THE ASSTT. COMMISSIONER OF INCOME TAX, JALANDHAR vs. M/S BROADWAY OVERSEAS LTD., JALANDHAR

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

Transfer Pricing Officer could not have taken cognizance suo moto of any international transaction for adjustment in the arm's length price u/s 92CA of the Income Tax Act, 1961 because no reference was made for the aforesaid transaction 9 I.T.A. Nos. 477 & CO 32/Asr/2015 & Ors Asstt. CIT v. Broadways Overseas Ltd. & Ors 4. That the appellant craves leave

THE ASSTT. COMMISSIONER OF INCOME TAX, JALANDHAR vs. M/S BROADWAYS OVERSEAS LTD, JALANDHAR

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

Transfer Pricing Officer could not have taken cognizance suo moto of any international transaction for adjustment in the arm's length price u/s 92CA of the Income Tax Act, 1961 because no reference was made for the aforesaid transaction 9 I.T.A. Nos. 477 & CO 32/Asr/2015 & Ors Asstt. CIT v. Broadways Overseas Ltd. & Ors 4. That the appellant craves leave

THE ASSTT. COMMISSIONER OF INCOME TAX, JALANDHAR vs. M/S BROADWAY OVERSEAS LTD., JALANDHAR

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

Transfer Pricing Officer could not have taken cognizance suo moto of any international transaction for adjustment in the arm's length price u/s 92CA of the Income Tax Act, 1961 because no reference was made for the aforesaid transaction 9 I.T.A. Nos. 477 & CO 32/Asr/2015 & Ors Asstt. CIT v. Broadways Overseas Ltd. & Ors 4. That the appellant craves leave

THE ASSTT. COMMISSIONER OF INCOME TAX, JALANDHAR vs. M/S BROADWAY OVERSEAS LTD., JALANDHAR

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

Transfer Pricing Officer could not have taken cognizance suo moto of any international transaction for adjustment in the arm's length price u/s 92CA of the Income Tax Act, 1961 because no reference was made for the aforesaid transaction 9 I.T.A. Nos. 477 & CO 32/Asr/2015 & Ors Asstt. CIT v. Broadways Overseas Ltd. & Ors 4. That the appellant craves leave

BRODAWAYS OVERSEAS LIMITED,JALANDHAR vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1, JALANDHAR

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

Transfer Pricing Officer could not have taken cognizance suo moto of any international transaction for adjustment in the arm's length price u/s 92CA of the Income Tax Act, 1961 because no reference was made for the aforesaid transaction 9 I.T.A. Nos. 477 & CO 32/Asr/2015 & Ors Asstt. CIT v. Broadways Overseas Ltd. & Ors 4. That the appellant craves leave

THE ASSTT. COMMISSIONER OF INCOME TAX, JALANDHAR vs. M/S BROADWAY OVERSEAS LTD., JALANDHAR

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

Transfer Pricing Officer could not have taken cognizance suo moto of any international transaction for adjustment in the arm's length price u/s 92CA of the Income Tax Act, 1961 because no reference was made for the aforesaid transaction 9 I.T.A. Nos. 477 & CO 32/Asr/2015 & Ors Asstt. CIT v. Broadways Overseas Ltd. & Ors 4. That the appellant craves leave

SATIA INDUSTRIES LIMITED,MUKTSAR vs. DCIT/ACIT CIRCLE I, BATHINDA, BATHINDA

In the result, the appeal of the assessee is partly allowed

Bench: Dr. M. L. Meena & Sh. Udayan Dasgupta

transferring manufactured electricity from C.P.P. unit to its other unit including electricity tax levied by State Electricity Board was price ordinarily prevailing in open market, and, therefore, Commissioner (Appeals) was not justified in disallowing

