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

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

disallowance made of amount paid to M/s GlaxoSmithKline Biological S.A., Belgium , being Rs.16,08,70,538/- for purchase of vaccine, on account of non-deduction of tax at source thereon ,holding that there was a permanent establishment

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(P.L) in India. The circular of CBDT. Double Taxation Avoidance Agreement (DTAA) have been brushed aside by the Ld.AO in a casual way with ;i predetermined mind to disallow

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(P.L) in India. The circular of CBDT. Double Taxation Avoidance Agreement (DTAA) have been brushed aside by the Ld.AO in a casual way with ;i predetermined mind to disallow

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(P.L) in India. The circular of CBDT. Double Taxation Avoidance Agreement (DTAA) have been brushed aside by the Ld.AO in a casual way with ;i predetermined mind to disallow

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(P.L) in India. The circular of CBDT. Double Taxation Avoidance Agreement (DTAA) have been brushed aside by the Ld.AO in a casual way with ;i predetermined mind to disallow

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

disallowing the commission paid abroad by invoking the provisions of Section 40(a)(i) of the Income Tax Act, 1961. 3. That the appellant craves to add, amend or alter any ground of appeal before or at the time of hearing of appeal, with the permission of the Hon’ble Income Tax Appellate Tribunal. 5. Briefly the facts

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.

disallowing the commission paid abroad by invoking the provisions of Section 40(a)(i) of the Income Tax Act, 1961. 3. That the appellant craves to add, amend or alter any ground of appeal before or at the time of hearing of appeal, with the permission of the Hon’ble Income Tax Appellate Tribunal. 5. Briefly the facts

M/S GLAXO SMITHKLINE ASIA PVT. LTD.,NABHA vs. DCIT, C-4(1), CHANDIGARH

In the result, all the appeals of the assessee and the Revenue, stand partly allowed for statistical purposes

disallowance of Rs.5,10,74,000, being 1/3rd of the expenditure on advertisement and promotion of Rs. 15,32,22,000 allegedly on the ground that the said expenditure resulted in promotion of brand name owned by the foreign company. 1.1 That the CIT(A) erred on facts and in law in not appreciating that the assessee is the exclusive

ACIT, CHANDIGARH vs. M/S GLAXO SMITHKLINE ASIA PVT. LTD., GURGAON

In the result, all the appeals of the assessee and the Revenue, stand partly allowed for statistical purposes

disallowance of Rs.5,10,74,000, being 1/3rd of the expenditure on advertisement and promotion of Rs. 15,32,22,000 allegedly on the ground that the said expenditure resulted in promotion of brand name owned by the foreign company. 1.1 That the CIT(A) erred on facts and in law in not appreciating that the assessee is the exclusive

GLAXOSMITHKLINE ASIA PVT. LTD.,GURGAON vs. ACIT, CHANDIGARH

In the result, all the appeals of the assessee and the Revenue, stand partly allowed for statistical purposes

disallowance of Rs.5,10,74,000, being 1/3rd of the expenditure on advertisement and promotion of Rs. 15,32,22,000 allegedly on the ground that the said expenditure resulted in promotion of brand name owned by the foreign company. 1.1 That the CIT(A) erred on facts and in law in not appreciating that the assessee is the exclusive

GLAXOSMITHKLINE ASIA PVT. LTD.,GURGAON vs. DCIT, CHANDIGARH

In the result, all the appeals of the assessee and the Revenue, stand partly allowed for statistical purposes

disallowance of Rs.5,10,74,000, being 1/3rd of the expenditure on advertisement and promotion of Rs. 15,32,22,000 allegedly on the ground that the said expenditure resulted in promotion of brand name owned by the foreign company. 1.1 That the CIT(A) erred on facts and in law in not appreciating that the assessee is the exclusive

GLAXOSMITHKLINE ASIA PVT. LTD.,GURGAON vs. DCIT, CHANDIGARH

In the result, all the appeals of the assessee and the Revenue, stand partly allowed for statistical purposes

disallowance of Rs.5,10,74,000, being 1/3rd of the expenditure on advertisement and promotion of Rs. 15,32,22,000 allegedly on the ground that the said expenditure resulted in promotion of brand name owned by the foreign company. 1.1 That the CIT(A) erred on facts and in law in not appreciating that the assessee is the exclusive

ACIT, CHANDIGARH vs. M/S GLAXO SMITHKLINE ASIA PVT. LTD., GURGAON

In the result, all the appeals of the assessee and the Revenue, stand partly allowed for statistical purposes

disallowance of Rs.5,10,74,000, being 1/3rd of the expenditure on advertisement and promotion of Rs. 15,32,22,000 allegedly on the ground that the said expenditure resulted in promotion of brand name owned by the foreign company. 1.1 That the CIT(A) erred on facts and in law in not appreciating that the assessee is the exclusive

