M/S NECTAR LIFESCIENCE LTD.,CHANDIGARH vs. DCIT, C-1(1), CHANDIGARH

In the result, appeal of the assessee is allowed

Income-tax Act, 1961 are as unden- 1. Comparable Uncontrolled Price Method 2. Transactional Net Margin Method 3. Resale Price Method 4. Cost Plus Method 5. Profit Split Method and 6. Any Other Method prescribed by the Board. 7.13 The assessee has submitted that they have applied CUP method for benchmarking the transaction. Now the issue arises is that whether

ACIT,CIRCLE-1, LUDHIANA vs. M/S VARDHMAN TEXTILES LTD., LUDHIANA

In the result, appeals of the Assessee are partly allowed whereas the Cross appeals of the Revenue are dismissed

Bench: SHRI. AAKASH DEEP JAIN (Vice President), SHRI. SHRI. KRINWANT SAHAY (Accountant Member)

income of Rs. 65,47,626/-. Its breakup is rebate and discount of Rs. 55,97,132/-, recovery from contractor of Rs. 7,24,136/- and other miscellaneous receipts of Rs. 2,26,358/-. 16.5 Regarding the rebate and discount, this comprises of Turnover discount received from suppliers. It is undisputedly relates to material purchases, which is, obviously the business

VARDHMAN TEXTILES LIMITED,LUDHIANA vs. ACIT-CIRCLE-1, LUDHIANA

In the result, appeals of the Assessee are partly allowed whereas the Cross appeals of the Revenue are dismissed

Bench: SHRI. AAKASH DEEP JAIN (Vice President), SHRI. SHRI. KRINWANT SAHAY (Accountant Member)

income of Rs. 65,47,626/-. Its breakup is rebate and discount of Rs. 55,97,132/-, recovery from contractor of Rs. 7,24,136/- and other miscellaneous receipts of Rs. 2,26,358/-. 16.5 Regarding the rebate and discount, this comprises of Turnover discount received from suppliers. It is undisputedly relates to material purchases, which is, obviously the business

DCIT, C-1, LUDHIANA vs. M/S VARDHMAN TEXTILES LIMITED, LUDHIANA

In the result, appeals of the Assessee are partly allowed whereas the Cross appeals of the Revenue are dismissed

Bench: SHRI. AAKASH DEEP JAIN (Vice President), SHRI. SHRI. KRINWANT SAHAY (Accountant Member)

income of Rs. 65,47,626/-. Its breakup is rebate and discount of Rs. 55,97,132/-, recovery from contractor of Rs. 7,24,136/- and other miscellaneous receipts of Rs. 2,26,358/-. 16.5 Regarding the rebate and discount, this comprises of Turnover discount received from suppliers. It is undisputedly relates to material purchases, which is, obviously the business

M/S VARDHMAN TEXTILES LIMITED,LUDHIANA vs. ACIT, C-1, LUDHIANA

In the result, appeals of the Assessee are partly allowed whereas the Cross appeals of the Revenue are dismissed

Bench: SHRI. AAKASH DEEP JAIN (Vice President), SHRI. SHRI. KRINWANT SAHAY (Accountant Member)

income of Rs. 65,47,626/-. Its breakup is rebate and discount of Rs. 55,97,132/-, recovery from contractor of Rs. 7,24,136/- and other miscellaneous receipts of Rs. 2,26,358/-. 16.5 Regarding the rebate and discount, this comprises of Turnover discount received from suppliers. It is undisputedly relates to material purchases, which is, obviously the business

M/S VARDHMAN TEXTILES LIMITED,LUDHIANA vs. DCIT, C-1, LUDHIANA

In the result, appeals of the Assessee are partly allowed whereas the Cross appeals of the Revenue are dismissed

Bench: SHRI. AAKASH DEEP JAIN (Vice President), SHRI. SHRI. KRINWANT SAHAY (Accountant Member)

income of Rs. 65,47,626/-. Its breakup is rebate and discount of Rs. 55,97,132/-, recovery from contractor of Rs. 7,24,136/- and other miscellaneous receipts of Rs. 2,26,358/-. 16.5 Regarding the rebate and discount, this comprises of Turnover discount received from suppliers. It is undisputedly relates to material purchases, which is, obviously the business

M/S ADARSH CONSTRUCTIONS AND ENGINEERS,SANGRUR vs. PR.CIT, PATIALA

In the result, all the appeals of the respective assessees stands allowed

business." As such whole gross receipts of Rs.33,00,133/- are required to be treated as commission income and the difference of Rs.30,36,122/- (33,00,133 - 2,64,011) has been taken into account as income by the AO while framing the assessment. From the aforesaid facts and circumstances of the case, it is noticed that

