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

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

43,69,110/- made by the assessing officer u/s 69 /69B of the IT Act,1961 by holding that the Documents i.e. MOU dated 22.01.2008 and supplement MOU dated 18.03.2008 which were found and seized during the time of search, though not signed by either of the parties, in this case; could not be taken as evidence of the payment

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

43,69,110/- made by the assessing officer u/s 69 /69B of the IT Act,1961 by holding that the Documents i.e. MOU dated 22.01.2008 and supplement MOU dated 18.03.2008 which were found and seized during the time of search, though not signed by either of the parties, in this case; could not be taken as evidence of the payment

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

43,69,110/- made by the assessing officer u/s 69 /69B of the IT Act,1961 by holding that the Documents i.e. MOU dated 22.01.2008 and supplement MOU dated 18.03.2008 which were found and seized during the time of search, though not signed by either of the parties, in this case; could not be taken as evidence of the payment

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

43 Assessment Year: 2018-19 of judgment is in favour of assessee. The ld. DR respectfully relied on the order of Hon’ble Orrisa High Court, but the claim is restricted before the ld. AO. Pursuing the order of the Hon’ble Apex Court in the case of Goetze (India) Ltdthere is no impingement in power of section

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

The appeal of the assessee is dismissed

6) of the Act 1961 dated 01.01.2020 which has\nemanated from the order of the Assistant Commissioner of Income Tax, Circle-3,\nSrinagar, (in short the AO) u/s 143(3) of the Act dated 27.12.2017 for A.Y. 2015-\n16.\n2.\nThe grounds of appeal preferred by the assessee as per memorandum of\nappeal are as under;\n1. That the learned

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