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 ASSISTANT 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 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

SH. MANJIT KRISHAN MALHOTRA,ABOHAR vs. PR. COMMISSIONER OF INCME TAX , BATHINDA

The appeals of the assessee are disposed of in the terms indicated as above

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

147. We also do not find anything in the context of s. 273 which would require the words 'regular assessment' to be given a meaning different from the one given by the legislature when these words were defined." 25. I respectfully agree with the views expressed by Chandurkar J. Moreover, there is another aspect to this case. This

SHRI. MANJIT KRISHAN MALHOTRA,ABOHAR vs. PRINCIPAL COMMISSIONER OF INCOME TAX, BATHINDA

The appeals of the assessee are disposed of in the terms indicated as above

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

147. We also do not find anything in the context of s. 273 which would require the words 'regular assessment' to be given a meaning different from the one given by the legislature when these words were defined." 25. I respectfully agree with the views expressed by Chandurkar J. Moreover, there is another aspect to this case. This

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

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

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

section 147 of the act. Thus ground number 3 and 4 of the appellant are rejected. Adjudication on merits of the case: In ground nos. 5 to 15, the quantum addition is challenged by spreading in multiple grounds with consequential interest to addition u/s 234A, 234B and 234C of the Act, and hence adjudicated simultaneously in the following paras

M/S SADHU SINGH HAMDARD TRUST,JALANDHAR vs. ASSISTANT COMMISSIONER OF INCOME TAX, JALANDHAR

In the result, the appeals of the assessee bearing ITA Nos

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

147 was time barring only on 31.03.1997/31.03.1998 as notice u/s 148 was issued on 04/08/1994 or later as per chart attached. Further argued that the ld. AR of the assessee has furnished a copy of interim order dated 11/04/1996 in the above writ petitions. In this order of Hon'ble Court, it has been mentioned "Stay to continue

M/S SADHU SINGH HAMDARD TRUST,JALANDHAR vs. ASSISTANT COMMISSIONER OF INCOME TAX, JALANDHAR

In the result, the appeals of the assessee bearing ITA Nos

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

147 was time barring only on 31.03.1997/31.03.1998 as notice u/s 148 was issued on 04/08/1994 or later as per chart attached. Further argued that the ld. AR of the assessee has furnished a copy of interim order dated 11/04/1996 in the above writ petitions. In this order of Hon'ble Court, it has been mentioned "Stay to continue

M/S SADHU SINGH HAMDARD TRUST,JALANDHAR vs. ASSISTANT COMMISSIONER OF INCOME TAX, JALANDHAR

In the result, the appeals of the assessee bearing ITA Nos

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

147 was time barring only on 31.03.1997/31.03.1998 as notice u/s 148 was issued on 04/08/1994 or later as per chart attached. Further argued that the ld. AR of the assessee has furnished a copy of interim order dated 11/04/1996 in the above writ petitions. In this order of Hon'ble Court, it has been mentioned "Stay to continue

M/S SADHU SINGH HAMDARD TRUST,JALANDHAR vs. ASSISTANT COMMISSIONER OF INCOME TAX, JALANDHAR

In the result, the appeals of the assessee bearing ITA Nos

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

147 was time barring only on 31.03.1997/31.03.1998 as notice u/s 148 was issued on 04/08/1994 or later as per chart attached. Further argued that the ld. AR of the assessee has furnished a copy of interim order dated 11/04/1996 in the above writ petitions. In this order of Hon'ble Court, it has been mentioned "Stay to continue

M/S SADHU SINGH HAMDARD TRUST,JALANDHAR vs. ASSISTANT COMMISSIONER OF INCOME TAX, JALANDHAR

In the result, the appeals of the assessee bearing ITA Nos

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

147 was time barring only on 31.03.1997/31.03.1998 as notice u/s 148 was issued on 04/08/1994 or later as per chart attached. Further argued that the ld. AR of the assessee has furnished a copy of interim order dated 11/04/1996 in the above writ petitions. In this order of Hon'ble Court, it has been mentioned "Stay to continue

M/S SADHU SINGH HAMDARD TRUST,JALANDHAR vs. ASSISTANT COMMISSIONER OF INCOME TAX, JALANDHAR

In the result, the appeals of the assessee bearing ITA Nos

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

147 was time barring only on 31.03.1997/31.03.1998 as notice u/s 148 was issued on 04/08/1994 or later as per chart attached. Further argued that the ld. AR of the assessee has furnished a copy of interim order dated 11/04/1996 in the above writ petitions. In this order of Hon'ble Court, it has been mentioned "Stay to continue

M/S SADHU SINGH HAMDARD TRUST,JALANDHAR vs. ASSISTANT COMMISSIONER OF INCOME TAX, JALANDHAR

In the result, the appeals of the assessee bearing ITA Nos

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

147 was time barring only on 31.03.1997/31.03.1998 as notice u/s 148 was issued on 04/08/1994 or later as per chart attached. Further argued that the ld. AR of the assessee has furnished a copy of interim order dated 11/04/1996 in the above writ petitions. In this order of Hon'ble Court, it has been mentioned "Stay to continue

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