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32 results for “transfer pricing”+ Section 11(4)clear

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Key Topics

Section 143(3)61Section 26351Addition to Income28Section 153A19Section 35A16Section 1459Section 143(2)7Section 145(3)7Natural Justice

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

section 263 of the Act. 7. That on the facts and in the circumstances of the case, the Ld. Pr. CIT, Udaipur grossly erred in setting aside the assessment order passed by the ld. AO without any finding as to how the assessment order passed by the ld. AO is erroneous so as it prejudicial the interest of revenue

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 32 · Page 1 of 2

7
Disallowance7
Section 1326
Deduction5
ITA 268/JODH/2024[2017-18]Status: Disposed
ITAT Jodhpur
01 Apr 2025
AY 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

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 of its contention that the case of Goldstone Teleservices Ltd. was wrongly included by it in the list of comparables, which is actually not comparable

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

11 ITA 02/Jodh/2021 Secure Meters Ltd. Vs PCIT the provision of transfer pricing (sec 92 and related sections) is not applicable and the assessment order cannot be said to be erroneous and prejudicial to the interest of revenue on this aspect. The assessee further submitted that the observation that gross total income of Rs. 778,404,660 is less than

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

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

BHAMASHAH SUNDARLAL DAGA CHARITABLE TRUST,BIKANER vs. CIT - EXEMPTION, JAIPUR

The appeal of the assessee is allowed for statistical purpose

ITA 278/JODH/2023[2022-23 to 2026-27]Status: DisposedITAT Jodhpur10 Nov 2023

Bench: Shri Pavan Kumar Gadale & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita No.278/Jodh/2023 िनधा"रण वष" / Assessment Year : N.A. Bhamashah Sundarlal Daga The Commissioner Of Charitable Trust, V Income Tax-Exemption, Bagree Mohallan, S Jaipur. Bikaner – 334001. Pan: Aaetb1013C Appellant/ Assessee Respondent/ Revenue Assessee By Shri Suresh Ojha – Ar Revenue By Smt. Alka Rajvanshi Jain – Cit(Dr) Date Of Hearing 14/08/2023 Date Of Pronouncement 10/11/2023

Section 12Section 12A(1)(ac)Section 80GSection 80G(5)

11 Bhamashah Sundarlal Daga Charitable Trust [A] price shoots up with the result that the market price prevailing on the date of the sale exceeds the agreed price at which the property is sold by more than 15 per cent of such agreed price. This is not at all an uncommon case in an economy of rising prices

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)

price of Rs 30/- per share while face value per share is Rs 10/- only. b) Company has obtained fair market value report as per requirement of Rule 11UA and submitted the copy of it before Ld AO and Ld CIT A ( A copy of which is also enclosed Paper Book Page No from to ) . c) Ld AO made addition

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

ASHOK PANWAR HUF,JODHPUR vs. ACIT, CENTRAL CIRCLE-3, JODHPUR

In the result, both the appeals of the assesses ITA No

ITA 56/JODH/2024[2014-15]Status: DisposedITAT Jodhpur22 Aug 2025AY 2014-15

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

Section 10(38)Section 143(2)Section 143(3)Section 250Section 68

transfer forms APB page 35 to 37; (2) account statement of investment in shares and brokers account APB pages 38 to 39; (3) broker note for sale of shares during the year from Suresh Rathi Securities Pvt Ltd APB pages 40 to 56. The assessee purchased shares through banking channel on 09/03/2012 and the said scrip was sold in F.Y.2014-15

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

4 Shree Navkar Realinfra Pvt. Ltd. The assessee has submitted his reply through e-proceedings, which is taken on record. 4.1 On perusal of details filed revealed that the assessee has existing share capital of Rs. 70,20,000/- as on 31.03.2016 and during the year under consideration, issued 1,00,000 nos. of shares at face value

ACIT, CENTRAL CIRCLE-3, JODHPUR vs. BHANWAR SINGH RATHORE , PALI

Accordingly, it is held that the AO rightly added Rs.19,06,200/- u/s 68 of the IT. Act,1961. The appellant fails on this ground. The ground raised by the appellant regarding this issue is, hereby, ...

ITA 347/JODH/2019[2012-13]Status: DisposedITAT Jodhpur21 Dec 2020AY 2012-13

Bench: Hon’Ble Shri Sandeep Gosain, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am (Hearing Through Video Conferencing Mode) आयकरअपील सं./ I.T.A. No.347/Jodh/2019 ("नधा"रणवष" / Assessment Year: 2012-13) Acit-Central Circle-2 Bhanwar Singh Rathore बनाम/ Room No.68, Income Tax Office Bagh Niwas, Sumerpur Road Paota, C-Road Village-Mandali, Hemawas, Pali Vs. Jodhpur, Rajasthan- 342 006. Rajasthan-306 401 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Abepr-9925-L (अपीलाथ"/Appellant) (""यथ" / Respondent) : & C.O. No.02/Jodh/2020 (Arising Out Of Ita No.347/Jodh/2019 ("नधा"रणवष" / Assessment Year: 2012-13) Bhanwar Singh Rathore Acit-Central Circle-2 बनाम/ Bagh Niwas, Sumerpur Road Room No.68, Income Tax Office Village-Mandali, Hemawas, Pali Paota, C-Road Vs. Rajasthan-306 401 Jodhpur, Rajasthan- 342 006. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Abepr-9925-L (अपीलाथ"/Appellant) (""यथ" / Respondent) :

