SARASWATI AGRO CHEMICALS (INDIA) PVT. LTD,MOHALI vs. DCIT, CIRCLE-6(1), MOHALI

In the result, the transfer pricing adjustment so made by the AO and confirmed by the ld CIT(A) amounting to Rs 89,22,420/- is hereby set-aside and the ground of appeal is allowed

Bench: Or At The Time Of Hearing.”

disallowed and added to income. In fact, issuance/investment of shares is undoubtedly on capital account and thus cannot be construed as income/expense and therefore not subject to transfer pricing

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

Disallowance u/s 14A for Rs.34.60 Lacs; (iv) Transfer Pricing (TP) adjustment on reimbursement of expenses; (v) Transfer Pricing Adjustment on Corporate

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

Disallowance u/s 14A for Rs.34.60 Lacs; (iv) Transfer Pricing (TP) adjustment on reimbursement of expenses; (v) Transfer Pricing Adjustment on Corporate

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

disallowed the said loss only on the basis that the agreement to sell was unregistered. It was contended that the sale consideration had been transferred through banking channels and then the said plot had been transferred by the builder to the purchaser with whom the agreement to sell had been executed. Further, it was submitted that the transfer/sale

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

Disallowance u/s 14A for Rs.0.23 Lacs; (iii) Transfer Pricing (TP) adjustment on Corporate Guarantee; (iv) Set-off of brought forward

DCIT, C-1(1) , CHANDIGARH vs. M/S FIDELITY INFORMATION SERVICES INDIA PVT. LTD., CHANDIGARH

In the result, the cross-objection filed by the assessee is dismissed

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

Transfer Pricing adjustment involved. 3 2008-09 2,18,67,637 New Service Foreign travelling The Hon'ble Tribunal agreement dated expenditure disallowed

JANTA LAND PROMOTERS PVT LTD,MOHALI vs. THE PRINICIPAL COMMISSIONER OF INCOME TAX ,CHANDIGARH-1, CHANDIGARH

In the result, appeal of the Assessee is allowed

transfer pricing adjustment. From perusal of the financial statements, it is evident that there is neither an international transaction nor specified domestic transactions under Section 92BA apply to the assessee. The Ld. AR had further submitted that the Ld. PCIT has not pointed out, either in the show cause notice or in the impugned order, that the assessee has entered

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)

price determined by the assessee in relation to transfer of steam by Vardhman Fabrics CPP and holding that the steam produced had NIL cost. 19.1 The TPO/AO held that steam is a by-product with NIL cost. The entire transfer value of steam, amounting to Rs. 35.37 Crores was, hence, disallowed

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)

price determined by the assessee in relation to transfer of steam by Vardhman Fabrics CPP and holding that the steam produced had NIL cost. 19.1 The TPO/AO held that steam is a by-product with NIL cost. The entire transfer value of steam, amounting to Rs. 35.37 Crores was, hence, disallowed

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)

price determined by the assessee in relation to transfer of steam by Vardhman Fabrics CPP and holding that the steam produced had NIL cost. 19.1 The TPO/AO held that steam is a by-product with NIL cost. The entire transfer value of steam, amounting to Rs. 35.37 Crores was, hence, disallowed

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)

price determined by the assessee in relation to transfer of steam by Vardhman Fabrics CPP and holding that the steam produced had NIL cost. 19.1 The TPO/AO held that steam is a by-product with NIL cost. The entire transfer value of steam, amounting to Rs. 35.37 Crores was, hence, disallowed

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)

price determined by the assessee in relation to transfer of steam by Vardhman Fabrics CPP and holding that the steam produced had NIL cost. 19.1 The TPO/AO held that steam is a by-product with NIL cost. The entire transfer value of steam, amounting to Rs. 35.37 Crores was, hence, disallowed

MAXPORT INDIA PRIVATE LIMITED,CHANDIGARH vs. DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1,CHANDIGARH, CHANDIGARH

Disallowance of 80IC on subsidy claimed in ITR.\nIssue 18 : Jewellery found at House no 2273, Sector 21C, Chandigarh & Locker no\n64, Bank of India, Sector 35, Chandigarh during the search.\n20\nIssue 19: Approval u/s 153D.\n4. Since common a nd identical issues are involved i n most of the\ncaptioned appeals, hence we deem it appropriate to adjudicate

SMT. TEENA GARG,CHANDIGARH vs. PCIT, PANCHKULA

In the result, appeal of the assessee is allowed

Pricing\nOfficer, as the case may be, shall be deemed to be erroneous in so\nfar as it is prejudicial to the interests of the revenue, if, in the opinion\nof the Principal Chief Commissioner or Chief Commissioner or\nPrincipal Commissioner or Commissioner,-\n\n(a) the order is passed without making inquiries or verification which\nshould have been made

M/S CENTRIENT PHARMACEUTICALS INDIA PRIVATE LIMITED,NAWANSHAHAR vs. ADDITINAL/JOINT/DEPUTY/ASSTT. C.IT,ITO,NEAC, DELHI

In the result, appeal of the assessee is partly allowed for statistical purposes

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

Transfer Pricing Adjustment of Rs.8,05,24,450/- in respect of corporate services fees. The TPO applied CUP as the most appropriate method and determined ALP of the transaction as Nil. The TPO has further observed that no independent party would have made a similar payment in uncontrolled circumstances. We find that this issue is perennial in nature

SH. BALJIT SINGH,LUDHIANA vs. PR. CIT, LUDHIANA -1, LUDHIANA

In the result, appeal of the Assessee is dismissed

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member), SHRI. PARESH M. JOSHI (Judicial Member)

Transfer Pricing Officer, as the case may be) is erroneous in so far as it is prejudicial to the interest of the revenue, he may, after giving the assesse an opportunity of being heard and after making or causing to be made such inquiry as he deems necessary, pass such order thereon as the circumstances of the case justify, including

M/S SHREE GANESH JEWELLERS LIMITED,LUDHIANA vs. ACIT, CIRCLE V(1), LUDHIANA

In the result, the appeal of the assessee is allowed

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member)

disallowance; (d) the amount of under-reported income represented by any addition made in conformity with the arm's length price determined by the Transfer

SCOTT EDIL ADVANCE RESEARCH LABORATORIES AND EDUCATION LIMITED,CHANDIGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, CHANDIGARH

Disallowance of 80IC on subsidy claimed in ITR.\nIssue 18 : Jewellery found at House no 2273, Sector 21C, Chandigarh & Locker no\n64, Bank of India, Sector 35, Chandigarh during the search.\n20\nIssue 19: Approval u/s 153D.\n4. Since common a nd ident ical issues are involved i n most of the\ncaptioned appeals, hence we deem it appropriate