SH. ASHISH JAIN,LUDHIANA vs. DCIT, CC-III, LUDHIANA

In the result, the ground no

Bench: SHRI. AAKASH DEEP JAIN (Vice President), SHRI. VIKRAM SINGH YADAV (Accountant Member)

capital gains on sale of shares. 11. In his submissions, the ld CIT/DR submitted that it is a clear case where incriminating material has been found during the course of search in terms of share certificates and the contract notes. It was submitted that both the AO as well as the Ld. CIT(A) have recorded a categorical finding that

SH. AKHIL JAIN,LUDHIANA vs. DCIT, CC-III, LUDHIANA

In the result, the ground no

Bench: SHRI. AAKASH DEEP JAIN (Vice President), SHRI. VIKRAM SINGH YADAV (Accountant Member)

capital gains on sale of shares. 11. In his submissions, the ld CIT/DR submitted that it is a clear case where incriminating material has been found during the course of search in terms of share certificates and the contract notes. It was submitted that both the AO as well as the Ld. CIT(A) have recorded a categorical finding that

SH. ASHISH JAIN,LUDHIANA vs. DCIT, CC-III, LUDHIANA

In the result, the ground no

Bench: SHRI. AAKASH DEEP JAIN (Vice President), SHRI. VIKRAM SINGH YADAV (Accountant Member)

capital gains on sale of shares. 11. In his submissions, the ld CIT/DR submitted that it is a clear case where incriminating material has been found during the course of search in terms of share certificates and the contract notes. It was submitted that both the AO as well as the Ld. CIT(A) have recorded a categorical finding that

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

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

capital expenditure. We are also not in agreement with the contention of the Ld. DR that these expenditures were not related with particular previous year but were related to many earlier years cannot be accepted as these products constitute a part of the closing stock for the instant year. 11. Now coming to the issue whether this expenditure has been

DCIT, CHANDIGARH vs. M/S WINSOME YARNS LTD., CHANDIGARH

In the result, all the appeals of the Revenue are dismissed

Bench: Shri Sanjay Garg & Dr. B.R.R. Kumar

permanent establishment or business connection in India. No IDS is required to be deducted as per the provision of section 195 of the Income Tax Act 1961 and DTAA is applicable to all payment covered by section 195 Similar issue came up for consideration of M/s IDS Infortech Ltd. vs. DCIT Circle 4(1), in IT A. No 52/Chd/2016 Assessment

DCIT, C-4(1), CHANDIGARH vs. M/S WINSOME YARNS LTD,, CHANDIGARH

In the result, all the appeals of the Revenue are dismissed

Bench: Shri Sanjay Garg & Dr. B.R.R. Kumar

permanent establishment or business connection in India. No IDS is required to be deducted as per the provision of section 195 of the Income Tax Act 1961 and DTAA is applicable to all payment covered by section 195 Similar issue came up for consideration of M/s IDS Infortech Ltd. vs. DCIT Circle 4(1), in IT A. No 52/Chd/2016 Assessment

DCIT, CHANDIGARH vs. M/S WINSOME TEXTILES INDUSTRIES LTD., CHANDIGARH

In the result, all the appeals of the Revenue are dismissed

Bench: Shri Sanjay Garg & Dr. B.R.R. Kumar

permanent establishment or business connection in India. No IDS is required to be deducted as per the provision of section 195 of the Income Tax Act 1961 and DTAA is applicable to all payment covered by section 195 Similar issue came up for consideration of M/s IDS Infortech Ltd. vs. DCIT Circle 4(1), in IT A. No 52/Chd/2016 Assessment

DCIT, CHANDIGARH vs. M/S WINSOME YARNS LTD., CHANDIGARH

In the result, all the appeals of the Revenue are dismissed

Bench: Shri Sanjay Garg & Dr. B.R.R. Kumar

permanent establishment or business connection in India. No IDS is required to be deducted as per the provision of section 195 of the Income Tax Act 1961 and DTAA is applicable to all payment covered by section 195 Similar issue came up for consideration of M/s IDS Infortech Ltd. vs. DCIT Circle 4(1), in IT A. No 52/Chd/2016 Assessment

M/S JAIN AMAR CLOTHING PVT. LTD.,LUDHIANA vs. DCIT, CC-III, LUDHIANA

In the result, the ground no

Bench: SHRI. AAKASH DEEP JAIN (Vice President), SHRI. VIKRAM SINGH YADAV (Accountant Member)

Capital & Premium in the assessee company consequent to the search action and the above fact was supported by the report sent by the DDIT Investigation Unit-2(1), Kolkata along with statements recorded of the ex-directors of the investor companies u/s 131 of the Act. 10.1 It was submitted that there is no dispute that the Hon’ble Supreme

M/S ORBIT RESORTS (P) LTD.,CHANDIGARH vs. DCIT, C-1(1), CHANDIGARH

In the result, appeals of the Assessee stands allowed

Bench: or at the time of hearing of appeal, with the permission of the Hon'ble Income Tax Appellate Tribunal.

permanent establishment in India and that TDS would have been deductible only if Income was chargeable to tax in India. Thereafter, the learned assessing officer has controverted the 4 findings of the assessee. The AO has discussed his finding and while concluding relied on the judgement of SKF Boilers and Dryers Pvt, which is referred to at page number

