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

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

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

price. Thus, the Panel is of the view that the assessee has wrongly claimed the Income from Sale of RECs/ESCs u/s 115BBG of Income Tax Act, I.T.A. No.193/Asr/2022 22 Assessment Year: 2018-19 1961. Income from sale of REC/ESCs is normal business income few the assessee and needs to be included in the business income and taxed at normal tale

SATIA INDUSTRIES LIMITED,MUKTSAR, PUNJAB vs. DCIT, ACIT CIRCLE 1, BATHINDA

In the result, the appeal is partly allowed

Bench: Shri Udayan Das Gupta & Shri Krinwant Sahayआयकरअपीलसं./Ita No. 527/Asr/2024 िनधा"रणवष" / Assessment Year : 2020-21

business i.e., in open market - held, yes- Whether thus, price at which surplus power supplied by assessee to State Electricity Board was determined entirely by State Electricity Board in terms of statutory regulations and contract, such a price could not be equated with market value as was understood for purpose of section 80-IA (8) and on contrary, rate

POONAM MARWAHA,AMRITSAR vs. ACIT DCIT CEN CIR, AMRITSAR

In the result, the appeal filed by assessee is allowed

price. The correct value\nof excess stock as per cost as submitted before the AO is worked out and the assessee\nhas put an alternate argument to demonstrate that the revenue is not prejudiced:\n“Additional argument on the aspect of prejudicial to the interest of revenue:\nThat the appellant vide reply dated 17.03.2021 specifically requested the AO to consider

SHRI NITIN AIMA,SHRINAGAR vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-3, SRINAGAR

The appeal of the assessee is dismissed

price and duty drawback. In view of the\ndecision of Supreme Court in the case of Keshavji Ravji & Co vs. CIT\nreported at 183 ITR 1 the duty drawback should be reduced from the\nvalue of purchases as a result of which the profits earned from exports\nwill only be in respect of value of sales credited to the Manufacturing

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

Income Tax Act, 1961. Section 80-IA (8) Where any goods [or services] held for the purposes of the eligible business are transferred to any other business carried on by the assessee, or where any goods 96[or services] held for the purposes of any other business carried on by the assessee are transferred to the eligible business

THE DY. COMMISSIONER INCOME-TAX, JAMMU vs. M/S. HORIZON BUILDCON PVT. LTD,, JAMMU

In the result, the appeals of the Revenue in I

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

Income Tax Appellate Tribunal, Chandigarh Bench 'B', Chandigarh in the case of I.T.O. v. Shri Manjit Singh reported in (2010)128 TTJ (Chd)(UO) 82, held:- "In the absence of any evidence to show that the assessee had received any consideration over and above what is stated in the sale deed, addition could not be made by disregarding the 'full

THE DY. COMMISSIONER INCOME-TAX, JAMMU vs. M/S. HORIZON BUILDCON PVT. LTD,, JAMMU

In the result, the appeals of the Revenue in I

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

Income Tax Appellate Tribunal, Chandigarh Bench 'B', Chandigarh in the case of I.T.O. v. Shri Manjit Singh reported in (2010)128 TTJ (Chd)(UO) 82, held:- "In the absence of any evidence to show that the assessee had received any consideration over and above what is stated in the sale deed, addition could not be made by disregarding the 'full

THE DY. COMMISSIONER INCOME-TAX, JAMMU vs. M/S. HORIZON BUILDCON PVT. LTD,, JAMMU

In the result, the appeals of the Revenue in I

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

Income Tax Appellate Tribunal, Chandigarh Bench 'B', Chandigarh in the case of I.T.O. v. Shri Manjit Singh reported in (2010)128 TTJ (Chd)(UO) 82, held:- "In the absence of any evidence to show that the assessee had received any consideration over and above what is stated in the sale deed, addition could not be made by disregarding the 'full

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

business of trading in electrical, electronic and mechanical items-Assessee filed its e-return- AO noticed that there was escapement of income as Assessee had billed royalty under head other income-AO completed assessment u/s. 143(3) restricting TDS-Assessment was reopened to consider relevant TDS relating to income offered by assessee and income included in TDS certificate, which included

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

business of trading in electrical, electronic and mechanical items-Assessee filed its e-return- AO noticed that there was escapement of income as Assessee had billed royalty under head other income-AO completed assessment u/s. 143(3) restricting TDS-Assessment was reopened to consider relevant TDS relating to income offered by assessee and income included in TDS certificate, which included

SHRI JASBIR SINGH ,AMRITSAR vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE, AMRITSAR

In the result, appeal of the assesseeITA No

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjeei.T.A. No. 133/Asr/2022 Assessment Year: 2019-20

price whichever is lower at the acquisition in the past. 4. That Ld. AO has not appreciated the fact that surrender was agreed in the hands of four persons to avoid litigation, buy peace and to make amicable settlement with the department. 5. That the Ld. AO erred under law and facts in making addition

ASSISTANT COMMISSIONER OF INCOME TAX (CENTRAL CIRCLE), JAMMU vs. ANITA KAPAHI, JAMMU

In the result, the appeal of the revenue is dismissed being devoid of merits

Bench: Sh. Udayan Dasgupta & Sh. Krinwant Sahay

business and is stated to be one of the directors and shareholder of Jammu Hotels Pvt. Ltd. and Future Housing Infra Pvt. Ltd., respectively and the return of income was filed on 31.01.2020, declaring total income 3 I.T.A. No.557/Asr/2024 Assessment Year: 2019-20 of Rs.67.53 lacs under the head capital gains , which was ultimately assessed , with an addition of Rs.2.05

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