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 ought to have considered TNMM method. I find that the credits in the account of AE have arisen out of export sale made by the assessee company to the AE and therefore, receivables arising from such transactions are undoubtedly inextricable connected. Further. TPO has applied interest rate of 17.26% which has been applied

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 ought to have considered TNMM method. I find that the credits in the account of AE have arisen out of export sale made by the assessee company to the AE and therefore, receivables arising from such transactions are undoubtedly inextricable connected. Further. TPO has applied interest rate of 17.26% which has been applied

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 ought to have considered TNMM method. I find that the credits in the account of AE have arisen out of export sale made by the assessee company to the AE and therefore, receivables arising from such transactions are undoubtedly inextricable connected. Further. TPO has applied interest rate of 17.26% which has been applied

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 ought to have considered TNMM method. I find that the credits in the account of AE have arisen out of export sale made by the assessee company to the AE and therefore, receivables arising from such transactions are undoubtedly inextricable connected. Further. TPO has applied interest rate of 17.26% which has been applied

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

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

Transfer Pricing Officer ought to have considered TNMM method. I find that the credits in the account of AE have arisen out of export sale made by the assessee company to the AE and therefore, receivables arising from such transactions are undoubtedly inextricable connected. Further. TPO has applied interest rate of 17.26% which has been applied

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 ought to have considered TNMM method. I find that the credits in the account of AE have arisen out of export sale made by the assessee company to the AE and therefore, receivables arising from such transactions are undoubtedly inextricable connected. Further. TPO has applied interest rate of 17.26% which has been applied

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

14. The Ld. AR also submitted that the (DRP)was wrong by shifting the method from the” Transactional Net Margin Method (TNMM)” to the “Cost Plus Method” in 8 I.T.A. No. 702/Asr/2024 Assessment Year: 2021-22 the case of steam, and to the “External Comparable Uncontrolled Price (CUP) method” in the case of electricity, without considering the fact that

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

section 69B of the Act. Dy. CIT v. Horizon Buildcon Pvt. Ltd. When the assessee further challenged the same before the Tribunal, it quashed and set aside the order of the Assessing Officer and that of CIT(Appeals) and held the entire addition to have been made on the basis of presumptions and surmises by holding thus: - 14. From

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

section 69B of the Act. Dy. CIT v. Horizon Buildcon Pvt. Ltd. When the assessee further challenged the same before the Tribunal, it quashed and set aside the order of the Assessing Officer and that of CIT(Appeals) and held the entire addition to have been made on the basis of presumptions and surmises by holding thus: - 14. From

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

section 69B of the Act. Dy. CIT v. Horizon Buildcon Pvt. Ltd. When the assessee further challenged the same before the Tribunal, it quashed and set aside the order of the Assessing Officer and that of CIT(Appeals) and held the entire addition to have been made on the basis of presumptions and surmises by holding thus: - 14. From

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

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

14). Thereafter, the Assessing Officer computed the Long Term Capital Gain at Rs.3,68,15,000/-. The Assessee had submitted that the sale consideration received by him was utilised for purchase of 24 acres 1 Kanai agricultural land at village Daulatpura, Tehsil Abohar for Rs.3,73,48,255/- and claimed benefit of section 54B. The Assessing Officer denied the benefit

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

transferred through bank channel. 14. He further pointed out that both the seller and buyer has filed sworn affidavits in support of their respective declaration, that they have never seen the said loose sheet of paper earlier and have no knowledge about its existence and has not entered into any cash transaction over and above the monetary transaction effected through

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

14 and 16 to 18] [In favour of assessee]\nC) [2022] 141 taxmann.com 512 (Gujarat) HIGH COURT OF GUJARATPrincipal\nCommissioner of Income-tax v. Shukla Dairy (P.) Ltd.*\nII. Section 40A(3), read with section 263, of the Income-tax Act, 1961 and rule 6DD of\nIncome-tax Rules, 1962 - Business disallowance - Cash payment exceeding prescribed limit\n(Rule

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

DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-1, JALANDHAR vs. SHRI BHAVNOOR SINGH BEDI, JALANDHAR

In the result, the appeal of the revenue, ITA No 90/Asr/2020 is dismissed

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

transferred and registration of 3 Kanal 10 Marla was executed on 18.05.2018 for Rs.42 lacs and the balance property including the building & others are still in possession & power of M/s. S. Amar Singh Educational Charitable Trust. The electricity bill of the institute is still in the name of GNA-IMT which, as per the AR, justifies the claims