DCIT, C-1(1), CHANDIGARH vs. M/S STYLAM INDUSTRIES LTD., CHANDIGARH

In the result, the Department’s appeal in for assessment year

Bench: SHRI A.D.JAIN (Vice President), SHRI VIKRAM SINGH YADAV (Accountant Member)

TDS ignoring the detailed finding of the assessing officer that as per section 5 and section 9 of the Act the income is deemed to accrue or arise in India even if the services by the commission agents have been rendered abroad. Further since the right to receive the commission arises in India, the income of such commission agents

M/S STYLAM INDUSTRIES LTD.,CHANDIGARH vs. DCIT, C-1(1), CHANDIGARH

In the result, the Department’s appeal in for assessment year

Bench: SHRI A.D.JAIN (Vice President), SHRI VIKRAM SINGH YADAV (Accountant Member)

TDS ignoring the detailed finding of the assessing officer that as per section 5 and section 9 of the Act the income is deemed to accrue or arise in India even if the services by the commission agents have been rendered abroad. Further since the right to receive the commission arises in India, the income of such commission agents

DCIT, C-1(1), CHANDIGARH vs. M/S STYLAM INDUSTRIES LTD., CHANDIGARH

In the result, the Department’s appeal in for assessment year

Bench: SHRI A.D.JAIN (Vice President), SHRI VIKRAM SINGH YADAV (Accountant Member)

TDS ignoring the detailed finding of the assessing officer that as per section 5 and section 9 of the Act the income is deemed to accrue or arise in India even if the services by the commission agents have been rendered abroad. Further since the right to receive the commission arises in India, the income of such commission agents

ACIT, CIRCLE 1(1), CHANDIGARH vs. M/S SML ISUZU LTD., CHANDIGARH

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member), SHRI. PARESH M. JOSHI (Judicial Member)

TDS particulars was wholly unjustified. [Para 7] As regards second ground for reopening the assessment, the dividend income received during the year was claimed as exempt and the same was accepted in the assessment order passed under section 143(3). The reason for reopening the assessment was that in the absence of particulars it could not be said that

DCIT, C-1, (E), CHANDIGARH vs. M/S MANAV MANGAL SOCIETY, CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

254 ITR 377 (Del) opined- 2.3 Further, the Hon'ble SC in CIT vs. Delhi Safe Deposits Co. Ltd. [1982] 133 ITR 756 (SC), gave a view that- 2.4 Taking in consideration the ratio laid down by the Hon’ble SC, the appellant wishes to apply the same to its own case. The Learned AO, in the impugned order made

DCIT, C-1, (E), CHANDIGARH vs. M/S MANAV MANGAL SOCIETY, CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

254 ITR 377 (Del) opined- 2.3 Further, the Hon'ble SC in CIT vs. Delhi Safe Deposits Co. Ltd. [1982] 133 ITR 756 (SC), gave a view that- 2.4 Taking in consideration the ratio laid down by the Hon’ble SC, the appellant wishes to apply the same to its own case. The Learned AO, in the impugned order made

DCIT,CIRCLE-1(EXEMPTION), CHANDIGARH vs. M/S MANAV MANGAL SCHOOL( MANAV MANGAL SOCIETY), CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

254 ITR 377 (Del) opined- 2.3 Further, the Hon'ble SC in CIT vs. Delhi Safe Deposits Co. Ltd. [1982] 133 ITR 756 (SC), gave a view that- 2.4 Taking in consideration the ratio laid down by the Hon’ble SC, the appellant wishes to apply the same to its own case. The Learned AO, in the impugned order made

DCIT, C-1, (E), CHANDIGARH vs. M/S MANAV MANGAL SOCIETY, CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

254 ITR 377 (Del) opined- 2.3 Further, the Hon'ble SC in CIT vs. Delhi Safe Deposits Co. Ltd. [1982] 133 ITR 756 (SC), gave a view that- 2.4 Taking in consideration the ratio laid down by the Hon’ble SC, the appellant wishes to apply the same to its own case. The Learned AO, in the impugned order made

M/S MANAV MANGAL SOCIETY,CHANDIGARH vs. DCIT, C-1, (E), CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

254 ITR 377 (Del) opined- 2.3 Further, the Hon'ble SC in CIT vs. Delhi Safe Deposits Co. Ltd. [1982] 133 ITR 756 (SC), gave a view that- 2.4 Taking in consideration the ratio laid down by the Hon’ble SC, the appellant wishes to apply the same to its own case. The Learned AO, in the impugned order made

M/S MANAV MANGAL SOCIETY,CHANDIGARH vs. DCIT, C-1, (E), CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

254 ITR 377 (Del) opined- 2.3 Further, the Hon'ble SC in CIT vs. Delhi Safe Deposits Co. Ltd. [1982] 133 ITR 756 (SC), gave a view that- 2.4 Taking in consideration the ratio laid down by the Hon’ble SC, the appellant wishes to apply the same to its own case. The Learned AO, in the impugned order made

DCIT, C-1, (E), CHANDIGARH vs. M/S MANAV MANGAL SOCIETY, CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

