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)

3) of the Act by order dated 09.02.2021. Aggrieved by the same, the assessee preferred appeal before the Commissioner of Income Tax (Appeals), Kolkata [CIT(A)]. The assessee contested the addition of Transfer Pricing Adjustment (TPA) by contending that the assessing officer/TPO erred in rejecting the economic analysis document as part of the Transfer Pricing Study Report undertaken

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

3. In terms of Section 144C(1), the National e-Assessment Centre forwarded to the petitioner a draft of the proposed assessment order dated March 16, 2021 incorporating the variation determined by the Transfer Pricing Officer. Along with the draft order, a notice of demand under Section 156 and a notice initiating penalty proceedings under Section 274 read with Section

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

Section 143(3) of the Income Tax Act, 1961 (hereinafter Page 5 of 77 referred to as ‘the Act, 1961’) relating to the assessment year 2006-07. 6. In appeal filed by the respondent ITC before the CIT[Appeal], the appeal was allowed and the receipt of the aforesaid amount of Rs.32.42 crores was held to be a capital receipt

PRINCIPAL COMMISSIONER OF INCOME TAX 1 KOLKATA vs. M/S ORCHID GRIHA NIRMAN PVT LTD

Bench: : The Hon’Ble Justice T.S. Sivagnanam A N D The Hon’Ble Justice Hiranmay Bhattacharyya Dated January 31, 2022. [Via Video Conference] Appearance : Mr. P.K. Bhowmick, Adv. Mr. Asok Bhowmick, Adv. … For The Appellant Mr. J.P. Khaitan, Sr. Adv. Ms. Swapna Das, Adv. Mr. Siddharth Das, Adv. ..For The Respondent The Court :- We Have Heard Mr. P.K. Bhowmick, Learned Standing Counsel For The Appellant/Revenue Duly Assisted By Mr. Asok

10 (2A) of the Act partners’ share in the total income of the firm is not to be included in the total income of the partner. Therefore, it was held that the there was no reason for initiating proceedings under section 147 of the Act. With regard to the applicability of Section 45(3) of the Act, the tribunal after

PRINCIPAL COMMISSIONER OF INCOME TAX-2, KOLKATA vs. M/S. CENTURY ENKA LIMITED

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

3 Joint APLs and such inventory was made pursuant to the order of the Hon'ble Division Bench dated 23rd August, 2012. Further, the Hon'ble Division Bench in the order dated 4th May, 2020 held that the unanimous report of Joint ALPs has not been disputed. Further, the inventory of assets records the share holding held by the estate

PRINCIPAL COMMISSIONER OF INCOME TAX-4, KOLKATA vs. M/S V2 RETAIL LTD.

Bench: HON'BLE JUSTICE T. S. SIVAGNANAM,HON'BLE JUSTICE BIVAS PATTANAYAK

3 Joint APLs and such inventory was made pursuant to the order of the Hon'ble Division Bench dated 23rd August, 2012. Further, the Hon'ble Division Bench in the order dated 4th May, 2020 held that the unanimous report of Joint ALPs has not been disputed. Further, the inventory of assets records the share holding held by the estate

PRINCIPAL COMMISSIONER OF INCOME TAX-4, KOLKATA vs. M/S. JAGANNATH BANWARILAL TEXOFABS PVT LTD

Bench: HON'BLE JUSTICE T. S. SIVAGNANAM,HON'BLE JUSTICE BIVAS PATTANAYAK

3 Joint APLs and such inventory was made pursuant to the order of the Hon'ble Division Bench dated 23rd August, 2012. Further, the Hon'ble Division Bench in the order dated 4th May, 2020 held that the unanimous report of Joint ALPs has not been disputed. Further, the inventory of assets records the share holding held by the estate

PRINCIPAL COMMISSIONER OF INCOME TAX-4, KOLKATA vs. M/S. J.J.EXPORTERS LTD.

Bench: HON'BLE JUSTICE T. S. SIVAGNANAM,HON'BLE JUSTICE BIVAS PATTANAYAK

3 Joint APLs and such inventory was made pursuant to the order of the Hon'ble Division Bench dated 23rd August, 2012. Further, the Hon'ble Division Bench in the order dated 4th May, 2020 held that the unanimous report of Joint ALPs has not been disputed. Further, the inventory of assets records the share holding held by the estate

PRINCIPAL COMMISSIONER OF INCOME TAX-5, KOLKATA vs. L D S CITY PROJECTS PVT LTD

Bench: HON'BLE JUSTICE T. S. SIVAGNANAM,HON'BLE JUSTICE BIVAS PATTANAYAK

3 Joint APLs and such inventory was made pursuant to the order of the Hon'ble Division Bench dated 23rd August, 2012. Further, the Hon'ble Division Bench in the order dated 4th May, 2020 held that the unanimous report of Joint ALPs has not been disputed. Further, the inventory of assets records the share holding held by the estate

