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10 results for “transfer pricing”+ Section 194clear

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Key Topics

Section 14711Section 143(3)10Addition to Income9Section 1488Unexplained Cash Credit8Capital Gains7Long Term Capital Gains7Section 685Section 143(2)

KALUBHAI DULABHAI GOLAVIYA,SURAT vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2, , SURAT

In the result, ground raised by the assessee is allowed

ITA 619/SRT/2018[2014-15]Status: DisposedITAT Surat30 Mar 2023AY 2014-15

Bench: Shri Pawan Singh, Jm &Dr. A.L.Saini, Am आयकर अपीलसं./It(Ss)A No.15 & Ita No.619/Srt/2018 (िनधा"रणवष" / Assessment Years: (2011-12 &2014-15) (Virtual Court Hearing) Shri Kalubhai Dulabhai Golaviya Deputy Commissioner Of Income-Tax, B/1-2, Jalaram Society, B/H. Central Circle-2, Aaykar Bhavan, Vs. Gurunagar Society, Varachha Majura Gate, Surat-395001 Road, Surat "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Ablpp 5116 A (अपीलाथ" /Appellant) (""थ" /Respondent)

For Appellant: Shri Ashwin K Parekh, C.AFor Respondent: Shri Ashok B.Koli, CIT-DR &
Section 132Section 143(2)Section 143(3)Section 153ASection 45(3)Section 54F

prices. The assessee had not developed the plots into houses or is not dealing in Real Estate. The intention of the assessee is not in the nature of “Adventure in the Nature of trade but land was held with an intention to construct farm house”. However, later on the city limit was increased and it was not allowed to construct

5
Disallowance5
Deduction4
Section 145(3)3

GIRDHARBHAI HARIBHAI GAJERA,SURAT vs. ITO(INTERNATIONAL TAXATION), SURAT

In the result, additional grounds raised by the assessee is allowed

ITA 143/SRT/2019[2015-16]Status: DisposedITAT Surat22 Feb 2023AY 2015-16

Bench: Shri Pawan Singh, Jm &Dr. A.L.Saini, Am आयकर अपील सं./Ita No.143/Srt/2019 (िनधा"रणवष" / Assessment Year: (2015-16) (Physical Court Hearing) Girdharbhai Haribhai Gajera Income Tax Officer 1,Vrushal Nagar, Opp. (International Taxation), 107, 1St Vs. Ktargam Police Station, Floor, Anavil Business Centre, Katargam Road, Surat-35004 Adajan-Hazira Road, Opp. Star Bazar, Adajan, Surat-395009 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Abepg 7339 M (Assessee ) (Respondent)

For Appellant: Shri Hiren R.Vepari, C.AFor Respondent: Shri Vinod Kumar, Sr-D.R
Section 142(1)Section 143(2)Section 143(3)Section 2(14)Section 271Section 45(2)

194 has held as under: “Section 45 of the Income-tax Act, 1961 -Capital gains – Chargeable as – Assessment, year 1994-95 – Where land was purchased in 1970, and after cloud of land ceiling laws, was cleared and other adjoining lands had been developed, it was decided to be sold in piecemeal by earmarking plots, nonetheless sale transaction would remain

RAVI MAHEXA,DAMAN AND DIU vs. INCOME TAX OFFICER, DAMAN WARD, DAMAN

ITA 195/SRT/2022[2017-18]Status: DisposedITAT Surat31 Jul 2023AY 2017-18

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita Nos.193 To 195/Srt/2022 Assessment Years: (2015-16 To 2017-18) (Physical Hearing) Ravi Mahexa, Vs. Income Tax Officer, Ward-5, 7Th 14/55, Dilipnagar Near Dilip Nagar Vapi, Fortune Square, Floor, 8Th Floor & 9Th Floor, Ii, Ground, Daman, Daman – 396210, Daman & Diu (Ut) Chala Road, Vapi-396191 Ravi Mahexa Income Tax Officer, Daman 14/55, Dilipnagar Near Dilip Nagar Ward, Daman Jevanji Ground, Daman, Daman & Diu (Ut) - Apartment, Kavi Khabardar 396210 Road, Daman-396210 Vapi "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Apkpm1888H (Assessee) (Respondent) Assessee By Shri P. M. Jagasheth, Ca Respondent By Shri Minal Kamble, Sr. Dr Date Of Hearing 19/07/2023 Date Of Pronouncement 31/07/2023

Section 115BSection 143(3)Section 145(3)Section 40ASection 68

price ultimately credited to profit & loss account) and on the other hand amounts received from above parties has also been added u/s. 68 of the Act. This view has been held by the Hon'ble Supreme Court in the case of CIT v. Devi Prasad Vishwanath Prasad [1969] 72 ITR 194 that "It is for the assessee to prove that

