MAX FINANCIAL SERVICE LIMITED ,NAWANSHAHR vs. PRINCIPAL COMMISSIONER OF INCOME TAX -1, JALANDHAR

In the result, the appeal of the assessee is therefore partly allowed

section 56(2) (viia) and 56(2)(viib) of the Act were applicable to the facts of the case. The Ld.Counsel for the assessee, therefore, contended that it had been clearly demonstrated to the Ld. Pr.CIT that there was no error so as to cause prejudice to the Revenue in the order of the AO. 53 A.Y.2015-16

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

9) of the 1922 Act, which was construed in Deviprasad's case (supra) is that the words 'regular assessment' have now been specifically defined by the legislature. The 1922 Act did not define the words 'regular assessment'. In view of the definition of these words in s. 2(40) of the Act, under the accepted canons of construction, wherever those

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

9) of the 1922 Act, which was construed in Deviprasad's case (supra) is that the words 'regular assessment' have now been specifically defined by the legislature. The 1922 Act did not define the words 'regular assessment'. In view of the definition of these words in s. 2(40) of the Act, under the accepted canons of construction, wherever those

THE ASSTT. COMMISSIONER OF INCOME TAX, JALANDHAR vs. M/S BROADWAYS OVERSEAS LTD, JALANDHAR

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

2. That Ld. CIT(A) ought to have held that in any case, reference made to Transfer Pricing Officer without demonstrating as to why it was necessary and expedient to do so is bad in law. 3. That Ld. ClT(A) is not justified in rejecting the objection of the assessee company citing provisions of section 92CA(2B) that assuming

THE ASSTT. COMMISSIONER OF INCOME TAX, JALANDHAR vs. M/S BROADWAY OVERSEAS LTD., JALANDHAR

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

2. That Ld. CIT(A) ought to have held that in any case, reference made to Transfer Pricing Officer without demonstrating as to why it was necessary and expedient to do so is bad in law. 3. That Ld. ClT(A) is not justified in rejecting the objection of the assessee company citing provisions of section 92CA(2B) that assuming

THE ASSTT. COMMISSIONER OF INCOME TAX, JALANDHAR vs. M/S BROADWAY OVERSEAS LTD., JALANDHAR

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

2. That Ld. CIT(A) ought to have held that in any case, reference made to Transfer Pricing Officer without demonstrating as to why it was necessary and expedient to do so is bad in law. 3. That Ld. ClT(A) is not justified in rejecting the objection of the assessee company citing provisions of section 92CA(2B) that assuming

THE ASSTT. COMMISSIONER OF INCOME TAX, JALANDHAR vs. M/S BROADWAY OVERSEAS LTD., JALANDHAR

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

2. That Ld. CIT(A) ought to have held that in any case, reference made to Transfer Pricing Officer without demonstrating as to why it was necessary and expedient to do so is bad in law. 3. That Ld. ClT(A) is not justified in rejecting the objection of the assessee company citing provisions of section 92CA(2B) that assuming

THE ASSTT. COMMISSIONER OF INCOME TAX, JALANDHAR vs. M/S BROADWAY OVERSEAS LTD., JALANDHAR

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

2. That Ld. CIT(A) ought to have held that in any case, reference made to Transfer Pricing Officer without demonstrating as to why it was necessary and expedient to do so is bad in law. 3. That Ld. ClT(A) is not justified in rejecting the objection of the assessee company citing provisions of section 92CA(2B) that assuming

THE ASSISTANT COMMISSIONER OF INCOME TAX, JALANDHAR vs. M/S BROADWAYS OVERSEAS LTD, JALANDHAR

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

2. That Ld. CIT(A) ought to have held that in any case, reference made to Transfer Pricing Officer without demonstrating as to why it was necessary and expedient to do so is bad in law. 3. That Ld. ClT(A) is not justified in rejecting the objection of the assessee company citing provisions of section 92CA(2B) that assuming

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

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

2. That Ld. CIT(A) ought to have held that in any case, reference made to Transfer Pricing Officer without demonstrating as to why it was necessary and expedient to do so is bad in law. 3. That Ld. ClT(A) is not justified in rejecting the objection of the assessee company citing provisions of section 92CA(2B) that assuming

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

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

9. The grounds of appeal preferred by the assessee in form 36 are as follows: “1. That on the facts and circumstances of the case, the AD erred in making addition of Rs. 8,85,40,036/- vide order under section 143(3) read with section 144C(13) in consequence of directions of DRP u/s144C(5) of the Income

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

9)……………………………. Explanation 1.—For the purposes of this section, in computing the period of limitation— (i)………………………………….. To (xiii) shall be excluded: Provided that where immediately after the exclusion of the aforesaid period, the period of limitation referred to in sub-sections (1), (2), (3) and sub-section (8) available to the Assessing Officer for making an order of assessment, reassessment

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

9)……………………………. Explanation 1.—For the purposes of this section, in computing the period of limitation— (i)………………………………….. To (xiii) shall be excluded: Provided that where immediately after the exclusion of the aforesaid period, the period of limitation referred to in sub-sections (1), (2), (3) and sub-section (8) available to the Assessing Officer for making an order of assessment, reassessment

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

9)……………………………. Explanation 1.—For the purposes of this section, in computing the period of limitation— (i)………………………………….. To (xiii) shall be excluded: Provided that where immediately after the exclusion of the aforesaid period, the period of limitation referred to in sub-sections (1), (2), (3) and sub-section (8) available to the Assessing Officer for making an order of assessment, reassessment

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

9)……………………………. Explanation 1.—For the purposes of this section, in computing the period of limitation— (i)………………………………….. To (xiii) shall be excluded: Provided that where immediately after the exclusion of the aforesaid period, the period of limitation referred to in sub-sections (1), (2), (3) and sub-section (8) available to the Assessing Officer for making an order of assessment, reassessment

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

9)……………………………. Explanation 1.—For the purposes of this section, in computing the period of limitation— (i)………………………………….. To (xiii) shall be excluded: Provided that where immediately after the exclusion of the aforesaid period, the period of limitation referred to in sub-sections (1), (2), (3) and sub-section (8) available to the Assessing Officer for making an order of assessment, reassessment

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

9)……………………………. Explanation 1.—For the purposes of this section, in computing the period of limitation— (i)………………………………….. To (xiii) shall be excluded: Provided that where immediately after the exclusion of the aforesaid period, the period of limitation referred to in sub-sections (1), (2), (3) and sub-section (8) available to the Assessing Officer for making an order of assessment, reassessment

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

9)……………………………. Explanation 1.—For the purposes of this section, in computing the period of limitation— (i)………………………………….. To (xiii) shall be excluded: Provided that where immediately after the exclusion of the aforesaid period, the period of limitation referred to in sub-sections (1), (2), (3) and sub-section (8) available to the Assessing Officer for making an order of assessment, reassessment