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 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 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

transferred to paper unit, in that circumstances the arm length rate works out to 3,18,91,85,267.04. 26. He further referred to the TPO order for the Assessment Year 2017-18 wherein the department accepted the price of electricity at Rs. 6.87 per KWH (calculated as 43,60,95,829/ 6,34,63,979) and the position

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

18 Assessment Year: 2018-19 d. It is also an undisputed fact that the electricity so generated by use of the Bio-fuels is not being sold to any other concern, but it is wholly consumed in the manufacturing activity of the appellant and this use of Bio-fuels saves the environment being an environment friendly as it reduces

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

The appeal of the assessee is dismissed

18. Analyzing the concept of remission of duty draw back and DEPB,\nwe are satisfied that the remission of duty is on account of the\nstatutory/policy provisions in the Customs Act/Scheme(s) framed by\nthe Government of India. In the circumstances, we hold that profits\nderived by way of such incentives do not fall within the expression\n\"profits derived

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. 18

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 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

section 54B is available for any land which is utilised for the purpose of agriculture for atleast two years immediately preceding the date on which the transfer took place. In the instant case it is not disputed that the appellant was cultivating the said land. The appellant in his written submissions has produced the revenue record as proof of doing

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

In the result, the appeal filed by assessee is allowed

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 6DD) - Assessment year

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

price, ITO's estimate of excess receipt by assessee on sale of onions could not be affirmed Held, yes Whether, therefore, impugned addition made in assessee's income was to be set aside-Held, yes" (i) Addition u/s 69 The AO has made addition in the hands of assessee u/s 69 of the Income Tax Act, 1961. It shall

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

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

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