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

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

section 92CA(2B) that assuming but not admitting that excess period of credit allowed by the assessee company on sales made to the subsidiary company is to be treated as an independent international transaction, Ld. 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

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

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

section 92CA(2B) that assuming but not admitting that excess period of credit allowed by the assessee company on sales made to the subsidiary company is to be treated as an independent international transaction, Ld. 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

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

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

section 92CA(2B) that assuming but not admitting that excess period of credit allowed by the assessee company on sales made to the subsidiary company is to be treated as an independent international transaction, Ld. 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

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

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

section 92CA(2B) that assuming but not admitting that excess period of credit allowed by the assessee company on sales made to the subsidiary company is to be treated as an independent international transaction, Ld. 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

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

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

section 92CA(2B) that assuming but not admitting that excess period of credit allowed by the assessee company on sales made to the subsidiary company is to be treated as an independent international transaction, Ld. 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

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

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

section 92CA(2B) that assuming but not admitting that excess period of credit allowed by the assessee company on sales made to the subsidiary company is to be treated as an independent international transaction, Ld. 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

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

11 I.T.A. No. 702/Asr/2024 Assessment Year: 2021-22 23. This method involves comparing the price charged in a controlled transaction (i.e., a transaction between related parties) with the price charged in a comparable uncontrolled transaction (i.e., a transaction between independent un-related parties) for identical or similar goods, services, or assets. 24. To summaries the arguments the Ld AR submitted

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

6. The facts are taken from ITA No. 671/Asr/2014 in respect of the assessment year 2009-10 as a lead case for discussion. The search u/s 132 of the I.T. Act 1961 was conducted on 07.04.2011 in the case of the appellant during which documents had been found and seized as per Annexure DNB-1, A-2, Pages

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

6. The facts are taken from ITA No. 671/Asr/2014 in respect of the assessment year 2009-10 as a lead case for discussion. The search u/s 132 of the I.T. Act 1961 was conducted on 07.04.2011 in the case of the appellant during which documents had been found and seized as per Annexure DNB-1, A-2, Pages

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

6. The facts are taken from ITA No. 671/Asr/2014 in respect of the assessment year 2009-10 as a lead case for discussion. The search u/s 132 of the I.T. Act 1961 was conducted on 07.04.2011 in the case of the appellant during which documents had been found and seized as per Annexure DNB-1, A-2, Pages

M/S BLUE CITY TOWNSHIP & COLONIZERS,AMRITSAR. vs. THE INCOME TAX OFFICER,, AMRITSAR.

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

6 I.T.A. No. 90/Asr/2017 Blue City Township & Colonizers v. ITO 7 I.T.A. No. 90/Asr/2017 Blue City Township & Colonizers v. ITO 8. Per contra, the defendant ld. DR has raised strong objection, to the legal ground raised by the assessee as being not justified and that the ground was not raised either during the assessment proceedings or the appellate proceedings before

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

11 of the PAT Rules, 2012 issuesthe ‘energy savings certificates’ to these Designated Consumers, whose energy consumption is less than the prescribed norms and standards. g. Further, the objective of REC mechanism is to promote ‘renewable energy’ and facilitate compliance of Renewable Purchase Obligations (‘RPO’) through a market-based instrument aimed at addressing the mismatch, between availability of renewable energy

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

transfer of long term securities (Share dealings) - Assessment year 2013-14 - Assessee had sold shares of SNCFL and earned long-term capital gains - Assessing Officer issued a show cause notice alleging that transaction was a pennystock deal aimed at illegitimately claiming long-term capital gain exemption under section 10(38) - Assessing Officer treated purchase as bogus and added

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

transfer of long term securities (Share dealings) - Assessment year 2013-14 - Assessee had sold shares of SNCFL and earned long-term capital gains - Assessing Officer issued a show cause notice alleging that transaction was a pennystock deal aimed at illegitimately claiming long-term capital gain exemption under section 10(38) - Assessing Officer treated purchase as bogus and added

M/S CITI PLAZA,JALANDHAR vs. INCOME TAX OFFICER , WARD 3(1), JALANDHAR

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

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

price of Rs.2,30,00,000/-, has wrongly been assessed and upheld in this case. I.T.A. No. 356/Asr/2017 3 Assessment Year: 2006-07 6. That the Id.CIT(A) was not justified in ignoring assessee's submissions that if at all the reopening was valid, the Id ITO could not have given a clean chit to other group of partners headed

INCOME TAX OFFICER, INCOME TAX OFFICE vs. VIKAS MEHRA, THE MALL

In the result, the appeal filed by the revenue is dismissed being devoid of

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

price index on purchase value, indexed cost comes to Rs 8.800/- and Rs.792,000/- respectively. But the appellant credited his account with amount of Rs.2.55,00,000/- instead of Rs 8,00,800/- without paying any tax Therefore the appellant was given final opportunity to explain as to why the amount

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

In the result, the appeal filed by assessee is allowed

transfer of long term securities (Penny stock shares) - Assessment year 2014-\n15 - Whether before exercise of power under section 263 it is Principal Commissioner\nwho has to apply its mind to issue and thereafter record reasons as to how twin conditions\nof order of Assessing Officer being erroneous and prejudicial to interest of revenue are\nsatisfied and then issue

INCOME TAX OFFICER WARD-2 (2), MUKTSAR vs. AJAIB SINGH, VILLAGE BHARU

In the result, the appeal of the revenue is dismissed

Bench: Sh. Udayan Dasgupta & Sh. Krinwant Sahay(Hybrid Hearing) I.T.A. No. 354/Asr/2024 Assessment Year: 2012-13

6. In course of hearing the ld. DR relied on the assessment order and submitted that as per Girdawari record (Crops Sown record maintained by state government) the agricultural activities prior to sale where made on the land measuring (10 kanal 4 marla and the balance land of 12 kanal 18 marla) shown as “Gair mumkin” land and hence condition