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31 results for “transfer pricing”+ Section 10(20)clear

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Key Topics

Section 143(3)59Section 26351Addition to Income25Section 35A24Section 153A19Section 194I16Section 201(1)12Section 1459Section 1489

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

20. The Instruction of 2016 provides for mainly two categories of cases in which reference can be made by the AO to the TPO for the ALP determination. The first category consists of the cases that are selected for scrutiny on the basis of "transfer pricing risk parameters" and second category comprises of cases that are selected for scrutiny

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

ITA 2/JODH/2021[2016-17]Status: DisposedITAT Jodhpur

Showing 1–20 of 31 · Page 1 of 2

Deduction9
Disallowance6
Natural Justice5
02 Sept 2021
AY 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

10 ITA 02/Jodh/2021 Secure Meters Ltd. Vs PCIT with underlying details. Similarly an amount of Rs 1.12 crores, which was not recoverable from the customers was written off during the year and charged to the profit and loss account, the reply of which was submitted vide letter dated 28.9.2018 with details to AO. 15. In regard to the foreign exchange

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

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

20 Lakh, was made hence no further addition was permissible u/s 147. The same was upheld by the Hon'ble High Court holding as under: "14. For exercise of power under s. 263, it is mandatory that the order passed by the AO should be erroneous and prejudicial to the interest of the Revenue. In the present case

INDU BALA PORWAL,UDAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRE CIRCLE-1, UDAIPUR, UDAIPUR

In the result, ground no 5, 9 and 11 appeal is also allowed in favor as indicated above

ITA 173/JODH/2023[2014-15]Status: DisposedITAT Jodhpur18 Jun 2025AY 2014-15

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

Section 132Section 153Section 153ASection 250

section 153A of the Act and also contended that the additions were wrongly made in hands of the Assessee merely on the basis of bank accounts or information in 10 Indu Bal Porwal vs. DCIT Central Circle-1, Udaipur relating to accounts, wherein she is just authorized signatory and entire asset/income belong to BWR Trust, which is family trust formed

PATEL MINERALS PVT. LTD. ,UDAIPUR vs. ACIT, CIRCLE-1, UDAIPUR

In the result, the appeal of the assessee is allowed

ITA 22/JODH/2024[2015-16]Status: DisposedITAT Jodhpur02 Jan 2025AY 2015-16

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

Section 142Section 143(2)Section 143(3)Section 56Section 56(2)(viib)

10 and @ premium of Rs 20 per share at total consideration of Rs 51,00,000/- including premium received for Rs 34,00,000/- during the year. As there was no business activity during the year as per submission filed, assessee was asked to justify the premium as per section 56(2)(viib) of the Act and rule 11UA

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

SUKHDEV CHAYAL,BIKANER vs. PCIT-1,, JODHPUR

In the result, this appeal of the assessee is allowed

ITA 26/JODH/2021[2016-17]Status: DisposedITAT Jodhpur07 Oct 2021AY 2016-17

Bench: Shri Sandeep Gosain & Shri Vikram Singh Yadavassessment Year: 2016-17 Sukhdev Chayal, Vs. Pr.Cit-1, Near Ratan Sagar Well, Jodhpur. Bikaner. Pan No. Afjpc 9250 J

Section 143(3)Section 263

transfer from the old accounts. As per the ld. AR, the background of agriculture land at khara bypass 0.83 hectare and land at khara 3.56 hectare has already been deliberated upon in length at point no. 2 of this letter. Ld. AR submitted that these two are basically offset 18 ITA 26/Jodh/2021 Sukhdev Chayal Vs PCIT accounts which cot debited

SUNITA AGARWAL,BIKANER vs. PCIT-1, JODHPUR

In the result, this appeal of the assessee is allowed

ITA 25/JODH/2021[2016-17]Status: DisposedITAT Jodhpur07 Oct 2021AY 2016-17

Bench: Hon’Ble Sh. Sandeep Gosain & Hon’Ble Sh. Vikram Singh Yadavassessment Year: 2016-17 Sunita Agarwal, Vs. Pr.Cit-1, 98, Industrial Area, Jodhpur. Bikaner. Pan No. Aeopa 9467 R

Section 115Section 131Section 143(3)Section 263

transfer entry from Individual Balance Sheet to the consolidated/Merged Balance Sheet of the Proprietorship concern M/s Yogesh Enterprises. All the bank statements of the assessee are on record and in case there had been any receipt of unsecured loan from Virendra Agarwal then definitely it would have been shown therein. Our attention was also drawn to the statement containing

ACIT, PAOTA C ROAD vs. VARAHA INFRA LIMITED, PAOTA B ROAD

In the result, the appeal of the revenue is dismissed

ITA 160/JODH/2024[2017-18]Status: DisposedITAT Jodhpur01 Jan 2025AY 2017-18

Bench: Dr. S. Seethalakshmi & Shri Rathod Kamlesh Jayantbhaithe Acit Vs M/S. Vardha Infra Ltd. Room No. 215, Aayakar Bhawan 6 Jalam Vilas Scheme Paota C Road, Jodhpur Paota B Road, Jodhpur (Appellant) (Respondent) Pan No. Aaccv 7972 K

Section 142(1)Section 143(2)Section 143(3)Section 40

prices are quoted yielding lower profits. Moreover, cost of construction and other expanses keep on increasing Various contracts were required to be completed within strict time frame failing which contractual penalties were also too high. Besides these factors, the assessee-company took some of the projects on sub-contract basis on low profit margins." 3.2 On perusal of the audited

