SAHIBZADA TIMBER AND PLY PRIVATE LIMITED ,MOHALI vs. DCIT, ACIT CENTRAL CIRCLE-2, CHANDIGARH, CHANDIGARH

In the result, the appeal of the assessee is dismissed

Bench: SHRI. VIKRAM SINGH YADAV, AM आयकर अपील सं./ ITA No. 699/Chd/2024 निर्धारण वर्ष / Assessment Year : 2019-20 M/s Sahibzada Timber & Ply Private Limited B41-42, Phase-3, Indl. Aera, SAS Nagar Mohali, Punjab बनाम The DCIT Central Circle-2 Chandigarh स्थायी लेखा सं./PAN NO: AAQCS2239G अपीलार्थी/Appellant प्रत्यर्थी/Respondent निर्धारिती की ओर से/Assessee by : Shri Mohit Dhiman, C.A राजस्व की ओर से/ Revenue by : Dr. Ranjeet Kaur, Sr. DR Shri Dharam Vir, Addl. CIT, Sr.DR सुनवाई की तारीख/Date of He

price ought to be taken as mentioned in the sale deed or the value of the property arrived at by the AO by reference to the DVO and as to whether the AO rightly made a reference to the DVO and the relevant discussions and findings of the Hon’ble High Court read as under: 12. The first

M/S PUNJAB CHEMICALS & CROP. PROTECTION LTD.,CHANDIGARH vs. ADDL. CIT, NEAC DELHI

The appeal stand partly allowed

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकरअपीलसं./ Ita No.127/Chandi/2021 (िनधा"रणवष" / Assessment Year: 2008-09) & 2. आयकरअपीलसं./ Ita No.128/Chandi/2021 (िनधा"रणवष" / Assessment Year: 2009-10) M/S Punjab Chemicals & Crop. Addl. Cit Protection Ltd. Nfac बनाम/ Milestone-18, Ambala-Kalka Road Delhi Vs. Vpo Bhankharpur, Derabassi Distt. Sas Nagar (Mohali), Punjab 140201 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaacp-9904-H (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri Anil Khanna (Ca) – Ld. Ar ""थ"कीओरसे/Respondent By : Ms. Kusum Bansal (Cit) – Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 17-03-2025 घोषणाकीतारीख /Date Of Pronouncement : 22-05-2025 आदेश / O R D E R Manoj Kumar Aggarwal () 1.1 Aforesaid Appeals By Assessee For Assessment Years (Ay) 2008-09 & 2009-10 Is In Second Round Of Litigation Since The Appeal Was Disposed-Off By Tribunal Vide Ita Nos.60/Chd/2013 & Ita No.100/Chd/2013 Common Order Dated 23-07-2018 For Ays 2008-09 & 2009-10 Wherein Few Of The Issues Were Restored Back To Lower

Transfer Pricing Adjustment on Corporate Guarantee charges. Having heard rival submissions and upon perusal of case records, these grounds are adjudicated as under. 2. Disallowance of Commission Paid to working directors 2.1 The Tribunal restored this issue back to Ld. AO to verify that the expenditure was an ascertained liability. The Ld. AO rendered a finding that the actual amount

M/S PUNJAB CHEMICALS & CROP. PROTECTION LTD.,CHANDIGARH vs. ADDL. CIT, NEAC DELHI

The appeal stand partly allowed

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकरअपीलसं./ Ita No.127/Chandi/2021 (िनधा"रणवष" / Assessment Year: 2008-09) & 2. आयकरअपीलसं./ Ita No.128/Chandi/2021 (िनधा"रणवष" / Assessment Year: 2009-10) M/S Punjab Chemicals & Crop. Addl. Cit Protection Ltd. Nfac बनाम/ Milestone-18, Ambala-Kalka Road Delhi Vs. Vpo Bhankharpur, Derabassi Distt. Sas Nagar (Mohali), Punjab 140201 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaacp-9904-H (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri Anil Khanna (Ca) – Ld. Ar ""थ"कीओरसे/Respondent By : Ms. Kusum Bansal (Cit) – Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 17-03-2025 घोषणाकीतारीख /Date Of Pronouncement : 22-05-2025 आदेश / O R D E R Manoj Kumar Aggarwal () 1.1 Aforesaid Appeals By Assessee For Assessment Years (Ay) 2008-09 & 2009-10 Is In Second Round Of Litigation Since The Appeal Was Disposed-Off By Tribunal Vide Ita Nos.60/Chd/2013 & Ita No.100/Chd/2013 Common Order Dated 23-07-2018 For Ays 2008-09 & 2009-10 Wherein Few Of The Issues Were Restored Back To Lower