M/S GURU NANAK RICE MILLS,NAKODAR vs. DY. COMMISSIONER OF INCOME TAX, NEW DELHI

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Shri Udayan Dasgupta, Jm 1. आयकर अपील सं. / Ita No.103/Asr/2019 (िनधा"रण वष" / Assessment Year: 2013-14) & 2. आयकर अपील सं. / Ita No.104/Asr/2019 (िनधा"रण वष" / Assessment Year: 2013-14) & 3. आयकर अपील सं. / Ita No.105/Asr/2019 (िनधा"रण वष" / Assessment Year: 2014-15) M/S Guru Nanak Rice Mills Ito बनाम/ Vpo Pandori Khas Nakodar (Punjab) - 144040 Vs. Nakodar (Punjab) - 144040 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aadfg-3256-H (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Sh. Ashray Sarna (Ca) – Ld. Ar ""थ"कीओरसे/Respondent By : Sh. Farat Khan (Cit) – Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 04-02-2026 घोषणाकीतारीख /Date Of Pronouncement 05-02-2026 : आदेश / O R D E R Manoj Kumar Aggarwal () 1. In These Appeals, The Assessee Assails Confirmation Of Quantum Additions As Well As Confirmation Of Penalty U/S 271G. First, We Take Up Quantum Appeal Ita No.103/Asr/2019 Which Arises Out Of An Order

Transfer Pricing (TP) Adjustment for Rs.413.72 Lacs as well as quantum additions of Rs.83 Lacs, Rs.35,924/- and Rs.28,683/-. The only prayer of Ld. AR is to set aside the matter before lower authorities which has been opposed by Ld. CIT-DR. Having heard rival submissions and upon perusal of case records, our adjudication would be as under

M/S GURU NANAK RICE MILLS,NAKODAR vs. ASSISSTANT COMMISSIONER OF INCOME TAX, NAKODAR

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Shri Udayan Dasgupta, Jm 1. आयकर अपील सं. / Ita No.103/Asr/2019 (िनधा"रण वष" / Assessment Year: 2013-14) & 2. आयकर अपील सं. / Ita No.104/Asr/2019 (िनधा"रण वष" / Assessment Year: 2013-14) & 3. आयकर अपील सं. / Ita No.105/Asr/2019 (िनधा"रण वष" / Assessment Year: 2014-15) M/S Guru Nanak Rice Mills Ito बनाम/ Vpo Pandori Khas Nakodar (Punjab) - 144040 Vs. Nakodar (Punjab) - 144040 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aadfg-3256-H (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Sh. Ashray Sarna (Ca) – Ld. Ar ""थ"कीओरसे/Respondent By : Sh. Farat Khan (Cit) – Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 04-02-2026 घोषणाकीतारीख /Date Of Pronouncement 05-02-2026 : आदेश / O R D E R Manoj Kumar Aggarwal () 1. In These Appeals, The Assessee Assails Confirmation Of Quantum Additions As Well As Confirmation Of Penalty U/S 271G. First, We Take Up Quantum Appeal Ita No.103/Asr/2019 Which Arises Out Of An Order

Transfer Pricing (TP) Adjustment for Rs.413.72 Lacs as well as quantum additions of Rs.83 Lacs, Rs.35,924/- and Rs.28,683/-. The only prayer of Ld. AR is to set aside the matter before lower authorities which has been opposed by Ld. CIT-DR. Having heard rival submissions and upon perusal of case records, our adjudication would be as under

M/S GURU NANAK RICE MILLS,NAKODAR vs. INCOME TAX OFFICER, NAKODAR

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Shri Udayan Dasgupta, Jm 1. आयकर अपील सं. / Ita No.103/Asr/2019 (िनधा"रण वष" / Assessment Year: 2013-14) & 2. आयकर अपील सं. / Ita No.104/Asr/2019 (िनधा"रण वष" / Assessment Year: 2013-14) & 3. आयकर अपील सं. / Ita No.105/Asr/2019 (िनधा"रण वष" / Assessment Year: 2014-15) M/S Guru Nanak Rice Mills Ito बनाम/ Vpo Pandori Khas Nakodar (Punjab) - 144040 Vs. Nakodar (Punjab) - 144040 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aadfg-3256-H (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Sh. Ashray Sarna (Ca) – Ld. Ar ""थ"कीओरसे/Respondent By : Sh. Farat Khan (Cit) – Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 04-02-2026 घोषणाकीतारीख /Date Of Pronouncement 05-02-2026 : आदेश / O R D E R Manoj Kumar Aggarwal () 1. In These Appeals, The Assessee Assails Confirmation Of Quantum Additions As Well As Confirmation Of Penalty U/S 271G. First, We Take Up Quantum Appeal Ita No.103/Asr/2019 Which Arises Out Of An Order

Transfer Pricing (TP) Adjustment for Rs.413.72 Lacs as well as quantum additions of Rs.83 Lacs, Rs.35,924/- and Rs.28,683/-. The only prayer of Ld. AR is to set aside the matter before lower authorities which has been opposed by Ld. CIT-DR. Having heard rival submissions and upon perusal of case records, our adjudication would be as under

