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18 results for “transfer pricing”+ Section 45(4)clear

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Key Topics

Section 143(3)50Addition to Income17Section 153A15Section 26312Section 1459Section 145(3)5Section 69A5Section 271(1)(c)4Section 132

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)

45 52 4. Vinayaka Microns (India) Pvt. Ltd. vs. Pr. CIT ITAT 53 58 Jaipur 5. Annu Agrotech Private Limited vs. Principal 59 86 Commissioner of Income Tax ITAT Jaipur 7. Per contra, ld. DR relied upon the orders of the lower authorities and raised the similar contention as recorded in the orders of the lower authorities and submitted that

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

4
Natural Justice3
Cash Deposit2

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

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

Price)- 3 Equity Funds 6206894 5814131 383555026 USD 4 Bonds Funds 1623759 1594271 100340190 12,375,698.34 5 Portfolio Funds 1000310 961969 61814130 (PB Page No. 6 Commodity Funds 96679 98549 5974279 113 Vol 1) 7 Alternative Funds 679202 668868 41971292 8 Dividend Right 56202 53852 3473007 Certificate 9 Hybrid On Shares 1140648 1111439 70486354 Total

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

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

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

45,99,322/- 3 BHK (Standard) 2040 2151/- 43,88,040 2,50,000 46,38,040/- 3 BHK (Standard) 2060 2151/- 44,31,060 2,50,000 46,81,060/- Ashiana Buildprop Pvt. Ltd., Udaipur. On the basis of above, the AO was of the view that the assessee has offered to sell flats in “Sanchi Enclave Project

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

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

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

45,000/- whereas the sales for the year\nbeing Rs.19,93,963/- only. The AO has overlooked the fact that the assessee also had\ndebtors of Rs.13,37,552/- as on 31.03.2015, in addition to agricultural receipts of Rs.\n10,69,442/- and rental receipts of Rs.1,20,000/-. The AO has also expressed a doubt that\nthe return