Transfer Pricing Adjustment on Corporate Guarantee charges. Having heard rival submissions and upon perusal of case records, these grounds are adjudicated as under. 2. Disallowance of Commission Paid to working directors 2.1 The Tribunal restored this issue back to Ld. AO to verify that the expenditure was an ascertained liability. The Ld. AO rendered a finding that the actual amount

PUNJAB CHEMICALS & CROP PROTECTION LTD.,MOHALI vs. THE ADDITIONAL COMMISSIONER OF INCOME TAX, RANGE 1, CHANDIGARH

The appeal stands partly allowed

Bench: Hon’Ble Shri Laliet Kumar, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपीलसं./ Ita No. 316/Chandi/2022 (िनधा"रणवष" / Assessment Year: 2017-18) Punjab Chemicals & Crop Protection Ltd. Addl. Cit बनाम/ Milestone-18, Ambala-Kalka Road, Range-1 Vpo Bhankharpur, Derabassi Chandigarh Vs. District Sas Nagar Mohali-140201 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaacp-9904-H (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Sh. Anil Khanna (Ca). – Ld. Ar ""थ"कीओरसे/Respondent By : Ms. Tarundeep Kaur (Cit) – Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 24-06-2025 घोषणाकीतारीख /Date Of Pronouncement : 01-07-2025 आदेश / O R D E R

Transfer Pricing (TP) adjustment on Corporate Guarantee; (iv) Set-off of brought forward losses. These grounds are adjudicated as under. 2. Disallowance of interest u/s 36(1)(iii) In view of the fact that the assessee paid interest on unsecured loans and the assessee had Capital Work-in-progress (CWIP), Ld. AO proceeded to compute interest disallowance

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)

depreciation on the same. 17.1 We find that the matter stands covered in favour of the assessee by the decision of Tribunal for A.Y. 2008-09, 2009-10 and 2011-12 and 2014-15. 17.2 Though the Department states that this issue is before the Hon’ble High Court for these years against Tribunal order, finding that there

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)

depreciation on the same. 17.1 We find that the matter stands covered in favour of the assessee by the decision of Tribunal for A.Y. 2008-09, 2009-10 and 2011-12 and 2014-15. 17.2 Though the Department states that this issue is before the Hon’ble High Court for these years against Tribunal order, finding that there

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)

depreciation on the same. 17.1 We find that the matter stands covered in favour of the assessee by the decision of Tribunal for A.Y. 2008-09, 2009-10 and 2011-12 and 2014-15. 17.2 Though the Department states that this issue is before the Hon’ble High Court for these years against Tribunal order, finding that there

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)

depreciation on the same. 17.1 We find that the matter stands covered in favour of the assessee by the decision of Tribunal for A.Y. 2008-09, 2009-10 and 2011-12 and 2014-15. 17.2 Though the Department states that this issue is before the Hon’ble High Court for these years against Tribunal order, finding that there

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)

depreciation on the same. 17.1 We find that the matter stands covered in favour of the assessee by the decision of Tribunal for A.Y. 2008-09, 2009-10 and 2011-12 and 2014-15. 17.2 Though the Department states that this issue is before the Hon’ble High Court for these years against Tribunal order, finding that there

DY.CIT, CIRCLE-1(1), CHANDIGARH vs. M/S GLAXOSMITHKLINE CONSUMER PVT. LTD., NABHA

In the result, Revenue’s appeal is dismissed

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 121/Chd/2023 "नधा"रण वष" / Assessment Year : 2016-17 Dcit, M/S Glaxosmithkline Circle 1(1), बनाम Consumer Pvt. Ltd., Chandigarh Patiala Road, Vs. Nabha. Punjab "थायी लेखा सं./Pan No. Aafcg8415R अपीलाथ"/Appellant ""यथ"/Respondent ( Hybrid Mode ) "नधा"रती क" ओर से/Assessee By : Sh. Ajay Vohra, Sr. Advocate With Sh. Neeraj Jain, Advocate & Ms. Somya Jain, Ca (Virtual) राज"व क" ओर से/ Revenue By : Shri Manav Bansal, Cit Dr सुनवाई क" तार"ख/Date Of Hearing : 06.08.2025 उदघोषणा क" तार"ख/Date Of Pronouncement : 16.10.2025 आदेश/Order Per Krinwant Sahay, Am:

