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38 results for “transfer pricing”+ Section 1clear

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Key Topics

Section 143(3)61Section 26351Addition to Income30Section 35A22Section 153A19Section 194I16Section 201(1)12Deduction10Section 1459

RAVINDRA HERAEUS PRIVATE LIMITED,UDAIPUR vs. PR. CIT, UDIAPUR , UDAIPUR

In the result, both the appeals filed by the assessee are allowed in light of aforesaid directions

ITA 14/JODH/2021[2015-16]Status: DisposedITAT Jodhpur08 Sept 2021AY 2015-16
For Appellant: Shri Rajendra Jain (C.A.)For Respondent: Smt. Sanchita Kumar (CIT) a
Section 143(3)Section 263

Price (ALP) in an international transaction or specified domestic transaction is contained in sub-section (3) of section 92C of the Act which empowers Ravindra Heraeus Pvt. Ltd vs. Pr. CIT the Assessing officer to determine the ALP of the international transaction/specified domestic transaction in accordance with sub- sections (1) and (2). However, section 92CA(1) provides that where

SHRI SHESHAVTAR 1008 SHRI KALLAJI VEDPITH EVAM SHODH SANSTHAN,NIMBAHERA, CHITTORGARH vs. ITO EXEMPTION WARD, UDAIPUR, AAYKAR BHAWAN, UDAIPUR

In the result, appeal of the assessee is partly allowed

Showing 1–20 of 38 · Page 1 of 2

Section 1489
Disallowance8
Natural Justice7
ITA 268/JODH/2024[2017-18]Status: DisposedITAT Jodhpur01 Apr 2025AY 2017-18

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

For Appellant: Shri Sunil Surana, CA &For Respondent: Shri Karni Dan, Addl. CIT, Sr.DR
Section 115BSection 12ASection 142Section 143(1)Section 143(2)Section 234BSection 234DSection 250

1 also allowed the assessee to claim exclusion of certain cases from the list of comparables which were inadvertently included by it in its transfer pricing study. In view of the aforenoted discussion and the ratio of the these precedents, we direct the AO/TPO to examine the correctness of the figures placed on record by the assessee in support

SMT. JAYA MOGRA,UDAIPUR vs. DCIT, CENTRAL CIRCLE-2, UDAIPUR

In the result, appeal of the assessee in ITA No

ITA 333/JODH/2019[2009-10]Status: DisposedITAT Jodhpur20 Sept 2023AY 2009-10
Section 127Section 132Section 271(1)(c)

section 271(1)(c) of the Act. As regards the above argument of the assessee, it is relevant to note that estimate of such income was necessitated because the assessee failed to furnish information regarding purchase price of land and date of purchase. These are facts in the knowledge of the assessee and refusal to furnish the same leads

ABDUL KADIR,UDAIPUR vs. DCIT, CIRCLE-TDS, UDAIPUR

In the result, all the appeals of these assessees are allowed

ITA 175/JODH/2019[2016-17]Status: DisposedITAT Jodhpur05 Apr 2023AY 2016-17

Bench: Shri B. R. Baskaran & Dr. S. Seethalakshmi

Section 194Section 194ISection 194LSection 201(1)

price being less than Rs. 50,00,000/-, the appellant was not required to deduct TDS under section 194-IA of the Act. At this juncture, it would be appropriate to refer to the provisions of section 194-IA of the Act which reads as below:- “1 provisions of Section 194-IA (1) Any person, being a transferee, responsible

ABDUL RASHID,UDAIPUR vs. DCIT, CIRCLE TDS, UDAIPUR

In the result, all the appeals of these assessees are allowed

ITA 172/JODH/2019[2016-17]Status: DisposedITAT Jodhpur05 Apr 2023AY 2016-17

Bench: Shri B. R. Baskaran & Dr. S. Seethalakshmi

Section 194Section 194ISection 194LSection 201(1)

price being less than Rs. 50,00,000/-, the appellant was not required to deduct TDS under section 194-IA of the Act. At this juncture, it would be appropriate to refer to the provisions of section 194-IA of the Act which reads as below:- “1 provisions of Section 194-IA (1) Any person, being a transferee, responsible

ABDUL HAKIM,UDAIPUR vs. DCIT, CIRCLE - TDS, UDAIPUR

In the result, all the appeals of these assessees are allowed

ITA 173/JODH/2019[2016-17]Status: DisposedITAT Jodhpur05 Apr 2023AY 2016-17

Bench: Shri B. R. Baskaran & Dr. S. Seethalakshmi

Section 194Section 194ISection 194LSection 201(1)

price being less than Rs. 50,00,000/-, the appellant was not required to deduct TDS under section 194-IA of the Act. At this juncture, it would be appropriate to refer to the provisions of section 194-IA of the Act which reads as below:- “1 provisions of Section 194-IA (1) Any person, being a transferee, responsible

