PRINCIPAL COMMISSIONER OF INCOME TAX CENTRAL 1 KOLKATA vs. RUNGTA MINES LTD

In the result, these appeals are dismissed and the substantial

Bench: THE HON'BLE THE CHIEF JUSTICE T.S SIVAGNANAM,HON'BLE JUSTICE CHAITALI CHATTERJEE (DAS)

transfer power to the manufacturing units which was reported to Arm’s Length Price (ALP) in the Transfer Pricing Study

PRINCIPAL COMMISSIONER OF INCOME TAX 2 KOLKATA vs. DIGVIJAY VINIMAY PVT LTD

Bench: THE HON'BLE THE CHIEF JUSTICE T.S SIVAGNANAM,HON'BLE JUSTICE HIRANMAY BHATTACHARYYA

Transfer Pricing Officer under Section 92CA(1) of the Act for determination of the arm’s length price in relation

PRINCIPAL COMMISSIONER OF INCOME TAX 1 KOLKATA vs. M/S ITC LTD

Bench: The Learned Tribunal – One By The Assessee & The Other By The Revenue Which Have Been Disposed Of By A Common Order, Impugned In This Appeal. 2. The Revenue Has Raised The Following Substantial Questions Of Law For Consideration :

Transfer Pricing Officer (TPO) for determination of Arm's Length Price and adjustment, if any, and by order dated 30.01.2024, TPO did not make

PRINCIPAL COMMISSIONER OF INCOME TAX 2, KOLKATA vs. M/S KESORAM INDUSTRIES LTD

In the result, the appeal is dismissed and it is held that substantial

Bench: :

price and fair market value are two 2 different concepts and the role of Transfer Pricing Officer is limited to determination

PRINCIPAL COMMISSIONER OF INCOME TAX 2 KOLKATA vs. M/S DHUNSERI VENTURES LTD

Accordingly, the appeal fails and the same is dismissed

Bench: : The Hon'Ble The Chief Justice T.S Sivagnanam -A N D- Hon'Ble Justice Chaitali Chatterjee (Das) Date : 20Th August, 2025. Appearance : Mr. Tilak Mitra, Adv. Mr. Prithu Dudhorea, Adv. …For Appellant.

transfer price of power supplied by CPP was to be bench marked at annual average of landed cost at which

COMMISSIONER OF INCOME TAX INTERNATIONAL TAXATION AND TRANSFER PRICING vs. SIGNIFY HOLDING B V

Accordingly, the appeal fails and is dismissed

Bench: : The Hon’Ble The Chief Justice T.S. Sivagnanam & The Hon’Ble Justice Chaitali Chatterjee (Das) Date: 6Th May, 2025 Appearance: Mr. Vipul Kundalia, Sr. Adv. Mr. Soumen Bhattacharjee, Adv. Mr. Ankan Das, Adv. Mr. Anindya Kanan, Adv. Ms. Shradhya Ghosh, Adv. …For Appellant

TRANSFER PRICING), KOLKATA VS. SIGNIFY HOLDING B.V. BEFORE : THE HON’BLE THE CHIEF JUSTICE T.S. SIVAGNANAM AND THE HON’BLE JUSTICE

PRINCIPAL COMMISSIONER OF INCOME TAX-1 KOLKATA vs. M/S LANDIS GYR

In the result, the substantial questions of law (i)

Bench: : The Hon’Ble Acting Chief Justice T.S. Sivagnanam & The Hon’Ble Justice Hiranmay Bhattacharyya Date : 3Rd April, 2023 Appearance : Mr. Soumen Bhattacharjee, Adv. ...For The Appellant Mr. Asim Choudhury, Adv. Mr. Soham Sen, Adv. ...For The Respondent. The Court : This Appeal Filed By The Revenue Under Section 260A Of The Income Tax Act, 1961 (The ‘Act’ For Brevity) Is Directed Against The Order Dated October 17, 2018 Passed By The Income Tax Appellate Tribunal, “C” Bench, Kolkata (The Tribunal) In Ita No.524/Kol/2017 For The Assessment Year 2012-13. The Revenue Has Raised The Following Substantial Questions Of Law For Consideration:

Transfer Pricing in respect of International Transactions” by TPO relied upon the decision in assessee’s own case for Assessment