Transferring Assets & Liabilities), while the liabilities taken over are in Part B of that Schedule. The assets taken over are contracts as per Schedule 4 (60 contracts), Plant & Equipment as per Schedule 5, real estate as per Schedule 6, employees and accounts receivable. The liabilities taken over are the accounts payable. It is therefore amply clear that this agreement

M/S SEL MANUFACTURING CO. LTD.,LUDHIANA vs. DCIT, CC-3, LUDHIANA

In the result, appeal is allowed

Bench: SHRI A.D.JAIN (Vice President), SHRI KRINWANT SAHAY (Accountant Member)

transfer pricing, TDS matter, excise assessment, VAT assessment and also with regard to notices issued by the relevant Government Authority for relevant assessment years under various provisions of the Applicable Law including Income Tax Act or indirect tax laws, the relevant Government A.Y. 2011-12 14 Authorities make any further assessment with respect to resolution of losses or unabsorbed depreciation

M/S SANJAY SINGAL HUF,CHANDIGARH vs. DCIT, CC-1, CHANDIGARH

Bench: SHRI A.D.JAIN (Vice President), SHRI KRINWANT SAHAY (Accountant Member)

transferred by the entry operators to such accommodation entry providers through the angadias (cash carriers). Accordingly, the operators then routed the unaccounted cash through the bank accounts of various paper companies and floated dummy / bogus buyers for buying the scrips at the artificially jacked-up share price of such listed securities from the beneficiaries. At that time, the beneficiary

SANJAY SINGAL,CHANDIGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CC-1, CHANDIGARH

Bench: SHRI A.D.JAIN (Vice President), SHRI KRINWANT SAHAY (Accountant Member)

transferred by the entry operators to such accommodation entry providers through the angadias (cash carriers). Accordingly, the operators then routed the unaccounted cash through the bank accounts of various paper companies and floated dummy / bogus buyers for buying the scrips at the artificially jacked-up share price of such listed securities from the beneficiaries. At that time, the beneficiary

CT EDUCATIONAL SOCIETY,JALANDHAR vs. DCIT, CHANDIGARH

In the result, the appeal filed by the Assessee is Partly Allowed for\nStatistical Purposes as per the directions above

price and no\ninterest bearing loan was used for the purpose, the addition on such account is\nnot justified. Thus, for the shake of principle of natural justice the AO should also\nget an opportunity to examine the contention of the appellant and therefore, I\ndirect the AO to verify the claim of the appellant on this issue

SMT. SHANKRI DEVI,PANCHKULA vs. ACIT, PANCKULA CIRCLE, PANCHKULA

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

transfer of agricultural land, where— (i) such land is situate in any area referred to in item (a) or item (b) of sub- clause (iii) of clause (14) of section 2; (ii) such land, during the period of two years immediately preceding the date of transfer, was being used for agricultural purposes by such Hindu undivided family or individual

SAROJ CHAUDHARY BALA,PANCHKULA vs. ITO, WARD-4, PANCHKULA

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

transfer of agricultural land, where— (i) such land is situate in any area referred to in item (a) or item (b) of sub- clause (iii) of clause (14) of section 2; (ii) such land, during the period of two years immediately preceding the date of transfer, was being used for agricultural purposes by such Hindu undivided family or individual

INCOME TAX OFFICER, FATEHABAD vs. MAHESH NAGPAL, FATEHABAD

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

transfer of agricultural land, where— (i) such land is situate in any area referred to in item (a) or item (b) of sub- clause (iii) of clause (14) of section 2; (ii) such land, during the period of two years immediately preceding the date of transfer, was being used for agricultural purposes by such Hindu undivided family or individual

SH. AMARDEEP SINGH ATHWAL,YAMUNANAGAR vs. ITO, WARD-1, YAMUNANAGAR

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

transfer of agricultural land, where— (i) such land is situate in any area referred to in item (a) or item (b) of sub- clause (iii) of clause (14) of section 2; (ii) such land, during the period of two years immediately preceding the date of transfer, was being used for agricultural purposes by such Hindu undivided family or individual