M/S CHENAB CONSTRUCTION,SANGRUR vs. PCIT, PATIALA

In the result, all the appeals of the respective assessees stands allowed

business." As such whole gross receipts of Rs.33,00,133/- are required to be treated as commission income and the difference of Rs.30,36,122/- (33,00,133 - 2,64,011) has been taken into account as income by the AO while framing the assessment. From the aforesaid facts and circumstances of the case, it is noticed that

M/S AMBEY ENGINEERS AND CONTRACTORS,NEW DELHI vs. PR.CIT, PATIALA

In the result, all the appeals of the respective assessees stands allowed

business." As such whole gross receipts of Rs.33,00,133/- are required to be treated as commission income and the difference of Rs.30,36,122/- (33,00,133 - 2,64,011) has been taken into account as income by the AO while framing the assessment. From the aforesaid facts and circumstances of the case, it is noticed that

M/S ANAND ENGINEERS & CONTRACTORS,SANGURUR vs. PR.CIT, PATIALA

In the result, all the appeals of the respective assessees stands allowed

business." As such whole gross receipts of Rs.33,00,133/- are required to be treated as commission income and the difference of Rs.30,36,122/- (33,00,133 - 2,64,011) has been taken into account as income by the AO while framing the assessment. From the aforesaid facts and circumstances of the case, it is noticed that

M/S HIMALYAN CONSTRUCTION AND ENGINEERS,SANGRUR vs. PCIT, PATIALA

In the result, all the appeals of the respective assessees stands allowed

business." As such whole gross receipts of Rs.33,00,133/- are required to be treated as commission income and the difference of Rs.30,36,122/- (33,00,133 - 2,64,011) has been taken into account as income by the AO while framing the assessment. From the aforesaid facts and circumstances of the case, it is noticed that

M/S HIND CONSTRUCTION ENGINEERS CONTRCTORS,SANGRUR vs. PR.CIT, PATIALA

In the result, all the appeals of the respective assessees stands allowed

business." As such whole gross receipts of Rs.33,00,133/- are required to be treated as commission income and the difference of Rs.30,36,122/- (33,00,133 - 2,64,011) has been taken into account as income by the AO while framing the assessment. From the aforesaid facts and circumstances of the case, it is noticed that

M/S GANGA CONSTRUCTIONS,SANGURUR vs. PCIT, PATIALA

In the result, all the appeals of the respective assessees stands allowed

business." As such whole gross receipts of Rs.33,00,133/- are required to be treated as commission income and the difference of Rs.30,36,122/- (33,00,133 - 2,64,011) has been taken into account as income by the AO while framing the assessment. From the aforesaid facts and circumstances of the case, it is noticed that

M/S AMAR CONTRUCTION AND ENGINEER ,SANGRUR vs. PCTI, PATIALA

In the result, all the appeals of the respective assessees stands allowed

business." As such whole gross receipts of Rs.33,00,133/- are required to be treated as commission income and the difference of Rs.30,36,122/- (33,00,133 - 2,64,011) has been taken into account as income by the AO while framing the assessment. From the aforesaid facts and circumstances of the case, it is noticed that

PAREXEL INTERNATIONAL SERVICES INDIA PVT.LTD,,CHANDIGARH vs. ACIT,CIRCLE-5(1),(NEAC), CHANDIGARH

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

Bench: SHRI. AAKASH DEEP JAIN (Vice President), SHRI. SHRI. KRINWANT SAHAY (Accountant Member)

Transfer Pricing adjustment order, which is under challenge before us. 3 5. Vide order dt. 31/03/2021, assessment was finalised by the National e- Assessment Centre, Delhi, pursuant to directions of the Dispute Resolution Panel, under section 143(3) r.w.s. 144C(13) read with sections 143(3A) and 143(3B) of the Income Tax Act. Aggrieved therewith, the assessee

