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

In the result, appeal of the assessee is allowed

transfer pricing guidelines which has to be followed while benchmarking any of the transaction. The methods prescribed under the 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

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

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

depreciation which is of no relevance since the entire claim of expenses has been allowed treating it as revenue in nature 21. The issue of allowability of market research expenses, accordingly, is decided in favour of the assessee. Issue No.6: The disallowance of post retirement medical benefit holding this expenditure as being in the nature of contingent liability, raised

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

depreciation which is of no relevance since the entire claim of expenses has been allowed treating it as revenue in nature 21. The issue of allowability of market research expenses, accordingly, is decided in favour of the assessee. Issue No.6: The disallowance of post retirement medical benefit holding this expenditure as being in the nature of contingent liability, raised

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

depreciation which is of no relevance since the entire claim of expenses has been allowed treating it as revenue in nature 21. The issue of allowability of market research expenses, accordingly, is decided in favour of the assessee. Issue No.6: The disallowance of post retirement medical benefit holding this expenditure as being in the nature of contingent liability, raised

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

depreciation which is of no relevance since the entire claim of expenses has been allowed treating it as revenue in nature 21. The issue of allowability of market research expenses, accordingly, is decided in favour of the assessee. Issue No.6: The disallowance of post retirement medical benefit holding this expenditure as being in the nature of contingent liability, raised

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

depreciation which is of no relevance since the entire claim of expenses has been allowed treating it as revenue in nature 21. The issue of allowability of market research expenses, accordingly, is decided in favour of the assessee. Issue No.6: The disallowance of post retirement medical benefit holding this expenditure as being in the nature of contingent liability, raised

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

depreciation which is of no relevance since the entire claim of expenses has been allowed treating it as revenue in nature 21. The issue of allowability of market research expenses, accordingly, is decided in favour of the assessee. Issue No.6: The disallowance of post retirement medical benefit holding this expenditure as being in the nature of contingent liability, raised

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

depreciation which is of no relevance since the entire claim of expenses has been allowed treating it as revenue in nature 21. The issue of allowability of market research expenses, accordingly, is decided in favour of the assessee. Issue No.6: The disallowance of post retirement medical benefit holding this expenditure as being in the nature of contingent liability, raised

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

depreciation which is of no relevance since the entire claim of expenses has been allowed treating it as revenue in nature 21. The issue of allowability of market research expenses, accordingly, is decided in favour of the assessee. Issue No.6: The disallowance of post retirement medical benefit holding this expenditure as being in the nature of contingent liability, raised

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

depreciation which is of no relevance since the entire claim of expenses has been allowed treating it as revenue in nature 21. The issue of allowability of market research expenses, accordingly, is decided in favour of the assessee. Issue No.6: The disallowance of post retirement medical benefit holding this expenditure as being in the nature of contingent liability, raised

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

depreciation which is of no relevance since the entire claim of expenses has been allowed treating it as revenue in nature 21. The issue of allowability of market research expenses, accordingly, is decided in favour of the assessee. Issue No.6: The disallowance of post retirement medical benefit holding this expenditure as being in the nature of contingent liability, raised

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

depreciation which is of no relevance since the entire claim of expenses has been allowed treating it as revenue in nature 21. The issue of allowability of market research expenses, accordingly, is decided in favour of the assessee. Issue No.6: The disallowance of post retirement medical benefit holding this expenditure as being in the nature of contingent liability, raised

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

depreciation which is of no relevance since the entire claim of expenses has been allowed treating it as revenue in nature 21. The issue of allowability of market research expenses, accordingly, is decided in favour of the assessee. Issue No.6: The disallowance of post retirement medical benefit holding this expenditure as being in the nature of contingent liability, raised

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

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