M/S ORBIT RESORTS (P) LTD.,CHANDIGARH vs. DCIT, C-1(1), CHANDIGARH

In the result, appeals of the Assessee stands allowed

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY, AM आयकर अपील सं. / ITA No. 343 /Chd/2019 निर्धारण वर्ष / Assessment Years : 2013-14 M/s Orbit Resorts Limited बनाम The DCIT H.No. 256, Sector 9C, Chandigarh Circle 1(1), Chandigarh स्थायी लेखा सं./PAN NO: AAACO4024H अपीलार्थी/Appellant प्रत्यर्थी/Respondent आयकर अपील सं. / ITA No. 988 /Chd/2019 निर्धारण वर्ष / Assessment Years : 2014-15 M/s Orbit Resorts Limited बनाम H.No. 256, Sector 9C, Chandigarh The DCIT Circle 1(1), Chandigarh

permanent establishment in India and that TDS would have been deductible only if Income was chargeable to tax in India. Thereafter, the learned assessing officer has controverted the 4 findings of the assessee. The AO has discussed his finding and while concluding relied on the judgement of SKF Boilers and Dryers Pvt, which is referred to at page number

ACIT,, LUDHIANA vs. M/S VARDHMAN TEXTILES LTD.,, LUDHIANA

In the result appeals of the Assessee and the Revenue are partly allowed

Bench: Smt. Diva Singh & Dr. B.R.R. Kumarassessment Year: 2002-03

gains derived from the eligible business. The words “derived from” is narrower in connotation as compared to the words “attributable to”. By using the expression “derived from”, Parliament intended to cover sources not beyond the first degree; (5) Though the object behind DEPB etc is to neutralize the incidence of customs duty payment on the import content of export product

ACIT,, LUDHIANA vs. M/S VARDHMAN TEXTILES LTD.,, LUDHIANA

In the result appeals of the Assessee and the Revenue are partly allowed

Bench: Smt. Diva Singh & Dr. B.R.R. Kumarassessment Year: 2002-03

gains derived from the eligible business. The words “derived from” is narrower in connotation as compared to the words “attributable to”. By using the expression “derived from”, Parliament intended to cover sources not beyond the first degree; (5) Though the object behind DEPB etc is to neutralize the incidence of customs duty payment on the import content of export product

VARDHMAN TEXTILE LTD.,LUDHIANA vs. ACIT, LUDHIANA

In the result appeals of the Assessee and the Revenue are partly allowed

Bench: Smt. Diva Singh & Dr. B.R.R. Kumarassessment Year: 2002-03

gains derived from the eligible business. The words “derived from” is narrower in connotation as compared to the words “attributable to”. By using the expression “derived from”, Parliament intended to cover sources not beyond the first degree; (5) Though the object behind DEPB etc is to neutralize the incidence of customs duty payment on the import content of export product

ACIT, LUDHIANA vs. M/S VARDHMAN TEXTILES LTD., LUDHIANA

In the result appeals of the Assessee and the Revenue are partly allowed

Bench: Smt. Diva Singh & Dr. B.R.R. Kumarassessment Year: 2002-03

gains derived from the eligible business. The words “derived from” is narrower in connotation as compared to the words “attributable to”. By using the expression “derived from”, Parliament intended to cover sources not beyond the first degree; (5) Though the object behind DEPB etc is to neutralize the incidence of customs duty payment on the import content of export product

ACIT, LUDHIANA vs. VARDHMAN TEXTILES LTD., LUDHIANA

In the result appeals of the Assessee and the Revenue are partly allowed

Bench: Smt. Diva Singh & Dr. B.R.R. Kumarassessment Year: 2002-03

gains derived from the eligible business. The words “derived from” is narrower in connotation as compared to the words “attributable to”. By using the expression “derived from”, Parliament intended to cover sources not beyond the first degree; (5) Though the object behind DEPB etc is to neutralize the incidence of customs duty payment on the import content of export product

M/S VARDHMAN TEXTILES LTD.,LUDHIANA vs. ACIT, LUDHIANA

In the result appeals of the Assessee and the Revenue are partly allowed

Bench: Smt. Diva Singh & Dr. B.R.R. Kumarassessment Year: 2002-03

gains derived from the eligible business. The words “derived from” is narrower in connotation as compared to the words “attributable to”. By using the expression “derived from”, Parliament intended to cover sources not beyond the first degree; (5) Though the object behind DEPB etc is to neutralize the incidence of customs duty payment on the import content of export product

M/S VARDHMAN TEXTILES LTD.,,LUDHIANA vs. ADDL. CIT,, LUDHIANA

In the result appeals of the Assessee and the Revenue are partly allowed

Bench: Smt. Diva Singh & Dr. B.R.R. Kumarassessment Year: 2002-03

gains derived from the eligible business. The words “derived from” is narrower in connotation as compared to the words “attributable to”. By using the expression “derived from”, Parliament intended to cover sources not beyond the first degree; (5) Though the object behind DEPB etc is to neutralize the incidence of customs duty payment on the import content of export product