254 ITR 377 (Del) opined- 2.3 Further, the Hon'ble SC in CIT vs. Delhi Safe Deposits Co. Ltd. [1982] 133 ITR 756 (SC), gave a view that- 2.4 Taking in consideration the ratio laid down by the Hon’ble SC, the appellant wishes to apply the same to its own case. The Learned AO, in the impugned order made

DCIT, C-1, (E), CHANDIGARH vs. M/S MANAV MANGAL SOCIETY, CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

254 ITR 377 (Del) opined- 2.3 Further, the Hon'ble SC in CIT vs. Delhi Safe Deposits Co. Ltd. [1982] 133 ITR 756 (SC), gave a view that- 2.4 Taking in consideration the ratio laid down by the Hon’ble SC, the appellant wishes to apply the same to its own case. The Learned AO, in the impugned order made

M/S PUNJAB TOURISM DEVELOPMENET CORPORATION LIMITED,CHANDIGARH vs. DCIT,CIRCLE-1(1), CHANDIGARH

Appeal of the assessee is allowed

Bench: Ao)

TDS interest of Rs. 1,658/- (supra) and amount of Rs. 32,20,737/- (supra). The impugned assessment order of the ld. A.O. is dated 18.11.2016, wherein aggregate addition is of Rs. 52,70,767/-(supra amounts). Assessed loss is of Rs. 63,18,868/- against returned loss of (-)Rs. 1,15,89,635/-. 11. The Assessee being aggrieved

M/S PUNJAB TOURISM DEVELOPMENET CORPORATION LIMITED,CHANDIGARH vs. DCIT,CIRCLE-1(1), CHANDIGARH

Appeal of the assessee is allowed

Bench: Ao)

TDS interest of Rs. 1,658/- (supra) and amount of Rs. 32,20,737/- (supra). The impugned assessment order of the ld. A.O. is dated 18.11.2016, wherein aggregate addition is of Rs. 52,70,767/-(supra amounts). Assessed loss is of Rs. 63,18,868/- against returned loss of (-)Rs. 1,15,89,635/-. 11. The Assessee being aggrieved

M/S PUNJAB TOURISM DEVELOPMENET CORPORATION LIMITED,CHANDIGARH vs. DCIT,CIRCLE-1(1), CHANDIGARH

Appeal of the assessee is allowed

Bench: Ao)

TDS interest of Rs. 1,658/- (supra) and amount of Rs. 32,20,737/- (supra). The impugned assessment order of the ld. A.O. is dated 18.11.2016, wherein aggregate addition is of Rs. 52,70,767/-(supra amounts). Assessed loss is of Rs. 63,18,868/- against returned loss of (-)Rs. 1,15,89,635/-. 11. The Assessee being aggrieved

M/S PUNJAB TOURISM DEVELOPMENET CORPORATION LIMITED,CHANDIGARH vs. DCIT,CIRCLE-1(1), CHANDIGARH

Appeal of the assessee is allowed

Bench: Ao)

TDS interest of Rs. 1,658/- (supra) and amount of Rs. 32,20,737/- (supra). The impugned assessment order of the ld. A.O. is dated 18.11.2016, wherein aggregate addition is of Rs. 52,70,767/-(supra amounts). Assessed loss is of Rs. 63,18,868/- against returned loss of (-)Rs. 1,15,89,635/-. 11. The Assessee being aggrieved

M/S GLAXOSMITHKLINE ASIA PVT. LTD.,GURGAON vs. DCIT, CHANDIGARH

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

TDS u/s 195 of the Act and therefore provisions of section 40(a)(i) are attracted. Appellant has also submitted that the entire disallowance is not called for in terms of CBDT circular no 2/2014 and 3/2015. I have perused these circulars and it is seen that these circulars have been followed by the assessing officer

SCOTT EDIL ADVANCE RESEARCH LABORATORIES AND EDUCATION LIMITED,CHANDIGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, CHANDIGARH

1) Tmi 629 –\n(Delhi High Court: (2013] 351 Itr 20\nAdditions u/s 69 - search conducted u/s 132 - notice u/s 153C - valuation of properties\nreferred to District Valuation Officer (DVO) - ITAT deleted the addition - Held that:- No\nreason to differ from the view taken by the Tribunal as no material was found in the\nsearch and seizure operations, which would

DY. COMMISSIONER OF INCOME TAX, CIRCLE-4,, AAYAKAR BHAWAN vs. ROCKMAN INDUSTRIES LIMITED, -

In the result order of CIT(A) is sustained as passed and the appeal of the Revenue is partly allowed for statistical purposes

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member), SHRI. PARESH M. JOSHI (Judicial Member)

254 dt. 05/03/2018 was issued and served upon the assessee on 06/03/2018. 2.5 A notice under section 142(1) dt. 19/11/2018 alongwith detailed questionnaire was issued and served upon the assessee on 20.11.2018. 2.6 We reproduce below Para 7 and 13 of order of this Tribunal (supra) “ 7. We have considered the rival contentions and have also gone through