PRINCIPAL COMMISSIONER OF INCOME TAX (CENTRAL-1), KOLKATA vs. M/S. RUNGTA MINES LTD

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

3 Joint APLs and such inventory was made pursuant to the order of the Hon'ble Division Bench dated 23rd August, 2012. Further, the Hon'ble Division Bench in the order dated 4th May, 2020 held that the unanimous report of Joint ALPs has not been disputed. Further, the inventory of assets records the share holding held by the estate

PRINCIPAL COMMISSIONER OF INCOME TAX-4, KOLKATA vs. M/S. TCG LIFESCIENCES LTD.

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

3 Joint APLs and such inventory was made pursuant to the order of the Hon'ble Division Bench dated 23rd August, 2012. Further, the Hon'ble Division Bench in the order dated 4th May, 2020 held that the unanimous report of Joint ALPs has not been disputed. Further, the inventory of assets records the share holding held by the estate

PRINCIPAL COMMISSIONER OF INCOME TAX-2, KOLKATA vs. M/S THE CALCUTTA TRAMWAYS COMPANY (1978) LTD.

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

3 Joint APLs and such inventory was made pursuant to the order of the Hon'ble Division Bench dated 23rd August, 2012. Further, the Hon'ble Division Bench in the order dated 4th May, 2020 held that the unanimous report of Joint ALPs has not been disputed. Further, the inventory of assets records the share holding held by the estate

PRINCIPAL COMMISSIONER OF INCOME TAX-1, KOLKATA vs. M/S. HEIGHT INSURANCE SERVICES LTD

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

3 Joint APLs and such inventory was made pursuant to the order of the Hon'ble Division Bench dated 23rd August, 2012. Further, the Hon'ble Division Bench in the order dated 4th May, 2020 held that the unanimous report of Joint ALPs has not been disputed. Further, the inventory of assets records the share holding held by the estate

PRINCIPAL CIT-14, KOLKATA vs. SHRI VISHWANATH GUPTA

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

3 Joint APLs and such inventory was made pursuant to the order of the Hon'ble Division Bench dated 23rd August, 2012. Further, the Hon'ble Division Bench in the order dated 4th May, 2020 held that the unanimous report of Joint ALPs has not been disputed. Further, the inventory of assets records the share holding held by the estate

RAJESH JAJODIA vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE 45 KOLKATA AND ORS

Bench: HON'BLE JUSTICE RAJESH BINDAL, CHIEF JUSTICE (ACTING),HON'BLE JUSTICE RAJARSHI BHARADWAJ

3 Joint APLs and such inventory was made pursuant to the order of the Hon'ble Division Bench dated 23rd August, 2012. Further, the Hon'ble Division Bench in the order dated 4th May, 2020 held that the unanimous report of Joint ALPs has not been disputed. Further, the inventory of assets records the share holding held by the estate

M/S SINGHI AND CO vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX VIII

Bench: HON'BLE JUSTICE RAJESH BINDAL, CHIEF JUSTICE (ACTING),HON'BLE JUSTICE ANIRUDDHA ROY

3 Joint APLs and such inventory was made pursuant to the order of the Hon'ble Division Bench dated 23rd August, 2012. Further, the Hon'ble Division Bench in the order dated 4th May, 2020 held that the unanimous report of Joint ALPs has not been disputed. Further, the inventory of assets records the share holding held by the estate

TCG LIFE SCIENCES PVT LTD vs. JOINT COMM OF INCOME TAX RANGE59 KOL AND ANR

Bench: HON'BLE JUSTICE RAJESH BINDAL, CHIEF JUSTICE (ACTING),HON'BLE JUSTICE ANIRUDDHA ROY

3 Joint APLs and such inventory was made pursuant to the order of the Hon'ble Division Bench dated 23rd August, 2012. Further, the Hon'ble Division Bench in the order dated 4th May, 2020 held that the unanimous report of Joint ALPs has not been disputed. Further, the inventory of assets records the share holding held by the estate

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

Bench: HON'BLE JUSTICE RAJESH BINDAL, CHIEF JUSTICE (ACTING),HON'BLE JUSTICE ANIRUDDHA ROY

3 Joint APLs and such inventory was made pursuant to the order of the Hon'ble Division Bench dated 23rd August, 2012. Further, the Hon'ble Division Bench in the order dated 4th May, 2020 held that the unanimous report of Joint ALPs has not been disputed. Further, the inventory of assets records the share holding held by the estate