RAJEEV BISWAS vs. UNION OF INDIA & ORS

Bench: : The Hon’Ble Justice T.S. Sivagnanam & The Hon’Ble Justice Supratim Bhattacharya Date : September 22, 2022. Appearance: Mr. Sukumar Bhattacharyya, Adv. Ms. Sayani Bhattacharya, Adv. Ms. Swaralipi Sarkar, Adv. …For Appellant Mr. Tilak Mitra, Adv. …For Respondent The Court :- This Appeal Filed By The Assessee Under Section 260A Of The Income Tax Act, 1961 (The Act) Is Directed Against The Order Dated 5.1.2018 Passed By The Income Tax Appellate Tribunal “A” Bench, Kolkata In Miscellaneous Application No. 205/Kol/2017 Affirming The Order Dated 27Th September, 2017 Passed In Income Tax Appeal No. 1176/Kol/2017 By Which The Order Passed By The Commissioner Of Income Tax (Appeals) –22 Kolkata, [Cit(A)] Dated 15Th March, 2017 Was Affirmed, Which Order Of The [Cit(A)] Arose Out Of An Order Passed By The Assessing Officer Namely Deputy Commissioner Of Income Tax (International Taxation), Circle – 2 (1), Kolkata Dated 28Th January, 2016 For The Assessment Year 2012-13. The Appeal Was Admitted On 3Rd December, 2018 To Decide The Following Substantial Questions Of Law:- “I. Whether The Subject Income Could Be Taken To Have Accrued In India Only For The Reason That It Was Shown In The Balance Sheet Of The Assessee ?

Transfer Pricing, Kolkata & Ors. in W.P. No. 369 of 2014. The learned Tribunal could not have ignored the said decision

PRINCIPAL COMMISSIONER OF INCOME TAX, KOLKATA vs. M/S JJ EXPORTS PVT. LTD

The appeal stands disposed of on the ground that the company has been wound up and

Bench: : The Hon’Ble Justice T.S. Sivagnanam & The Hon’Ble Justice Supratim Bhattacharya Date : September 5, 2022. Appearance: Ms. Smita Das De, Adv. … For Appellant Ms. Swapna Das, Adv. Mr. Siddhertha Das, Adv. …For Respondent Ga/1/2018(Ga/554/2018) The Court : We Have Heard Ms. Smita Das De, Learned Standing Counsel Appearing For The Appellant & Ms. Swapna Das & Mr. Siddhertha Das, Learned Advocates For The Respondent. There Is A Delay Of 127 Days In Filing This Appeal. We Have Perused The Affidavit Filed In Support Of The Application & We Find Sufficient Cause Has Not Been Shown To Prefer The Appeal Within The Period Of Limitation. Accordingly, The Application Is Allowed & The Delay In Filing The Appeal Is Condoned.

transfer pricing provision of comparing like with like for the purpose of conducting the bench marking study ? 3 v) Whether

PRINCIPAL COMMISSIONER OF INCOME TAX -I KOLKATA vs. M/S GKW LTD.

Bench: : The Hon’Ble Justice T.S. Sivagnanam & The Hon’Ble Justice Supratim Bhattacharya Date : September 22, 2022. Appearance: Mr. Sukumar Bhattacharyya, Adv. Ms. Sayani Bhattacharya, Adv. Ms. Swaralipi Sarkar, Adv. …For Appellant Mr. Tilak Mitra, Adv. …For Respondent The Court :- This Appeal Filed By The Assessee Under Section 260A Of The Income Tax Act, 1961 (The Act) Is Directed Against The Order Dated 5.1.2018 Passed By The Income Tax Appellate Tribunal “A” Bench, Kolkata In Miscellaneous Application No. 205/Kol/2017 Affirming The Order Dated 27Th September, 2017 Passed In Income Tax Appeal No. 1176/Kol/2017 By Which The Order Passed By The Commissioner Of Income Tax (Appeals) –22 Kolkata, [Cit(A)] Dated 15Th March, 2017 Was Affirmed, Which Order Of The [Cit(A)] Arose Out Of An Order Passed By The Assessing Officer Namely Deputy Commissioner Of Income Tax (International Taxation), Circle – 2 (1), Kolkata Dated 28Th January, 2016 For The Assessment Year 2012-13. The Appeal Was Admitted On 3Rd December, 2018 To Decide The Following Substantial Questions Of Law:- “I. Whether The Subject Income Could Be Taken To Have Accrued In India Only For The Reason That It Was Shown In The Balance Sheet Of The Assessee ?

