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 HC) 2

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 32 of the Act 1961, held it to be a “license”. In the present set of facts the question of nomination or transfer of license is not involved. Even at the time of execution of the operating license agreement in question no amount was paid by ITC to ELEL as cost of acquisition of license. 19. M/S ELEL

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

price of the shares sold and transferred by the Bagri Group of respondents to BulakidasBhaiya and his nominees within a period of 7 days' from date of the handing over of the share scrips and properly executed transfer deeds by the sellers to the purchasers in terms of this final Award. h) All other claims by parties against each other

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

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

price paid for or attributable to an asset exceeds the written down the value of the asset, proviso 2 to section 10(2)(vii) would ex facie be attracted. Where the person carrying on the business transfers the assets to a company in consideration of allotment of shares, it would be a case of exchange and not of sale

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.

2 of Section 9 states that every person, who has constructed a Captive Generating Plant and maintains and operates such plant shall have the right to open access for the purpose of carrying electricity from his Captive Generating Plant to the destination of his use. Section 42 of the Act deals with duties of the distribution licensees and open access

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