RAVI MAHEXA,DAMAN AND DIU vs. INCOME TAX OFFICER, DAMAN WARD, DAMAN

ITA 194/SRT/2022[2016-17]Status: DisposedITAT Surat31 Jul 2023AY 2016-17

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita Nos.193 To 195/Srt/2022 Assessment Years: (2015-16 To 2017-18) (Physical Hearing) Ravi Mahexa, Vs. Income Tax Officer, Ward-5, 7Th 14/55, Dilipnagar Near Dilip Nagar Vapi, Fortune Square, Floor, 8Th Floor & 9Th Floor, Ii, Ground, Daman, Daman – 396210, Daman & Diu (Ut) Chala Road, Vapi-396191 Ravi Mahexa Income Tax Officer, Daman 14/55, Dilipnagar Near Dilip Nagar Ward, Daman Jevanji Ground, Daman, Daman & Diu (Ut) - Apartment, Kavi Khabardar 396210 Road, Daman-396210 Vapi "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Apkpm1888H (Assessee) (Respondent) Assessee By Shri P. M. Jagasheth, Ca Respondent By Shri Minal Kamble, Sr. Dr Date Of Hearing 19/07/2023 Date Of Pronouncement 31/07/2023

Section 115BSection 143(3)Section 145(3)Section 40ASection 68

price ultimately credited to profit & loss account) and on the other hand amounts received from above parties has also been added u/s. 68 of the Act. This view has been held by the Hon'ble Supreme Court in the case of CIT v. Devi Prasad Vishwanath Prasad [1969] 72 ITR 194 that "It is for the assessee to prove that

RAVI MAHEXA,DAMAN AND DIU vs. INCOME TAX OFFICER, WARD 5, , VAPI

ITA 193/SRT/2022[2015-16]Status: DisposedITAT Surat31 Jul 2023AY 2015-16

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita Nos.193 To 195/Srt/2022 Assessment Years: (2015-16 To 2017-18) (Physical Hearing) Ravi Mahexa, Vs. Income Tax Officer, Ward-5, 7Th 14/55, Dilipnagar Near Dilip Nagar Vapi, Fortune Square, Floor, 8Th Floor & 9Th Floor, Ii, Ground, Daman, Daman – 396210, Daman & Diu (Ut) Chala Road, Vapi-396191 Ravi Mahexa Income Tax Officer, Daman 14/55, Dilipnagar Near Dilip Nagar Ward, Daman Jevanji Ground, Daman, Daman & Diu (Ut) - Apartment, Kavi Khabardar 396210 Road, Daman-396210 Vapi "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Apkpm1888H (Assessee) (Respondent) Assessee By Shri P. M. Jagasheth, Ca Respondent By Shri Minal Kamble, Sr. Dr Date Of Hearing 19/07/2023 Date Of Pronouncement 31/07/2023

Section 115BSection 143(3)Section 145(3)Section 40ASection 68

price ultimately credited to profit & loss account) and on the other hand amounts received from above parties has also been added u/s. 68 of the Act. This view has been held by the Hon'ble Supreme Court in the case of CIT v. Devi Prasad Vishwanath Prasad [1969] 72 ITR 194 that "It is for the assessee to prove that

RAMBILASH RAJARAM JAJOO,SURAT vs. INCOME TAX OFFICER WARD-2(2)(4), SURAT

In the result, assessee's appeal is allowed

ITA 552/SRT/2024[2011-12]Status: DisposedITAT Surat10 Feb 2025AY 2011-12
Section 143(3)Section 147Section 148Section 254(1)Section 68

transfer deed. Hence it is clear that there was\nno requirement of DEMAT during the period when the assessee purchased the shares\ni.e back in the year 2003. However, the assessee has submitted the holding Statement\nas on 31.03.2004 which reflects that the assessee had the shares of Global Capital\nMarket in possession and was held in its demat account

DAMODAR JAJOO,SURAT vs. INCOME TAX OFFICER, WD.2(2)(1), SURAT

In the result, appeal filed by the assessee (in ITA No

ITA 183/SRT/2021[2011-12]Status: DisposedITAT Surat06 Dec 2022AY 2011-12

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकरअपीलसं./Ita Nos.183 To 184/Srt/2021 ("नधा"रणवष" / Assessment Years: (2011-12) (Physical Court Hearing) Damodar Jajoo, Vs. The Ito, Ward-2(2)(1), 429-432, Golden Point, Nr. Bsnl Surat. Office, Falsawadi, Ring Road, Surat-395002, Gujarat. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aawpj4341H (Assessee) (Respondent) आयकरअपीलसं./Ita No.185/Srt/2021 ("नधा"रणवष" / Assessment Year: (2012-13) Jasodadevi Rajaram Jajoo, Vs. The Ito, Ward-2(2)(2), 429-432, Golden Point, Ring Surat. Road, Falsawadi, Begampura, Surat-395002, Gujarat. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaqpj7257E (Assessee) (Respondent) Assessee By Ms Richa Tosniwal, Ca & Shri Harishankar Tosniwal, Ca Shri J. K. Chandnani, Sr. Dr Respondent By Date Of Hearing 21/11/2022 Date Of Pronouncement 09/12/2022

