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

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

C) No.17539 of 2016] on the provisions of section 80IB, affirming their view earlier taken in the case of Liberty India 317 ITR 218 (SC): 225 CTR (SC) 233 on the claim of deduction u/s 80IB of the Act. The Ld. DR contended that the AO had rightly denied the deduction under section 10B of the Act to the assessee

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

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

C) No.17539 of 2016] on the provisions of section 80IB, affirming their view earlier taken in the case of Liberty India 317 ITR 218 (SC): 225 CTR (SC) 233 on the claim of deduction u/s 80IB of the Act. The Ld. DR contended that the AO had rightly denied the deduction under section 10B of the Act to the assessee

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

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

C) No.17539 of 2016] on the provisions of section 80IB, affirming their view earlier taken in the case of Liberty India 317 ITR 218 (SC): 225 CTR (SC) 233 on the claim of deduction u/s 80IB of the Act. The Ld. DR contended that the AO had rightly denied the deduction under section 10B of the Act to the assessee

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

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

C) No.17539 of 2016] on the provisions of section 80IB, affirming their view earlier taken in the case of Liberty India 317 ITR 218 (SC): 225 CTR (SC) 233 on the claim of deduction u/s 80IB of the Act. The Ld. DR contended that the AO had rightly denied the deduction under section 10B of the Act to the assessee

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

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

C) No.17539 of 2016] on the provisions of section 80IB, affirming their view earlier taken in the case of Liberty India 317 ITR 218 (SC): 225 CTR (SC) 233 on the claim of deduction u/s 80IB of the Act. The Ld. DR contended that the AO had rightly denied the deduction under section 10B of the Act to the assessee

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

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

C) No.17539 of 2016] on the provisions of section 80IB, affirming their view earlier taken in the case of Liberty India 317 ITR 218 (SC): 225 CTR (SC) 233 on the claim of deduction u/s 80IB of the Act. The Ld. DR contended that the AO had rightly denied the deduction under section 10B of the Act to the assessee

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

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

C) No.17539 of 2016] on the provisions of section 80IB, affirming their view earlier taken in the case of Liberty India 317 ITR 218 (SC): 225 CTR (SC) 233 on the claim of deduction u/s 80IB of the Act. The Ld. DR contended that the AO had rightly denied the deduction under section 10B of the Act to the assessee

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

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

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

1,67,11,295/, as the AD has already made an addition in respect of the difference in sales of power and steam separately, amounting to Rs. 6,66,54,028/-. 8. That the Assessing Officer (AO) has erred in confirming the disallowance to the extent of Rs. 51,74,713/- on the ground that the underlying expenditure

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

transferred. The Hon'ble Madras High Court in the case of CIT Vs. P. Suryanaraina 88 ITR 321 held that the full value of consideration in the said section meant only the actual value received by the assessee. However the market value may also be taken in place of full value of consideration only in the event of the consideration

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

transferred. The Hon'ble Madras High Court in the case of CIT Vs. P. Suryanaraina 88 ITR 321 held that the full value of consideration in the said section meant only the actual value received by the assessee. However the market value may also be taken in place of full value of consideration only in the event of the consideration

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

transferred. The Hon'ble Madras High Court in the case of CIT Vs. P. Suryanaraina 88 ITR 321 held that the full value of consideration in the said section meant only the actual value received by the assessee. However the market value may also be taken in place of full value of consideration only in the event of the consideration

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

NASA AGRO INDUSTRIES PRIVATE LIMITED,FAZILKA vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-II, BATHINDA

In the result, the appeal filed by the assessee is allowed for statistical purpose

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

transferred by the assessee to the M/s Devinder Kumar Deepesh Kumar ,as an accommodation entry for recording of bogus purchase, because 4 I.T.A. No. 236/Asr/2023 Assessment Year: 2011-12 as per the AO the physical movement of goods could not be proved, in absence of any Bilty, weighment slip of goods, octroi receipts, and in absence of any proof

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

The appeal of the assessee is dismissed

13.\nThe authorities below have only confined themselves to the expression “derived\nfrom\" and \"attributable to\" without considering the context in which these\nexpressions have been used. There is no doubt that the Supreme Court has held\nthat the expression \"derived from\" is much narrower than attributable to\". In\nsection 80-IB, the expression \"derived from industrial undertaking\" has been

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

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

C Ranjit Ward -5(1), Amritsar Avenue, Amritsar [PAN: AACCB 8256C] (Respondent) (Appellant) Appellant by Sh. Salil Kapoor, Adv. Respondent by Sh. Amit Jain, Sr. DR Date of Hearing : 30.05.2023 Date of Pronouncement : 14.07.2023 ORDER Per Dr. M. L. Meena, AM: The captioned appeal has been filed by the assessee against the order of the Ld. Commissioner of Income

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

C’ whose shares were allegedly purchased was a penny stock, SLP filed against said order was to be dismissed.” 12. Before concluding, the Ld DR has relied on the Hon’ble Calcutta High court decision in the case of Swati Bajaj [2022] 288 Taxman 403 ( Calcutta ) / 466 ITR , to put forth his argument that in absence of foundational facts , circumstantial

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

C’ whose shares were allegedly purchased was a penny stock, SLP filed against said order was to be dismissed.” 12. Before concluding, the Ld DR has relied on the Hon’ble Calcutta High court decision in the case of Swati Bajaj [2022] 288 Taxman 403 ( Calcutta ) / 466 ITR , to put forth his argument that in absence of foundational facts , circumstantial