 153ASection 250Section 68

Income-tax Act, 1961 1.1 As per the explicit and mandatory provisions enshrined under Section 153D of the Income-tax Act, 1961 (“the Act”), any Assessing Officer (“AO”) who is below Shri Ambika Garments vs. ACIT the rank of the Joint Commissioner of Income Tax (“JCIT”) is required to obtain prior approval u/s 153D by forwarding the draft assessment order

SANJAY KUMAR KARNANI,JAIPUR vs. ACIT, CENTRAL CIRCLE-3, JAIPUR, JAIPUR

In the result, all appeals of the assessee are disposed off in terms of

ITA 672/JPR/2025[2015-16]Status: DisposedITAT Jaipur15 Oct 2025AY 2015-16

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Shri Deepak Sharma, AdvFor Respondent: Mrs. Alka Gautam, CIT
Section 153ASection 250Section 68

Income-tax Act, 1961 1.1 As per the explicit and mandatory provisions enshrined under Section 153D of the Income-tax Act, 1961 (“the Act”), any Assessing Officer (“AO”) who is below Shri Ambika Garments vs. ACIT the rank of the Joint Commissioner of Income Tax (“JCIT”) is required to obtain prior approval u/s 153D by forwarding the draft assessment order

SHRI AMBICA GARMENTS, JODHPUR,JODHPUR vs. ACIT, CENTRAL CIRCLE-3, JAIPUR, JAIPUR

In the result, all appeals of the assessee are disposed off in terms of

ITA 61/JPR/2025[2019-20]Status: DisposedITAT Jaipur15 Oct 2025AY 2019-20

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Shri Deepak Sharma, AdvFor Respondent: Mrs. Alka Gautam, CIT
Section 153ASection 250Section 68

Income-tax Act, 1961 1.1 As per the explicit and mandatory provisions enshrined under Section 153D of the Income-tax Act, 1961 (“the Act”), any Assessing Officer (“AO”) who is below Shri Ambika Garments vs. ACIT the rank of the Joint Commissioner of Income Tax (“JCIT”) is required to obtain prior approval u/s 153D by forwarding the draft assessment order

KIRAN FINE JEWELLERS PRIVATE LIMITED,JAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2,, JAIPUR

In the result ground no 2 raised by the assessee is allowed

ITA 648/JPR/2024[2017-18]Status: DisposedITAT Jaipur25 Feb 2025AY 2017-18

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Sh. S. R. Sharma, CA &For Respondent: Sh. P. P. Meena, CIT-Th. V.H
Section 115BSection 143(3)Section 145(3)Section 68Section 69A

undisclosed income found recorded in above page has been unearth during the course of search proceedings. Hence, the same is income from other source. Accordingly, the assessee was asked to explain why the same should not consider as unexplained cash credit u/s 68 of the Act, vide note sheet entry. In reply to the same, the assessee claimed that

DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-3, JAIPUR vs. M/S RIGID CONDUCTORS (RAJ.) PVT. LTD., JAIPUR

In the result, the appeals of the revenue stands dismissed

ITA 264/JPR/2022[2016-17]Status: DisposedITAT Jaipur24 May 2023AY 2016-17

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

Section 143(3)

transfer of capital asset. Also section 45(5) of the I.T.Act, 1961 is related to capital gain in case of compulsory acquisition of land which is applicable in this case. Hence, the assessee’s theory of ‘shifting of land’ is nowhere described nor application in case in view of the facts as narrated above. 2. The compensation received

DEPUTY COMMISSINER OF INCOME TAX, LIC BUILDING vs. M/S GEE VEE DEVELOPERS PVT. LTD., JAIPUR

In the result, the appeals of the revenue stands dismissed

ITA 267/JPR/2022[2016-17]Status: DisposedITAT Jaipur24 May 2023AY 2016-17

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

Section 143(3)

transfer of capital asset. Also section 45(5) of the I.T.Act, 1961 is related to capital gain in case of compulsory acquisition of land which is applicable in this case. Hence, the assessee’s theory of ‘shifting of land’ is nowhere described nor application in case in view of the facts as narrated above. 2. The compensation received

DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-3, JAIPUR vs. M/S CHOKHI DHANI DEVELOPERS PVT. LTD., JAIPUR

In the result, the appeals of the revenue stands dismissed

ITA 265/JPR/2022[2016-17]Status: DisposedITAT Jaipur24 May 2023AY 2016-17

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

Section 143(3)

transfer of capital asset. Also section 45(5) of the I.T.Act, 1961 is related to capital gain in case of compulsory acquisition of land which is applicable in this case. Hence, the assessee’s theory of ‘shifting of land’ is nowhere described nor application in case in view of the facts as narrated above. 2. The compensation received

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-3, JAIPUR vs. M/S VISION ESTATES PVT. LTD., JAIPUR

In the result, the appeals of the revenue stands dismissed

ITA 266/JPR/2022[2016-17]Status: DisposedITAT Jaipur24 May 2023AY 2016-17

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

Section 143(3)

transfer of capital asset. Also section 45(5) of the I.T.Act, 1961 is related to capital gain in case of compulsory acquisition of land which is applicable in this case. Hence, the assessee’s theory of ‘shifting of land’ is nowhere described nor application in case in view of the facts as narrated above. 2. The compensation received

INCOME TAX OFFICER , SIKAR vs. BHASKAR CHAUHAN, JAIPUR

In the result the appeal of the revenue in ITA no

ITA 868/JPR/2024[2017-18]Status: DisposedITAT Jaipur24 Jul 2025AY 2017-18

Bench: Him.

For Appellant: Shri S.L.Poddar, AdvFor Respondent: Mrs Alka Gautam, CIT-DR a
Section 143(3)Section 144Section 153CSection 251Section 69Section 69ASection 69C

undisclosed sources and added to the income of the assessee u/s 69A of the Income tax Act, 1961. The appellant submitted that the firm was maintaining two bank accounts during the year under consideration one is with Axis Bank and another one is Indusind Bank Limited. Total credits in Indusind Bank amounts to Rs.1,12,16,408. Total credits

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

undisclosed investment and was to be taken under Section 69 and tax computed u/s. 115BBE of the I.T. Act, 1961 and could not be taxed at normal rate. The Assessing Officer has erred by not taxing the sum of Rs. 22,62,143/- at special rate.” 12. That in response to the SCN, assessee submitted proper reply within the stipulated

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-4, JAIPUR vs. PAWAN KUMAR JHALANI, JAIPUR

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

ITA 966/JPR/2025[2019-20]Status: DisposedITAT Jaipur17 Nov 2025AY 2019-20

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Shri Rohan Sogani, CAFor Respondent: Mrs. Anita Rinesh, JCIT
Section 132(1)Section 153CSection 4

undisclosed income as well as other transactions of unaccounted safe/purchases of gold bullion. He also admitted that the 10 ITA Nos. 966/JP/2025 & CO No. 25/JP/2025 ACIT vs. Pawan Kumar Jhalani above transactions of unaccounted sale/purchases of gold bullion, brokerage income are not recorded in his regular books of accounts. Based on these digital evidences recovered during the post search analysis

MOHAN LAL ASHOK KUMAR SARAF,JAIPUR vs. DCIT CEN CIR 1, JAIPUR

In the result, the appeal of the assessee is allowed as indicated hereinabove

ITA 879/JPR/2024[2017-2018]Status: DisposedITAT Jaipur28 Nov 2024AY 2017-2018
For Appellant: Shri Ankit Totuka, AdvocateFor Respondent: Ms. Alka Gautam, CIT-DR
Section 143(3)Section 68

prices of gold were doubling or tripling after the next day or the jewellery would not have been available on the next day. The rush was at the Jewellers apparently due to the reason that some people wanted to buy jewellery in cash using the demonetised currency which they could not have deposited in the bank account as that