ABDUL AJEEJ,UDAIPUR vs. DCIT, CIRCLE-TDS, UDAIPUR

In the result, all the appeals of these assessees are allowed

ITA 174/JODH/2019[2016-17]Status: DisposedITAT Jodhpur05 Apr 2023AY 2016-17

Bench: Shri B. R. Baskaran & Dr. S. Seethalakshmi

Section 194Section 194ISection 194LSection 201(1)

price being less than Rs. 50,00,000/-, the appellant was not required to deduct TDS under section 194-IA of the Act. At this juncture, it would be appropriate to refer to the provisions of section 194-IA of the Act which reads as below:- “1 provisions of Section 194-IA (1) Any person, being a transferee, responsible

SECURE METERS LIMITED,UDAIPUR vs. PR. CIT, UDAIPUR

ITA 2/JODH/2021[2016-17]Status: DisposedITAT Jodhpur02 Sept 2021AY 2016-17

Bench: Shri Sandeep Gosain & Shri Vikram Singh Yadavassessment Year:2016-17 Secure Meters Limited, Vs. Pr.Cit, E-Class, Pratap Nagar Udaipur. Industrial Area, Udaipur-313001. Pan No. Aaccs 8785 M

Section 115JSection 143(3)Section 263Section 43ASection 92C

section 92E. This is not a situation in the case of the assessee and report was submitted and also during the assessment the same was submitted. The second situation where in previous assessments if any addition on account of transfer pricing adjustment of more than ten crores and addition being upheld in appellate proceedings is also not applicable

P I INDUSTRIES LIMITED ,UDAIPUR vs. PR. CIT, UDAIPUR, UDAIPUR

ITA 4/JODH/2021[2016-17]Status: DisposedITAT Jodhpur08 Sept 2021AY 2016-17

Bench: Shri Sandeep Gosain & Shri Vikram Singh Yadavassessment Year:2016-17 Pi Industries Limited, Vs. Pr.Cit, Udaisagar Road, Udaipur. Udaipur-313001. Pan No. Aabcp 2183 M

Section 115JSection 143(3)Section 263Section 32ASection 35(1)(iv)Section 80ISection 92C

Section 92E at all or has not disclosed the said transactions in the Accountant’s report filed; (b)where there has been a transfer pricing adjustment of ₹10 Crore or more in an earlier assessment year and such adjustment has been upheld by the judicial authorities or is pending in appeal; and (c)where search and seizure or survey operations

MEWAR HOSPITAL PVT. LTD. ,UDAIPUR vs. ACIT, CENTRAL CIRCLE-2, UDAIPUR

In the result the appeal of the assessee in ITA No

ITA 142/JODH/2022[2016-17]Status: DisposedITAT Jodhpur12 Oct 2023AY 2016-17
Section 143(3)Section 145Section 153A

price received by the seller of the goods for the acquisition of which it has already incurred the cast. It is the realisation of excess over the cost incurred that only forms part of the profit included in the consideration of sales. Therefore, unless there is a finding to the effect that investment by way of incurring cost in acquiring

MEWAR HOSPITAL PVT. LTD. ,UDAIPUR vs. ACIT, CENTRAL CIRCLE-2, UDAIPUR

In the result the appeal of the assessee in ITA No

ITA 144/JODH/2022[2018-19]Status: DisposedITAT Jodhpur12 Oct 2023AY 2018-19
Section 143(3)Section 145Section 153A

price received by the seller of the goods for the acquisition of which it has already incurred the cast. It is the realisation of excess over the cost incurred that only forms part of the profit included in the consideration of sales. Therefore, unless there is a finding to the effect that investment by way of incurring cost in acquiring

ACIT, CENTRAL CIRCLE-2, UDAIPUR, UDAIPUR vs. M/S MEWAR HOSPITAL PVT. LTD., UDAIPUR

In the result the appeal of the assessee in ITA No

ITA 167/JODH/2022[2016-17]Status: DisposedITAT Jodhpur12 Oct 2023AY 2016-17
Section 143(3)Section 145Section 153A

price received by the seller of the goods for the acquisition of which it has already incurred the cast. It is the realisation of excess over the cost incurred that only forms part of the profit included in the consideration of sales. Therefore, unless there is a finding to the effect that investment by way of incurring cost in acquiring