M/S. SATIA INDUSTRIES LIMITED,MUKTSAR vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-1, BATHINDA

In the result, the appeal of the assessee bearing ITA No

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

transfer pricing issues in the case of any person having international transactions or in case of a foreign company. It has been provided under sub-section (8) of section 144C that DRP may confirm, reduce or enhance the variations proposed in the draft order of the Assessing Officer. I.T.A. No.193/Asr/2022 36 Assessment Year: 2018-19 In a recent judgement

ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE, AMRITSAR vs. M/S PUNJAB RICE LAND PRIVATE LIMITED , TARN TARAN

In the result, both the appeals of the revenue are dismissed and

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

disallowed. Under the facts & circumstances of the case and after looking the bill filed by the AR and enquiries done in the presence of AR during the appellate proceedings, the addition of Rs. 18,15,000/- made by the AO is found sustainable and hence confirmed. Bogus accommodation entry with the help of Sh. Raman Arora Regarding M/s. Dashmesh Agro

ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE, AMRITSAR vs. M/S PUNJAB RICE LAND PRIVATE LIMITED, TARN TARAN

In the result, both the appeals of the revenue are dismissed and

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

disallowed. Under the facts & circumstances of the case and after looking the bill filed by the AR and enquiries done in the presence of AR during the appellate proceedings, the addition of Rs. 18,15,000/- made by the AO is found sustainable and hence confirmed. Bogus accommodation entry with the help of Sh. Raman Arora Regarding M/s. Dashmesh Agro

MEASAGE.TAU AGRO SALES PRIVATE LIMITED,FARIDKOT vs. INCOME TAX OFFICER WARD-3(4), FARIDKOT

In the result the ground no

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

disallowed under section 40A(3). The ld. Counsel argued & placed the fact that assessee having factory in remote area in village Bholuwal, where no banking facility is available. In additional evidence the assessee has filed Certificate of Panchayat with English version & Affidavit of director of company which are enclosed as Page 31-33 of Paper book. By the additional evidence

MEASAGE TAU AGRO SALES PRIVATE LIMITED,FARIDKOT vs. INCOME TAX OFFICER WARD-3(2), FEROZEPUR

In the result the ground no

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

disallowed under section 40A(3). The ld. Counsel argued & placed the fact that assessee having factory in remote area in village Bholuwal, where no banking facility is available. In additional evidence the assessee has filed Certificate of Panchayat with English version & Affidavit of director of company which are enclosed as Page 31-33 of Paper book. By the additional evidence

SMT. SATYAWATI MARWAHA THROUGH LEGAL HEIR SH, CHANDER SHEIKHAR MARWAHA,JALANDHAR vs. ASSISTANT COMMISSIONER OF INCOME TAX, JALANDHAR

In the result, the appeal for Asstt

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta

price rigging against the company and only action taken by SEBI , against the company was suspension of trading due to non-payment of ALF dues ( with the remarks : Company has not paid Annual Listing Fees and is in violation of SEBI and Exchange Regulations ), which according to the AR of the assessee is effective in the year

SMT. SATYAWATI MARWAHA THROUGH LEGAL HEIR SH. CHANDER SHEIKHAR MARWAHA,JALANDHAR vs. ASSISTANT COMMISSIONER OF INCOME TAX, JALANDHAR

In the result, the appeal for Asstt

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta

price rigging against the company and only action taken by SEBI , against the company was suspension of trading due to non-payment of ALF dues ( with the remarks : Company has not paid Annual Listing Fees and is in violation of SEBI and Exchange Regulations ), which according to the AR of the assessee is effective in the year

MESERS GANESH RICE MILLS,MUKTSAR vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-II, BATHINDA

In the result the appeal of the assessee ITA No

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

transferred to the following concerns during the year itself on various dates- S.S. Enterprises, JalalabadRs.3,62,93,300/- Narinder Joson& Co., JalalabadRs.6,11,56,000/- Amrinder& Sons, Jalalabad Rs. 2,00,00,000/- Gurkirat Enterprises, Jalalabad Rs. 2,00,00,000/- Nawab Trading Rs. 1,07,06,700/- Josan Food Pvt. Ltd., Rs. 2,00,00,000/-” The ld. Counsel