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16 results for “transfer pricing”+ Section 9(1)(vi)clear

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Key Topics

Section 143(3)46Section 153A19Addition to Income14Section 1459Section 145(3)7Section 2505Section 1325Section 685Section 115B5

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

Natural Justice5
Exemption3
Charitable Trust2

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

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

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 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

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

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

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

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)

vi) an entity making fresh application for approval under clause (23C) of section 10, for registration under section 12AA, for approval under section 80G shall be provisionally approved or registered for three years on the basis of application without detailed enquiry even in the cases where activities of the entity are yet to begin and then it has to apply

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

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

price of Rs.1,58,67,077/- under section 68 of the Act to the total income of the assessee. The Ld.AO also calculated the commission amount to Rs. 6,55,255/- and total amount comes to Rs.1,65,22,302/-. The Assessing Officer further added Rs.8,08,458/- related to 145(3) of the Act on account of increase

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

VI of the Black Money (Undisclosed Foreign Income and Assets) and imposition of Tax Act, 2015. 18. Under the facts and circumstances of the case and in law, the Ld. CIT(A) has erred in upholding the impugned additions u/s 69 and 69A of the Act in the hands of Appellant on account of alleged unexplained foreign assets. 19. Under

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

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

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