For Appellant: Shri Rajendra Jain (Advocate) & MsFor Respondent: Shri A.S. Yadav- Ld. Sr. DR
Section 143(3)

section 68 of the Act. 4. Agricultural income:-Rs. 44,00,000/- : The appellant claimed that the cash transaction of Rs.13,50,000/- on 21.05.2011, Rs.5,50,000/- on 03.09.2011, 4,00,000/- on 24.10.2011, 9,00,000/- on 25.10.2011, 2,00,000/- on 09.11.2011 and 6,00,000/- on 12.11.2011 was his agricultural receipts. Before me, the appellant furnished

SAMBHAV ENERGY LIMITED ,CHENNAI vs. ACIT, CENTRAL CIRCLE-1, JODHPUR

In the result, both the appeals filed by the assessee are treated as allowed for statistical purposes

ITA 258/JODH/2019[2014-15]Status: DisposedITAT Jodhpur02 Nov 2022AY 2014-15

Bench: Shri B. R. Baskaran & Shri Sandeep Gosain

transferred share application money to the assessee. Accordingly, he disallowed the interest claim of Rs. 3.00 crores made in A.Y 2013-14. The assessee had claimed interest expenditure of Rs.11.94 crores against the loan taken from M/s Adarsh Credit Co-operative Society Ltd in AY 2014-15. The AO disallowed interest expenditure of Rs. 11.94 crores on the very same

SAMBHAV ENERGY LIMITED ,CHENNAI vs. ACIT, CENTRAL CIRCLE-1, JODHPUR

In the result, both the appeals filed by the assessee are treated as allowed for statistical purposes

ITA 257/JODH/2019[2013-14]Status: DisposedITAT Jodhpur02 Nov 2022AY 2013-14

Bench: Shri B. R. Baskaran & Shri Sandeep Gosain

transferred share application money to the assessee. Accordingly, he disallowed the interest claim of Rs. 3.00 crores made in A.Y 2013-14. The assessee had claimed interest expenditure of Rs.11.94 crores against the loan taken from M/s Adarsh Credit Co-operative Society Ltd in AY 2014-15. The AO disallowed interest expenditure of Rs. 11.94 crores on the very same

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

11. The amounts of gross assets/investments and current account negative balance and net value of assets is clearly verifiable from the BWR Trust Financial statements and the CIT(A) has taken up the figures duly according to the books of accounts maintained by the Trust, thus there is no dispute over the source of money and the funds transferred

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

4 Non examination of unsecured loan from Shri Virendra Agarwal The assessee has not received any unsecured loan form Shri Virendra Agarwal as alleged by the PCIT .The Id AO made detailed query regarding cash creditors vide notice dated 2/7/18 (PB21) . Also called for personal statement of affairs of the assessee vide notice dated 5/1 l/2018(PB 66). The allegation

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

4,28,36,27,201/- as it was in immediately preceding year. The reasons for this down fall as is explained by the assessee reads as under : "Decrease in contract receipts is approximately 42.40% as compared to last year. All work contracts are allotted on the basis of tender system. It is further submitted that in this line of business

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

4. In the 1st common issue, the revenue has challenged deletion of the addition made on account of disallowance of deduction claimed u/s 35AD r.w.s. 80-IA of the Income-tax Act, 1961. The Ld. CIT(DR) submitted that the deduction claimed under section 35AD, has been disallowed by the Id. AO in the reassessment proceedings

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

4. Whether the Ld. CIT(A) is justified in deleting the disallowance made u/s 35AD by holding that with regard to the filing of 10CCB, the fact that the appellant had filed the same during the course of the assessment proceedings and before the final order of assessment was made. With the above reasoning, whether

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)

4 Smt. Jaya Mogra Circle-02, Udaipur vide order no. 15 of 2010-11 dated 28.01.2011 u/s 127 of the I.T. Act, 1961 by the Commissioner of Income Tax, Udaipur. Accordingly, the notices were sent to the assessee and the assessment was completed by making the addition of Rs. 39.70 lacs. The additions of Rs 39.70 lac on account

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

transferred out to certain other bank accounts belonging to M/s. Lakhpat Trading and Industry Pvt. Ltd. The submissions made are duly considered and the same were sent to the AO calling for Remand Report. The AO submitted the Remand Report vide letter dated 28.02.2024. The copy of Remand Report was forwarded to the appellant for itscomments and the comments