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)

Section 80IA (8) of the Act. The CIT(A) noted that the assessee conducted a Transfer Pricing Study for the same which revealed that after undertaking FAR analysis, it was concluded that the CPPs were electricity providers to the manufacturing units bearing normal risk associated with the said activity and that the 1 (223 Taxman 234) (Chattisgarh

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

section 36(1) of the said Act. The parties have made detailed, elaborate submissions over 7 days, spread over a period of 4 months. FACTS OF THE CASE 9. The dispute is between the Bagri group, headed by Gopal Das Bagri and his sons on one side, and the Bhaiya group, headed by Bulaki Das Bhaiya on the other side

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

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

9(1) read with section 195 of the Income Tax Act? (xi) Whether on the facts and in the circumstances of the case, the Learned Tribunal erred in law in deleting the disallowance under section 40(a)(i) of Rs.3,06,20,256/- paid as commission to non-resident by considering the facts pertaining to such expenses were not produced

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 adjustment. Thereafter the assessing officer called for various details and the matter was discussed with the assessee. The issue which was considered by the assessing officer are with regard to the 6 unexpired discount on forward contracts, market to market loss of forward contracts, designed charges, non-deduction of TDS for information technology expense, information technology expense, patent

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

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 270A were also issued. Being aggrieved

PR CIT 9, KOLKATA vs. MANISHA TIKMANI

In the result, these appeals are allowed and the substantial

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

9 shares for every 1 share held and since she had purchased 500 equity shares she received 4500 further equity shares as bonus which were also transferred to D-Mat account. Further it was stated that the equity shares of the company were sub-divided i.e for every one share having nominal value of Rs. 10, the equity holders

PRINCIPAL COMMISSIONER OF INCOME TAX-5, KOLKATA vs. POOJA JHUNJHUNWALA

In the result, these appeals are allowed and the substantial

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

9 shares for every 1 share held and since she had purchased 500 equity shares she received 4500 further equity shares as bonus which were also transferred to D-Mat account. Further it was stated that the equity shares of the company were sub-divided i.e for every one share having nominal value of Rs. 10, the equity holders

PRINCIPAL COMMISSIONER OF INCOME TAX ASANSOL KOLKATA vs. RAJESH JHUNJHUNWALA

In the result, these appeals are allowed and the substantial

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

9 shares for every 1 share held and since she had purchased 500 equity shares she received 4500 further equity shares as bonus which were also transferred to D-Mat account. Further it was stated that the equity shares of the company were sub-divided i.e for every one share having nominal value of Rs. 10, the equity holders

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

9 shares for every 1 share held and since she had purchased 500 equity shares she received 4500 further equity shares as bonus which were also transferred to D-Mat account. Further it was stated that the equity shares of the company were sub-divided i.e for every one share having nominal value of Rs. 10, the equity holders

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

9 shares for every 1 share held and since she had purchased 500 equity shares she received 4500 further equity shares as bonus which were also transferred to D-Mat account. Further it was stated that the equity shares of the company were sub-divided i.e for every one share having nominal value of Rs. 10, the equity holders

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

9 shares for every 1 share held and since she had purchased 500 equity shares she received 4500 further equity shares as bonus which were also transferred to D-Mat account. Further it was stated that the equity shares of the company were sub-divided i.e for every one share having nominal value of Rs. 10, the equity holders

PRINCIPAL COMMISSIONER OF INCOME TAX, SILIGURI vs. PRAKASHO DEVI SARIA

In the result, these appeals are allowed and the substantial

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

9 shares for every 1 share held and since she had purchased 500 equity shares she received 4500 further equity shares as bonus which were also transferred to D-Mat account. Further it was stated that the equity shares of the company were sub-divided i.e for every one share having nominal value of Rs. 10, the equity holders

PRINCIPAL COMMISSIONER OF INCOME TAX-5, KOLKATA vs. AAYUSH JHUNJHUNWALA

In the result, these appeals are allowed and the substantial

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

9 shares for every 1 share held and since she had purchased 500 equity shares she received 4500 further equity shares as bonus which were also transferred to D-Mat account. Further it was stated that the equity shares of the company were sub-divided i.e for every one share having nominal value of Rs. 10, the equity holders

PRINCIPAL COMMISSIONER OF INCOME TAX CENTRAL -1, KOLKATA vs. SURAJ SAHANA

In the result, these appeals are allowed and the substantial

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

9 shares for every 1 share held and since she had purchased 500 equity shares she received 4500 further equity shares as bonus which were also transferred to D-Mat account. Further it was stated that the equity shares of the company were sub-divided i.e for every one share having nominal value of Rs. 10, the equity holders

PRINCIPAL COMMISSIONER OF INCOME TAX 9, KOLKATA vs. PUSPA DEVI TIKMANI

In the result, these appeals are allowed and the substantial

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

9 shares for every 1 share held and since she had purchased 500 equity shares she received 4500 further equity shares as bonus which were also transferred to D-Mat account. Further it was stated that the equity shares of the company were sub-divided i.e for every one share having nominal value of Rs. 10, the equity holders

PRINCIPAL COMMISSIONER OF INCOME TAX-15, KOLKATA vs. SMT. BABITA AGARWAL

In the result, these appeals are allowed and the substantial

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

9 shares for every 1 share held and since she had purchased 500 equity shares she received 4500 further equity shares as bonus which were also transferred to D-Mat account. Further it was stated that the equity shares of the company were sub-divided i.e for every one share having nominal value of Rs. 10, the equity holders

PRINCIPAL COMMISSIONER OF INCOME TAX-5, KOLKATA vs. JEMISH SHAH

In the result, these appeals are allowed and the substantial

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

9 shares for every 1 share held and since she had purchased 500 equity shares she received 4500 further equity shares as bonus which were also transferred to D-Mat account. Further it was stated that the equity shares of the company were sub-divided i.e for every one share having nominal value of Rs. 10, the equity holders

PRINCIPAL COMMISSIONER OF INCOME TAX vs. MUKESH SARAOGI (HUF)

In the result, these appeals are allowed and the substantial

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

9 shares for every 1 share held and since she had purchased 500 equity shares she received 4500 further equity shares as bonus which were also transferred to D-Mat account. Further it was stated that the equity shares of the company were sub-divided i.e for every one share having nominal value of Rs. 10, the equity holders