Transfer Pricing, Kolkata & Ors. in W.P. No. 369 of 2014. The learned Tribunal could not have ignored the said decision

PRINCIPAL COMMISSIONER OF INCOME TAX 5 KOLKATA vs. PREMIER TIE UP PVT LTD

Bench: HON'BLE JUSTICE T. S. SIVAGNANAM,HON'BLE JUSTICE SUPRATIM BHATTACHARYA

transfer deeds together with the original share scrips to BulakidasBhaiya or his nominee- purchasers in respect ofthe shares standing in their names respectively in the Register of Members of the Claimant Company. f)In consideration of such sale of shares the Claimant Company will be entitled to set-off and/or adjust the price

PRINCIPAL COMMISSIONER OF INCOME TAX -3, KOLKATA vs. M/S. ITC LIMITED

Appeal is allowed to the extent indicated

Bench: HON'BLE JUSTICE SURYA PRAKASH KESARWANI,HON'BLE JUSTICE RAJARSHI BHARADWAJ

transfer of a right to enjoy such property made for a certain time in consideration for a price paid or promised

PRINCIPAL COMMISSIONER OF INCOME TAX-3, KOLKATA vs. M/S. EIH LTD

Bench: HON'BLE JUSTICE T. S. SIVAGNANAM,HON'BLE JUSTICE HIRANMAY BHATTACHARYYA

transfers the assets of that business to another assessable entity may take different forms and may have different legal effect. The assets of a business may be sold at a fixed price

THE COMMISSIONER OF INCOME TAX, KOLKATA -II, KOLKATA vs. M/S. MADANLAL LIMITED

Bench: : The Hon'Ble The Chief Justice T.S Sivagnanam -A N D- Hon'Ble Justice Chaitali Chatterjee (Das) Date : 28Th July, 2025. Appearance : Mr. Aryak Dutt, Adv. Mr. Prithu Dudhoria, Adv. …For Appellant.

transfer of the commodity or scrips: Provided that for the purposes of this clause- 4 (a) a contract in respect of raw materials or merchandise entered into by a person in the course of his manufacturing or merchanting business to guard against loss through future price

PRINCIPAL COMMISSIONER OF INCOME TAX, CENTRAL-1, KOLKATA vs. KRISHNA KUMAR PARSURAMKA

In the result, these appeals are allowed and the substantial

Bench: HON'BLE JUSTICE T. S. SIVAGNANAM,HON'BLE JUSTICE HIRANMAY BHATTACHARYYA

price of the shares on the exchange goes down automatically in proportion with the ratio of split and one does not see anything adverse happening in the scripts. Further the shares of the company were very thinly traded and gradually the value is jacked up to a desired level in a period of about one year so as to provide

PRINCIPAL COMMISSIONER OF INCOME TAX-SILIGURI vs. SHEKHAR AGARWAL

In the result, these appeals are allowed and the substantial

Bench: HON'BLE JUSTICE T. S. SIVAGNANAM,HON'BLE JUSTICE HIRANMAY BHATTACHARYYA

price of the shares on the exchange goes down automatically in proportion with the ratio of split and one does not see anything adverse happening in the scripts. Further the shares of the company were very thinly traded and gradually the value is jacked up to a desired level in a period of about one year so as to provide

PRINCIPAL COMMISSIONER OF INCOME TAX, SILIGURI vs. SRI SATYA NARAYAN SARIA

In the result, these appeals are allowed and the substantial

Bench: HON'BLE JUSTICE T. S. SIVAGNANAM,HON'BLE JUSTICE HIRANMAY BHATTACHARYYA

price of the shares on the exchange goes down automatically in proportion with the ratio of split and one does not see anything adverse happening in the scripts. Further the shares of the company were very thinly traded and gradually the value is jacked up to a desired level in a period of about one year so as to provide

PRINCIPAL COMMISSIONER OF INCOME TAX ASANSOL KOLKATA vs. RAKESH JHUNJHUNWALA

In the result, these appeals are allowed and the substantial

Bench: HON'BLE JUSTICE T. S. SIVAGNANAM,HON'BLE JUSTICE HIRANMAY BHATTACHARYYA

price of the shares on the exchange goes down automatically in proportion with the ratio of split and one does not see anything adverse happening in the scripts. Further the shares of the company were very thinly traded and gradually the value is jacked up to a desired level in a period of about one year so as to provide