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21 results for “transfer pricing”+ Section 36(2)clear

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Key Topics

Section 143(3)50Section 26322Section 35A22Section 153A19Addition to Income19Section 1459Section 1489Section 145(3)7Deduction6

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

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

Showing 1–20 of 21 · Page 1 of 2

Disallowance6
Section 115B5
Natural Justice4

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

36 | P a g e 8.2.2 Su-Raj Diamond Dealers (P) Ltd. v/s PCIT (2020) 203 TTJ (Mumbai) 137 8.2.3 Nayek Paper Converters vs. ACIT (2005) 93 TTJ (Cal) 574 9. No valid assessment order in existence - Sec.263 Cannot be invoked 9.1 It is submitted that the law u/s 263 contemplates the existence of a legally valid order. If there

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

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

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

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

2,73,93,10,472/- declared gross loss of Rs 1,03,37,47,372/- (37.74%) and net loss of Rs.32,77,48,176/- (11.96%). On being asked it was submitted that contract receipts of the assessee- company during the year declined considerably to Rs.2,46,73.49.728/- from Rs 4,28,36,27,201/- as it was in immediately preceding

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

transfer to the specified business of machinery or plant previously used for any purpose; All assets were newly acquired for the hospital. (iii) where the business is of the nature The specified business was hospital referred to in sub-clause (iii) of clause (c) of sub-section (8), such business (iv) (ab) on or after the 1st day of April

ACIT, CENTRAL CIRCLE, BIKANER vs. M/S. MANOJ KUMAR VIPIN KUMAR , BIKANER

In the result, this appeal of the Revenue is dismissed

ITA 482/JODH/2018[2012-13]Status: DisposedITAT Jodhpur01 Feb 2021AY 2012-13

Bench: Shri Sandeep Gosain & Shri Manoj Kumar Aggarwala.C.I.T. Vs. M/S Manoj Kumar Vipin Kumar, Central Circle, 118, New Dhan Mandi, Bikaner. Bikaner. Pan No. Aarfm 0027 E

Section 131

36) which includes income from commodity market at Rs. 2.64 crores . iv) Statement of Shri Vipin Kumar, partner of assessee firm, recorded on 22.12.2016 wherein reply to question nos. 9, 10, 12, 17 to 26, reproduced at pages 11-13 of the order, he has explained the entire transaction and how Shri Kamal Agrawal, Director of M/s Swift

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

transfer to the\nspecified business of machinery or plant\npreviously used for any purpose;\nAll assets were newly acquired for the\nhospital.\n(iii) where the business is of the nature The specified business was hospital\nreferred to in sub-clause (iii) of clause (c)\nof sub-section (8), such business\n(iv) (ab) on or after

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

transfer to the\nspecified business of machinery or plant\npreviously used for any purpose;\nAll assets were newly acquired for the\nhospital.\n(iii) where the business is of the nature The specified business was hospital\nreferred to in sub-clause (iii) of clause (c)\nof sub-section (8), such business\n(iv) (ab) on or after

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

transferred are genuine. 12. The aforesaid verification is also being explained from following verification chart which tallies the investments as reflected in balance sheet of BWR Trust (PB No. 113), with addition wrongly made in the hands of Appellant taken up by the Ld. AO from the HBS Statement with the Trust Financials/documents. Verification Chart (Year ending 31st December

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

36,500/- made on account of cash deposit during demonetization period." 5. The appellant craves leave or reserves right to amend, modify, alter, add or forego any ground(s) of appeal at any time before or during the hearing of this appeal." Mewar Hospital Pvt. Ltd. vs. ACIT 3.2 The grounds of the appeal taken by the revenue in appeal

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

36,500/- made on account of cash deposit during demonetization period." 5. The appellant craves leave or reserves right to amend, modify, alter, add or forego any ground(s) of appeal at any time before or during the hearing of this appeal." Mewar Hospital Pvt. Ltd. vs. ACIT 3.2 The grounds of the appeal taken by the revenue in appeal

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

36,500/- made on account of cash deposit during demonetization period." 5. The appellant craves leave or reserves right to amend, modify, alter, add or forego any ground(s) of appeal at any time before or during the hearing of this appeal." Mewar Hospital Pvt. Ltd. vs. ACIT 3.2 The grounds of the appeal taken by the revenue in appeal

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

36,500/- made on account of cash deposit during demonetization period." 5. The appellant craves leave or reserves right to amend, modify, alter, add or forego any ground(s) of appeal at any time before or during the hearing of this appeal." Mewar Hospital Pvt. Ltd. vs. ACIT 3.2 The grounds of the appeal taken by the revenue in appeal

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

36,500/- made on account of cash deposit during demonetization period." 5. The appellant craves leave or reserves right to amend, modify, alter, add or forego any ground(s) of appeal at any time before or during the hearing of this appeal." Mewar Hospital Pvt. Ltd. vs. ACIT 3.2 The grounds of the appeal taken by the revenue in appeal

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

36,500/- made on account of cash deposit during demonetization period." 5. The appellant craves leave or reserves right to amend, modify, alter, add or forego any ground(s) of appeal at any time before or during the hearing of this appeal." Mewar Hospital Pvt. Ltd. vs. ACIT 3.2 The grounds of the appeal taken by the revenue in appeal

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

36,500/- made on account of cash deposit during demonetization period." 5. The appellant craves leave or reserves right to amend, modify, alter, add or forego any ground(s) of appeal at any time before or during the hearing of this appeal." Mewar Hospital Pvt. Ltd. vs. ACIT 3.2 The grounds of the appeal taken by the revenue in appeal

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

36,500/- made on account of cash deposit during demonetization period." 5. The appellant craves leave or reserves right to amend, modify, alter, add or forego any ground(s) of appeal at any time before or during the hearing of this appeal." Mewar Hospital Pvt. Ltd. vs. ACIT 3.2 The grounds of the appeal taken by the revenue in appeal

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

36,500/- made on account of cash deposit during demonetization period." 5. The appellant craves leave or reserves right to amend, modify, alter, add or forego any ground(s) of appeal at any time before or during the hearing of this appeal." Mewar Hospital Pvt. Ltd. vs. ACIT 3.2 The grounds of the appeal taken by the revenue in appeal