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

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 ASSISTANT 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

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

THE ASSTT. COMMISSIONER OF INCOME TAX, JAMMU vs. M/S KAISER INDUSTRIES PVT. LTD, SAMBA

In the result, the appeal of the Revenue is dismissed

Bench: Sh. N. S. Saini & Sh. N. K. Choudhryita No. 381/Asr./2016 : Asstt. Year : 2006-07 Asstt. Commissioner Of Income Vs M/S Kaiser Industries Pvt. Ltd., Tax, Circle-1, Jammu Industrial Growth Centre, Sidco, Samba (Appellant) (Respondent) Pan No. Aabck0456G Assessee By : Shri. Vasu Gupta, Ca Revenue By : Sh. Yashender Garg, Dr Date Of Hearing :21.02.2019 Date Of Pronouncement : 22.03.2019 Order Per N. S. Saini: This Is An Appeal Filed By The Revenue Against The Order Of Commissioner Of Income Tax (Appeals), Jammu Dated 31.03.2016. 2. The Sole Issue Involved In This Appeal Is That The Commissioner Of Income Tax (Appeals) Erred In Allowing The Deduction U/S 80Ib(4) Of The Income Tax Act, 1961 In Respect Of Samba Unit As The Same Was Claimed To Inflate The Profit Of Eligible Unit For The Motive Of Availing Deduction U/S 80Ib.

price of this material being transferred to Samba unit. It is categorically stated that Samba unit has not sold its finished products to any of its related parties at all. It is pertinent to state that common expenses viz. Directors remuneration and legal expenses have already been apportioned between Bahadurgarh unit and Samba unit as is apparent from the details

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 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. 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. 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

MAX FINANCIAL SERVICE LIMITED ,NAWANSHAHR vs. PRINCIPAL COMMISSIONER OF INCOME TAX -1, JALANDHAR

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

disallowed 45% of the total expenses debited to the profit and loss account. 33. The aforesaid justification has not been controverted before us nor any infirmity worth its name pointed out by the Ld.Pr.CIT. On the contrary, we find, the Ld.Pr.CIT has tried to negate the claim of expenses against the aforestated incomes by stating that: a) Since the assessee

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(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

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

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