Section 10(38)Section 143(2)Section 143(3)Section 147Section 148Section 69

transfer deed. Hence it is clear that there was no requirement of DEMAT during the period when the assessee purchased the shares i.e back in the year 2003. However, the assessee has submitted the holding Statement as on 31.03.2004 which reflects that the assessee had the shares of Global Capital Market in possession and was held in its demat account

JASODADEVI RAJARAM JAJOO,SURAT vs. INCOME TAX OFFICER WD.-2(2)(2), SURAT

In the result, appeal filed by the assessee (in ITA No

ITA 185/SRT/2021[2011-12]Status: DisposedITAT Surat06 Dec 2022AY 2011-12

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकरअपीलसं./Ita Nos.183 To 184/Srt/2021 ("नधा"रणवष" / Assessment Years: (2011-12) (Physical Court Hearing) Damodar Jajoo, Vs. The Ito, Ward-2(2)(1), 429-432, Golden Point, Nr. Bsnl Surat. Office, Falsawadi, Ring Road, Surat-395002, Gujarat. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aawpj4341H (Assessee) (Respondent) आयकरअपीलसं./Ita No.185/Srt/2021 ("नधा"रणवष" / Assessment Year: (2012-13) Jasodadevi Rajaram Jajoo, Vs. The Ito, Ward-2(2)(2), 429-432, Golden Point, Ring Surat. Road, Falsawadi, Begampura, Surat-395002, Gujarat. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaqpj7257E (Assessee) (Respondent) Assessee By Ms Richa Tosniwal, Ca & Shri Harishankar Tosniwal, Ca Shri J. K. Chandnani, Sr. Dr Respondent By Date Of Hearing 21/11/2022 Date Of Pronouncement 09/12/2022

Section 10(38)Section 143(2)Section 143(3)Section 147Section 148Section 69

transfer deed. Hence it is clear that there was no requirement of DEMAT during the period when the assessee purchased the shares i.e back in the year 2003. However, the assessee has submitted the holding Statement as on 31.03.2004 which reflects that the assessee had the shares of Global Capital Market in possession and was held in its demat account

DAMODAR JAJOO,SURAT vs. INCOME TAX OFFICER, WD.2(2)(1), SURAT

In the result, appeal filed by the assessee (in ITA No

ITA 184/SRT/2021[2012-13]Status: DisposedITAT Surat06 Dec 2022AY 2012-13

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकरअपीलसं./Ita Nos.183 To 184/Srt/2021 ("नधा"रणवष" / Assessment Years: (2011-12) (Physical Court Hearing) Damodar Jajoo, Vs. The Ito, Ward-2(2)(1), 429-432, Golden Point, Nr. Bsnl Surat. Office, Falsawadi, Ring Road, Surat-395002, Gujarat. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aawpj4341H (Assessee) (Respondent) आयकरअपीलसं./Ita No.185/Srt/2021 ("नधा"रणवष" / Assessment Year: (2012-13) Jasodadevi Rajaram Jajoo, Vs. The Ito, Ward-2(2)(2), 429-432, Golden Point, Ring Surat. Road, Falsawadi, Begampura, Surat-395002, Gujarat. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaqpj7257E (Assessee) (Respondent) Assessee By Ms Richa Tosniwal, Ca & Shri Harishankar Tosniwal, Ca Shri J. K. Chandnani, Sr. Dr Respondent By Date Of Hearing 21/11/2022 Date Of Pronouncement 09/12/2022

Section 10(38)Section 143(2)Section 143(3)Section 147Section 148Section 69

transfer deed. Hence it is clear that there was no requirement of DEMAT during the period when the assessee purchased the shares i.e back in the year 2003. However, the assessee has submitted the holding Statement as on 31.03.2004 which reflects that the assessee had the shares of Global Capital Market in possession and was held in its demat account

SUNITA JAJOO,SURAT vs. ITO WARD 2(2)(4), SURAT

In the result, assessee’s appeal is allowed

ITA 882/SRT/2024[2011-12]Status: DisposedITAT Surat10 Feb 2025AY 2011-12

Bench: Shri Pawan Singh & Shri Bijayananda Prusethआयकर अपील सं./Ita No. 552/Srt/2024 (Ay 2011-12) (Physical Court Hearing) Rambilash Rajaram Jajoo Income Tax Officer, Ward- 429-432, Golden Point, Falsawadi, 2(2)(4), Aaykar Bhawan, Majura बनाम Ring Road, Surat City, Gate, Opp. New Civil Hospital, Vs Surat-395 002 Surat-395 001 [Pan : Aampj 0040 K] अपीलाथ"/Appellant ""थ" /Respondent

Section 143(3)Section 147Section 148Section 254(1)Section 68Section 69C

transfer deed. Hence it is clear that there was no requirement of DEMAT during the period when the assessee purchased the shares i.e back in the year 2003. However, the assessee has submitted the holding Statement as on 31.03.2004 which reflects that the assessee had the shares of Global Capital Market in possession and was held in its demat account