KAPIL GUPTA,SIRMAUR vs. ACIT CENTRAL CIRCLE SHIMLA, SHIMLA

The appeals stand partly allowed in terms of our above order

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं. / Ita No.1010/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2020-21) & 2. आयकर अपील सं. / Ita No.1011/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2021-22) 3. आयकर अपील सं. / Ita No.1012/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2022-23) & 4. आयकर अपील सं. / Ita No.1013/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2023-24) Shri Kapil Gupta Acit (Central) C/O M/S Himgiri Beverages बनाम/ Vs. Shimla (Hp) -171001 Kala Amb – 173030 (Hp) "थायीलेखासं./जीआइआरसं./Pan/Gir No. Addpg-0399-Q (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Sh. Ajay Jain (Ca) A/W Sh. Lovesh Bansal (Ca) – Ld. Ars ""थ"कीओरसे/Respondent By : Smt. Kusum Bansal (Cit) & Shri Rajat Kumar Kureel (Cit) – Ld. Drs Date Of Final Hearing : 27-01-2026 Date Of Pronouncement : 29-01-2026 आदेश / O R D E R Manoj Kumar Aggarwal () 1. Aforesaid Appeals By Assessee For Assessment Years (Ay) 2020-21 To 2023-24 Arises Out Of Separate Orders Of Learned First

transfer such unaccounted liquor are destroyed after delivery to the buyers. d) Perusal of the above statements of employees of M/s Himgiri Beverages corroborated the fact that the three Diaries belonging to calendar year 2020 (Annexure A-1), calendar year 2021 (Annexure A-2) & calendar year 2022 (Annexure A-3) which were found and seized from the residential premise

KAPIL GUPTA,SIRMAUR vs. ACIT CENTRAL CIRCLE SHIMLA, SHIMLA

The appeals stand partly allowed in terms of our above order

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं. / Ita No.1010/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2020-21) & 2. आयकर अपील सं. / Ita No.1011/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2021-22) 3. आयकर अपील सं. / Ita No.1012/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2022-23) & 4. आयकर अपील सं. / Ita No.1013/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2023-24) Shri Kapil Gupta Acit (Central) C/O M/S Himgiri Beverages बनाम/ Vs. Shimla (Hp) -171001 Kala Amb – 173030 (Hp) "थायीलेखासं./जीआइआरसं./Pan/Gir No. Addpg-0399-Q (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Sh. Ajay Jain (Ca) A/W Sh. Lovesh Bansal (Ca) – Ld. Ars ""थ"कीओरसे/Respondent By : Smt. Kusum Bansal (Cit) & Shri Rajat Kumar Kureel (Cit) – Ld. Drs Date Of Final Hearing : 27-01-2026 Date Of Pronouncement : 29-01-2026 आदेश / O R D E R Manoj Kumar Aggarwal () 1. Aforesaid Appeals By Assessee For Assessment Years (Ay) 2020-21 To 2023-24 Arises Out Of Separate Orders Of Learned First

transfer such unaccounted liquor are destroyed after delivery to the buyers. d) Perusal of the above statements of employees of M/s Himgiri Beverages corroborated the fact that the three Diaries belonging to calendar year 2020 (Annexure A-1), calendar year 2021 (Annexure A-2) & calendar year 2022 (Annexure A-3) which were found and seized from the residential premise

KAPIL GUPTA,SIRMAUR vs. ACIT CENTRAL CIRCLE SHIMLA, SHIMLA

The appeals stand partly allowed in terms of our above order

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं. / Ita No.1010/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2020-21) & 2. आयकर अपील सं. / Ita No.1011/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2021-22) 3. आयकर अपील सं. / Ita No.1012/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2022-23) & 4. आयकर अपील सं. / Ita No.1013/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2023-24) Shri Kapil Gupta Acit (Central) C/O M/S Himgiri Beverages बनाम/ Vs. Shimla (Hp) -171001 Kala Amb – 173030 (Hp) "थायीलेखासं./जीआइआरसं./Pan/Gir No. Addpg-0399-Q (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Sh. Ajay Jain (Ca) A/W Sh. Lovesh Bansal (Ca) – Ld. Ars ""थ"कीओरसे/Respondent By : Smt. Kusum Bansal (Cit) & Shri Rajat Kumar Kureel (Cit) – Ld. Drs Date Of Final Hearing : 27-01-2026 Date Of Pronouncement : 29-01-2026 आदेश / O R D E R Manoj Kumar Aggarwal () 1. Aforesaid Appeals By Assessee For Assessment Years (Ay) 2020-21 To 2023-24 Arises Out Of Separate Orders Of Learned First

transfer such unaccounted liquor are destroyed after delivery to the buyers. d) Perusal of the above statements of employees of M/s Himgiri Beverages corroborated the fact that the three Diaries belonging to calendar year 2020 (Annexure A-1), calendar year 2021 (Annexure A-2) & calendar year 2022 (Annexure A-3) which were found and seized from the residential premise