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29 results for “transfer pricing”+ Section 9(1)(v)clear

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Key Topics

Section 143(3)59Section 26345Addition to Income25Section 153A19Section 1459Section 35A8Section 145(3)7Section 1326Natural Justice

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 29 · Page 1 of 2

6
Disallowance6
Section 685
Exemption4

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

1. The impugned order u/s 263 of the I T Act, 1961 passed by the ld. Principal Commissioner of Income Tax, Udaipur is patently invalid, void, contrary to the provisions of law and also contrary to facts, material existing on records. 2. The ld. PCIT has erred in holding that the original assessment order dated 19.12.2018 passed by the Assessing

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)

transfer of land, simultaneously, action for imposition of penalty u/s 271(1)(c) for concealment of particulars of income was initiated by issue of notice u/s 271(1)(c) on dated 18-09-2018. 1.3 Since, the appellant has not preferred an appeal against said enhancement order of CIT (A) before the Hon’ble ITAT i.e. First appellate Authority

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

1) had been duly and fully complied with and all the details and information were duly submitted and examined during the course of assessment proceedings. 8. The assessee replying on the decision of Hon’ble Delhi High Court in the case of CIT Vs. Vikas Polymers (2010) 236 CTR (Del) 476 mentioned that mere absence of the reference

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

9. Apropos to the ground no. 1 the bench observed that the assessment year under consideration is A.Y. 2017-18. The assessee has filed the return of income for the year on 28.08.2017 and as on the date of search time limit to issue the notice u/s. 143(2) was not expired and therefore, ground no. 1 raised

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

9. Apropos to the ground no. 1 the bench observed that the assessment year under consideration is A.Y. 2017-18. The assessee has filed the return of income for the year on 28.08.2017 and as on the date of search time limit to issue the notice u/s. 143(2) was not expired and therefore, ground no. 1 raised

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

9. Apropos to the ground no. 1 the bench observed that the assessment year under consideration is A.Y. 2017-18. The assessee has filed the return of income for the year on 28.08.2017 and as on the date of search time limit to issue the notice u/s. 143(2) was not expired and therefore, ground no. 1 raised

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

9. Apropos to the ground no. 1 the bench observed that the assessment year under consideration is A.Y. 2017-18. The assessee has filed the return of income for the year on 28.08.2017 and as on the date of search time limit to issue the notice u/s. 143(2) was not expired and therefore, ground no. 1 raised

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

9. Apropos to the ground no. 1 the bench observed that the assessment year under consideration is A.Y. 2017-18. The assessee has filed the return of income for the year on 28.08.2017 and as on the date of search time limit to issue the notice u/s. 143(2) was not expired and therefore, ground no. 1 raised

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

9. Apropos to the ground no. 1 the bench observed that the assessment year under consideration is A.Y. 2017-18. The assessee has filed the return of income for the year on 28.08.2017 and as on the date of search time limit to issue the notice u/s. 143(2) was not expired and therefore, ground no. 1 raised

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

9. Apropos to the ground no. 1 the bench observed that the assessment year under consideration is A.Y. 2017-18. The assessee has filed the return of income for the year on 28.08.2017 and as on the date of search time limit to issue the notice u/s. 143(2) was not expired and therefore, ground no. 1 raised

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

9. Apropos to the ground no. 1 the bench observed that the assessment year under consideration is A.Y. 2017-18. The assessee has filed the return of income for the year on 28.08.2017 and as on the date of search time limit to issue the notice u/s. 143(2) was not expired and therefore, ground no. 1 raised

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

9. Apropos to the ground no. 1 the bench observed that the assessment year under consideration is A.Y. 2017-18. The assessee has filed the return of income for the year on 28.08.2017 and as on the date of search time limit to issue the notice u/s. 143(2) was not expired and therefore, ground no. 1 raised

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

V is well settled Law that assessee can challenge the validity of the reassessment proceedings in the collateral proceedings (relating to examination of validity of order passed) under s. 263 of the IT Act. We rely upon the order of Tribunal, Mumbai Bench in the case of Westlife Development Ltd. vs. Principal CIT (2016) 49 ITR (Trib) 406 (Mumbai

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 1

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

9,15,77,230/- 25,94,25,580/- On this Annexure-C and table, the AO asked the explanation of the assessee as to why the income may assessee company may not be determined on the basis of the actual sales as calculated in the above table for the respective years. In response thereto the assessee has filed the detailed

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

v) as per this office notice for hearing dated 29.12.2020. Thus, it appears that the assessee has nothing to offer as regard the issue of disproportionate allotment of shares. Hence, necessary action is called for in view of the provisions of section 56(2)(vii) / 56(2)(viia). Further, also no explanation has been offered as regard the point

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)

v. Surat Art Silk Cloth Manufacturers Association [1980] 121 ITR 7 Bhamashah Sundarlal Daga Charitable Trust [A] l/[1980] 2 Taxman 501, where the speech made by the Finance Minister, while introducing the exclusionary clause in section 2(15) of the Act, was relied upon by the Court for the purpose of ascertaining what was the reason for introducing that

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, 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

Transfer (DBFOT) Basis Notice by the concessionaire for payment of compensation on account of delay events, additional works/change of scope and breach of contract by the authority." In view of the facts furnished by the assessee, the amount of Rs.1,72,77,91,273/- shown in the ITR as other income, was treated as contract receipts of the assessee which