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)

10,75,000/- Profit Rs. 21,45,000/-" 12. During the course of hearing of appeal the A.R of the appellant agreed to the estimation of business profit on sale of land at Badl by the CIT(A) at Rs 21,45,000/-. 13. Accordingly, the CIT(A) directed the AO to make an addition

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE 1, JODHPUR , JODHPUR vs. JODHPUR HEALTHCARE PVT. LTD., JODHPUR

In the result, the revenue appeals in ITA Nos

ITA 545/JODH/2024[2018-19]Status: DisposedITAT Jodhpur26 Jun 2025AY 2018-19

Bench: Dr. Mitha Lal Meena, Hon'Ble & Anikesh Banerjee, Hon'Ble

Section 139Section 148Section 35ASection 801A(7)Section 80J

10. The CIT(A) has extensively dealt with this issue in his order and considered the various contention raised by the AO and also the submissions made by the assessee during the appellate proceedings. The summary of his findings given in the order for A.Y. 2016-17 are reproduced as under: "The submissions of the appellant has been carefully perused

ASSTT. COMMISSIONER OF INCOME-TAX, CIRCLE-1, JODHPUR , JODHPUR vs. JODHPUR HEALTHCARE PVT. LTD., JODHPUR

In the result, the revenue appeals in ITA Nos

ITA 544/JODH/2024[2017-18]Status: DisposedITAT Jodhpur26 Jun 2025AY 2017-18

Bench: Dr. Mitha Lal Meena, Hon'Ble & Anikesh Banerjee, Hon'Ble

Section 139Section 148Section 35ASection 801A(7)Section 80J

10. The CIT(A) has extensively dealt with this issue in his order and considered the various contention raised by the AO and also the submissions made by the assessee during the appellate proceedings. The summary of his findings given in the order for A.Y. 2016-17 are reproduced as under: "The submissions of the appellant has been carefully perused

ASSTT. COMMISSIONER OF INCOME-TAX, CIRCLE-1, JODHPUR , JODHPUR vs. JODHPUR HEALTHCARE PVT. LTD., JODHPUR

In the result, the revenue appeals in ITA Nos

ITA 541/JODH/2024[2016-17]Status: DisposedITAT Jodhpur26 Jun 2025AY 2016-17

Bench: Dr. Mitha Lal Meena, Hon'Ble & Anikesh Banerjee, Hon'Ble

Section 139Section 148Section 35ASection 801A(7)Section 80J

10. The CIT(A) has extensively dealt with this issue in his order and considered the various contention raised by the AO and also the submissions made by the assessee during the appellate proceedings. The summary of his findings given in the order for A.Y. 2016-17 are reproduced as under: "The submissions of the appellant has been carefully perused

SHREE NAVKAR REALINFRA PRIVATE LIMITED,BHILWARA vs. PCIT, UDAIPUR

In the result, appeal of the assessee is allowed

ITA 133/JODH/2022[2017-18]Status: DisposedITAT Jodhpur24 Aug 2023AY 2017-18

Bench: Or At The Time Of Hearing Of This Appeal.”

Section 142(1)Section 143(2)Section 143(3)Section 263

20,000/- as on 31.03.2016 and during the year under consideration, issued 1,00,000 nos. of shares at face value of Rs. 10/- per share and also at premium of Rs. 40/- per share. Thus, the assessee, during the year under consideration, received share capital of Rs. 10,00,000/- and share premium of Rs.40,00,000/-. To verify

LAKHPAT TRADING AND INDUSTRYS PVT. LTD.,JODHPUR vs. ACIT, CIRCLE-3, JODHPUR

In the result, the appeal of the assessee is allowed

ITA 600/JODH/2025[2017-18]Status: DisposedITAT Jodhpur26 Feb 2026AY 2017-18

Bench: Dr. Mitha Lal Meena, Hon’Ble & Shri Sudhir Pareek, Hon’Blelakhpat Trading & Acit, Circle-3 Industryspvt. Ltd. Jodhpur G-72/73 79/80, 1St Phase, Boranada, Jodhpur - 342001 Pan No. Aaccl 5668 C Assessee By Shri Rajendra Jain, Advocate & Smt. Raksha Birla, Ca (Physical) Smt. Runi Pal, Cit-Dr (Virtual) Revenue By Date Of Hearing 29.01.2026. Date Of Pronouncement 26.02.2026. Order Dr. Mitha Lal Meena, A.M.: This Appeal Is Filed By Assessee Against The Order Of National Faceless Appeal Centre, Delhi [Hereinafter Referred To As Nfac/ Cit(A)] Dated 26.06.2025 With Respect To Assessment Year 2017-18 Challenging Therein The Rejection Of Its Books Of Accounts U/S 145(3), Estimation Of Income & Reducing Genuine Sales.

Section 115BSection 145(3)Section 68Section 69C

20. That petitioner may kindly be permitted to raise any addition or alternative ground at or before the time of hearing. 21. The petitioner prays for justice and relief. 3. In Ground No. 1 to 6, the assessee has challenged the rejection of books of accounts and applications of provisions of Section 145(3) of the Act in applying profit

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

20,000/- upon which there was no deduction of any TDS and therefore, these payments of Rs. 6,45,300/- were disallowed as per provisions of section 40(a)(ia) and 40A(3) of IT Act, 1961 during the year under consideration. (v) For the sake of clarity, Section 40(a)(in) of the Act is reproduced as under: “Section