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19 results for “transfer pricing”+ Section 28clear

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Key Topics

Section 143(3)50Section 153A19Addition to Income16Section 26315Section 1459Section 145(3)7Section 115B7Section 1326Section 69A5

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

Section) New Delhi." That the appellant reserves its right to add, amend or alter the ground(s) of appeal on or before the date, the appeal is finally heard." 3. The brief facts related to this case are that the assessee-company e- filed its return of income for AY 2017-18 in form ITR-6 declaring NIL income with

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

Natural Justice5
Condonation of Delay2
Exemption2

In the result, appeal of the assessee is partly allowed

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

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

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

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 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 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

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

28-29 – para 5.19, 5.20. However, the Ld. AO has only disbelieved the entire explanation backed by documentary evidence by merely relying upon reference by FT & TR division. 7. The funds transferred through entries which have been alleged by the Ld. AO to be non-genuine is a clearly baseless allegation as the said fund has only been transferred from

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)

28-06-2019. 5. Apropos to the levy of the penalty on the enhancement so made the relevant finding of the ld. CIT(A) while ordering the penalty is reiterated here in below : 9. The CIT(A), after considering the assessee's submissions the remand recom furnished by the AO and the assessee's counter comments, found that the source

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

28,60,000 (71510 x 40) on account of non subscription of share on account of premium of Rs. 40 per share. Thus, the AO has not gone through the examination of the issue under consideration w.r.t the above provisions of the Act and due to which the assessment order in the case of assessee

ISLAUDDIN,JODHPUR vs. ITO-PHALODI, PHALODI

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

ITA 800/JODH/2024[2017-18]Status: DisposedITAT Jodhpur29 May 2025AY 2017-18
Section 115BSection 69A

transferred to some other account. The assessing officer has simply\nassumed that the assessee did not have any debtors since past many years and the cash\ndeposited in bank represented his undisclosed income/investment. He has not given any\ncognizance to the balance sheet of the preceding years (AY 2008-09 to AY 2016-17), in\nwhich the debtors were duly

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

28 of the assessment order. He also stated that during the course of assessment the registries of the flats sold during the year were obtained and payment details have been verified from the regular books of accounts and found that none of the cash transactions as reported in the seized pages match with receipts shown in the books of accounts

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

28 | P a g e of the Act cannot be considered as erroneous and prejudicial to the interest of revenue to subject it to proceeding under s.263 of the Act. If, at all, any order of the subordinate authority which could have been considered as erroneous and prejudicial to the interest of revenue in allowing assessee's claim of deduction

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

ITA 706/JODH/2024[2013-14]Status: DisposedITAT Jodhpur26 May 2025AY 2013-14
Section 132Section 145(3)Section 153ASection 234ASection 250

price\napprox 64.70% of actual sale consideration in its books of accounts and profit\ncalculated on this only and there is unbilled sale is the approx 35.30% of the actual\n/projected sales which is not recorded in the books of account and not offered for\ntaxation.He also stated that unbilled sales/on money is received in cash and out of\nbooks

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

section 145 of the Act to reject the books of account to estimate trading result which is contrary to settled principles of law. The Hon'ble Rajasthan High Court in the case of CIT v/s Gotan Lime Khanij Udyog reported in 256 ITR Page 243 held as under: - "That even if technically it is held that provisions