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

In the result, all the appeals of the assessee and the Revenue, stand partly allowed for statistical purposes

disallowance of Rs.5,10,74,000, being 1/3rd of the expenditure on advertisement and promotion of Rs. 15,32,22,000 allegedly on the ground that the said expenditure resulted in promotion of brand name owned by the foreign company. 1.1 That the CIT(A) erred on facts and in law in not appreciating that the assessee is the exclusive

GLAXOSMITHKLINE ASIA PVT. LTD.,GURGAON vs. ACIT, CHANDIGARH

In the result, all the appeals of the assessee and the Revenue, stand partly allowed for statistical purposes

disallowance of Rs.5,10,74,000, being 1/3rd of the expenditure on advertisement and promotion of Rs. 15,32,22,000 allegedly on the ground that the said expenditure resulted in promotion of brand name owned by the foreign company. 1.1 That the CIT(A) erred on facts and in law in not appreciating that the assessee is the exclusive

ACIT, CHANDIGARH vs. M/S GLAXO SMITHKLINE ASIA PVT. LTD., GURGAON

In the result, all the appeals of the assessee and the Revenue, stand partly allowed for statistical purposes

disallowance of Rs.5,10,74,000, being 1/3rd of the expenditure on advertisement and promotion of Rs. 15,32,22,000 allegedly on the ground that the said expenditure resulted in promotion of brand name owned by the foreign company. 1.1 That the CIT(A) erred on facts and in law in not appreciating that the assessee is the exclusive

M/S GLAXO SMITHKLINE ASIA PVT. LTD.,GURGAON vs. ACIT, C-4(1), CHANDIGARH

In the result, all the appeals of the assessee and the Revenue, stand partly allowed for statistical purposes

disallowance of Rs.5,10,74,000, being 1/3rd of the expenditure on advertisement and promotion of Rs. 15,32,22,000 allegedly on the ground that the said expenditure resulted in promotion of brand name owned by the foreign company. 1.1 That the CIT(A) erred on facts and in law in not appreciating that the assessee is the exclusive

M/S GLAXO SMITHKLINE ASIA PVT. LTD.,GURGAON vs. ACIT, C-4(1), CHANDIGARH

In the result, all the appeals of the assessee and the Revenue, stand partly allowed for statistical purposes

disallowance of Rs.5,10,74,000, being 1/3rd of the expenditure on advertisement and promotion of Rs. 15,32,22,000 allegedly on the ground that the said expenditure resulted in promotion of brand name owned by the foreign company. 1.1 That the CIT(A) erred on facts and in law in not appreciating that the assessee is the exclusive

ACIT, CHANDIGARH vs. M/S GLAXO SMITHKLINE ASIA PVT. LTD., GURGAON

In the result, all the appeals of the assessee and the Revenue, stand partly allowed for statistical purposes

disallowance of Rs.5,10,74,000, being 1/3rd of the expenditure on advertisement and promotion of Rs. 15,32,22,000 allegedly on the ground that the said expenditure resulted in promotion of brand name owned by the foreign company. 1.1 That the CIT(A) erred on facts and in law in not appreciating that the assessee is the exclusive

DCIT vs. M/S THE VED PARKASH MUKAND LAL, YAMUNANAGAR

In the result, the assessee’s appeals, for both the years, stand dismissed

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं. / Ita No.824/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2005-06) & 2. आयकर अपील सं. / Ita No.825/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2006-07) The Ved Prakash Mukand Lal Dcit Educational Society Circle Yamuna Nagar बनाम/ Vs. (Radaur, Yamuna Nagar) Haryana C/O Shri Tej Mohan Singh (Advocate) #527, Sector – 10D, Chandigarh "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaatv-4812-B (अपीलाथ"/Appellant) (""थ" / Respondent) : & 3. आयकर अपील सं. / Ita No.833/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2005-06) & 4. आयकर अपील सं. / Ita No.832/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2006-07) Dcit The Ved Prakash Mukand Lal Circle Yamuna Nagar Educational Society बनाम/ Haryana (Radaur, Yamuna Nagar) Vs. C/O Shri Tej Mohan Singh (Advocate) #527, Sector – 10D, Chandigarh "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaatv-4812-B (अपीलाथ"/Appellant) (""थ" / Respondent) : अपीलाथ"कीओरसे/ Appellant By : Sh. Tejmohan Singh (Advocate) – Ld. Ar ""थ"कीओरसे/Respondent By : Smt. Yamini (Cit) - Ld. Dr (Virtual)

disallowance of carry forward of excess expenditure over its income for the earlier year to be adjusted in the subsequent year. 5. The learned CIT(A) by a common order dated 31.07.2014 has refused to accept the ground challenging the reopening and the issue of carry forward of excess expenditure over the income in the subsequent year. The learned