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17 results for “transfer pricing”+ Section 91clear

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Key Topics

Section 143(3)48Section 153A17Addition to Income15Section 26312Section 1459Section 145(3)7Section 115B5Section 1324Natural 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

4
Section 2503
Disallowance3
Exemption2

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

SAMBHAV ENERGY LIMITED ,CHENNAI vs. ACIT, CENTRAL CIRCLE-1, JODHPUR

In the result, both the appeals filed by the assessee are treated as allowed for statistical purposes

ITA 258/JODH/2019[2014-15]Status: DisposedITAT Jodhpur02 Nov 2022AY 2014-15

Bench: Shri B. R. Baskaran & Shri Sandeep Gosain

transferred share application money to the assessee. Accordingly, he disallowed the interest claim of Rs. 3.00 crores made in A.Y 2013-14. The assessee had claimed interest expenditure of Rs.11.94 crores against the loan taken from M/s Adarsh Credit Co-operative Society Ltd in AY 2014-15. The AO disallowed interest expenditure of Rs. 11.94 crores on the very same

SAMBHAV ENERGY LIMITED ,CHENNAI vs. ACIT, CENTRAL CIRCLE-1, JODHPUR

In the result, both the appeals filed by the assessee are treated as allowed for statistical purposes

ITA 257/JODH/2019[2013-14]Status: DisposedITAT Jodhpur02 Nov 2022AY 2013-14

Bench: Shri B. R. Baskaran & Shri Sandeep Gosain

transferred share application money to the assessee. Accordingly, he disallowed the interest claim of Rs. 3.00 crores made in A.Y 2013-14. The assessee had claimed interest expenditure of Rs.11.94 crores against the loan taken from M/s Adarsh Credit Co-operative Society Ltd in AY 2014-15. The AO disallowed interest expenditure of Rs. 11.94 crores on the very same

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

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

transferred to discount account. (v) It was further contended that the payment being received from such patients is verifiable from the account statement of these parties. For certain patients who were admitted for long duration, discount was being given on request being made by them and also considering the financial position of the patients. Some companies and insurances companies

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

transferred to discount account. (v) It was further contended that the payment being received from such patients is verifiable from the account statement of these parties. For certain patients who were admitted for long duration, discount was being given on request being made by them and also considering the financial position of the patients. Some companies and insurances companies

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

transferred to discount account. (v) It was further contended that the payment being received from such patients is verifiable from the account statement of these parties. For certain patients who were admitted for long duration, discount was being given on request being made by them and also considering the financial position of the patients. Some companies and insurances companies

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

transferred to discount account. (v) It was further contended that the payment being received from such patients is verifiable from the account statement of these parties. For certain patients who were admitted for long duration, discount was being given on request being made by them and also considering the financial position of the patients. Some companies and insurances companies

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

transferred to discount account. (v) It was further contended that the payment being received from such patients is verifiable from the account statement of these parties. For certain patients who were admitted for long duration, discount was being given on request being made by them and also considering the financial position of the patients. Some companies and insurances companies

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

transferred to discount account. (v) It was further contended that the payment being received from such patients is verifiable from the account statement of these parties. For certain patients who were admitted for long duration, discount was being given on request being made by them and also considering the financial position of the patients. Some companies and insurances companies

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

transferred to discount account. (v) It was further contended that the payment being received from such patients is verifiable from the account statement of these parties. For certain patients who were admitted for long duration, discount was being given on request being made by them and also considering the financial position of the patients. Some companies and insurances companies

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

transferred to discount account. (v) It was further contended that the payment being received from such patients is verifiable from the account statement of these parties. For certain patients who were admitted for long duration, discount was being given on request being made by them and also considering the financial position of the patients. Some companies and insurances companies

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

transferred to discount account. (v) It was further contended that the payment being received from such patients is verifiable from the account statement of these parties. For certain patients who were admitted for long duration, discount was being given on request being made by them and also considering the financial position of the patients. Some companies and insurances companies

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

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

91- 95) 29 | P a g e "If the exercise of revision jurisdiction under s. 263 in respect of issues which formed subject-matter of reassessment after the original assessment was reopened, the commencement of the limitation would be with reference to the order of reassessment, but if the CIT has exercised the jurisdiction under s. 263 on an issue

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

91,592/- and the appellant gets a relief of Rs.3,34,818/-. This ground is therefore partly allowed. Grounds no.7-15 deal with the addition of Rs.1,11,60,612/- on account of sales made to M/s. Milap Enterprises. In the assessment order, the AO has observed that M/s. Milap Enterprises is a fictitious entity as there is no office existing