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 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

SH. GURBACHAN SINGH BRAR,MOGA vs. ITO, WARD - 1,, MOGA

Bench: : Shri Laliet Kumar & Dr. Mitha Lal Meena

price mentioned on the said document. In this AR had submitted that, appellant, during the course of assessment proceedings, 3.7. denied the charge of the Learned Assessing Officer that the said property was actually sold for Rs. 11.25 crores on the following grounds: i) The assessee does not know the source of the purported alleged documents in the possession

SH. SANTOKH SINGH BRAR,MOGA vs. ITO, WARD - 2,, MOGA

Bench: : Shri Laliet Kumar & Dr. Mitha Lal Meena

price mentioned on the said document. In this AR had submitted that, appellant, during the course of assessment proceedings, 3.7. denied the charge of the Learned Assessing Officer that the said property was actually sold for Rs. 11.25 crores on the following grounds: i) The assessee does not know the source of the purported alleged documents in the possession

SMT. INDERMEET BAINS W/O SH. D.S. BAINS,BATHINDA vs. PR. COMMISSIONER OF INCOME TAX , BATHINDA

The appeal of the assessee is disposed of in the term indicated as above

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

vi). CIT vs. Hindustan Marketing & Advertising Co. Ltd. 341 ITR 180 Delhi-HC vii). Commissioner of Income Tax vs. Anil Kumar Sharma 335 ITR 180 Delhi- HC. 7. Further, the Ld. Counsel of the assessee relied upon on the judgment of Hon’ble Bombay Court, in the case of ‘Sh. Nirav Modi’ reported in 71 Taxmann.com 273, wherein the order

SMT. GURJEET KAUR,JALANDHAR vs. INCOME TAX OFFICER, WARD- IV (2),, JALANDHAR

The appeal of the assessee is allowed in terms of our

Bench: Sh. Ravish Sood & Dr. M. L. Meena

2)(vi) of the Act, however, in the absence of any addition having been made as regards the reason on the basis of which the case of the assessee was reopened, the assessment framed by him u/s 147/143(3), dated 30.03.2016 was liable to be quashed; (ii). that the addition made as regards the alleged on-money

SMT. GURJEET KAUR,JALANDHAR vs. INCOME TAX OFFICER, WARD- IV (2),, JALANDHAR

The appeal of the assessee is allowed in terms of our

Bench: Sh. Ravish Sood & Dr. M. L. Meena

2)(vi) of the Act, however, in the absence of any addition having been made as regards the reason on the basis of which the case of the assessee was reopened, the assessment framed by him u/s 147/143(3), dated 30.03.2016 was liable to be quashed; (ii). that the addition made as regards the alleged on-money

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 of impugned land purchase, ignoring the detailed discussion of the same in the assessment order; that the Ld. CIT(A) is not right to 15 I.T.A. No.557/Asr/2024 Assessment Year: 2019-20 hold that various ikrarnamas, photocopies of which were found and seized during search viz. A-9 DNB-1 are collusive in nature, as claimed by the assessee, when