ACIT, CENTRAL CIRCLE-2, UDAIPUR, UDAIPUR vs. M/S MEWAR HOSPITAL PVT. LTD., UDAIPUR

In the result the appeal of the assessee in ITA No

ITA 168/JODH/2022[2017-18]Status: DisposedITAT Jodhpur12 Oct 2023AY 2017-18
Section 143(3)Section 145Section 153A

price received by the seller of the goods for the acquisition of which it has already incurred the cast. It is the realisation of excess over the cost incurred that only forms part of the profit included in the consideration of sales. Therefore, unless there is a finding to the effect that investment by way of incurring cost in acquiring

ACIT, CENTRAL CIRCLE-2, UDAIPUR, UDAIPUR vs. M/S MEWAR HOSPITAL PVT. LTD., UDAIPUR

In the result the appeal of the assessee in ITA No

ITA 169/JODH/2022[2018-19]Status: DisposedITAT Jodhpur12 Oct 2023AY 2018-19
Section 143(3)Section 145Section 153A

price received by the seller of the goods for the acquisition of which it has already incurred the cast. It is the realisation of excess over the cost incurred that only forms part of the profit included in the consideration of sales. Therefore, unless there is a finding to the effect that investment by way of incurring cost in acquiring

MEWAR HOSPITAL PVT. LTD. ,UDAIPUR vs. ACIT, CENTRAL CIRCLE-2, UDAIPUR

In the result the appeal of the assessee in ITA No

ITA 139/JODH/2022[2012-13]Status: DisposedITAT Jodhpur12 Oct 2023AY 2012-13
Section 143(3)Section 145Section 153A

price received by the seller of the goods for the acquisition of which it has already incurred the cast. It is the realisation of excess over the cost incurred that only forms part of the profit included in the consideration of sales. Therefore, unless there is a finding to the effect that investment by way of incurring cost in acquiring

MEWAR HOSPITAL PVT. LTD. ,UDAIPUR vs. ACIT, CENTRAL CIRCLE-2, UDAIPUR

In the result the appeal of the assessee in ITA No

ITA 143/JODH/2022[2017-18]Status: DisposedITAT Jodhpur12 Oct 2023AY 2017-18
Section 143(3)Section 145Section 153A

price received by the seller of the goods for the acquisition of which it has already incurred the cast. It is the realisation of excess over the cost incurred that only forms part of the profit included in the consideration of sales. Therefore, unless there is a finding to the effect that investment by way of incurring cost in acquiring

MEWAR HOSPITAL PVT. LTD. ,UDAIPUR vs. ACIT, CENTRAL CIRCLE-2, UDAIPUR

In the result the appeal of the assessee in ITA No

ITA 140/JODH/2022[2014-15]Status: DisposedITAT Jodhpur12 Oct 2023AY 2014-15
Section 143(3)Section 145Section 153A

price received by the seller of the goods for the acquisition of which it has already incurred the cast. It is the realisation of excess over the cost incurred that only forms part of the profit included in the consideration of sales. Therefore, unless there is a finding to the effect that investment by way of incurring cost in acquiring

MEWAR HOSPITAL PVT. LTD. ,UDAIPUR vs. ACIT, CENTRAL CIRCLE-2, UDAIPUR

In the result the appeal of the assessee in ITA No

ITA 141/JODH/2022[2015-16]Status: DisposedITAT Jodhpur12 Oct 2023AY 2015-16
Section 143(3)Section 145Section 153A

price received by the seller of the goods for the acquisition of which it has already incurred the cast. It is the realisation of excess over the cost incurred that only forms part of the profit included in the consideration of sales. Therefore, unless there is a finding to the effect that investment by way of incurring cost in acquiring

AJMER DEVELOPMENT AUTHORITY,AJMER vs. CIT(EXEMPTION)/ ITO (EXEMPTION), JAIPUR / JODHPUR

In the result, the stay application filed by the assessee is dismissed

ITA 89/JODH/2022[2012-13]Status: DisposedITAT Jodhpur22 Mar 2023AY 2012-13

Bench: Shri Kul Bharatshri Manish Borad

Section 143(3)Section 147Section 263

price of the product/service of the business and the institution is following the same principal by selling property. Builders or real estate developers do the same activity which is being done by the assessee such as purchase and sale of land at commercial principles and rates, development of land and 42 | P a g e sale by auction or otherwise

ASHIANA BUILDPROP PRIVATE LIMITED,UDAIPUR vs. DCIT, CENTRAL CIRCLE-1, UDIAPUR, UDAIPUR

ITA 709/JODH/2024[2016-17]Status: DisposedITAT Jodhpur26 May 2025AY 2016-17

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

Section 132Section 145(3)Section 153ASection 234ASection 250

prices by reducing the amenities which were originally offered. They have also made complaint about the goodwill/reputation of the company if the project remains uncompleted. Considering the good will of the company and reputation of the relevant Directors in the Real Estate Market the position of continuation of project with new name has been decided by the company. However looking