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.”

section 143(2) and 142(1) were issued. Further during the course of assessment proceeding, the AO referred the matter to the Transfer Pricing Officer (TPO) to determine the Arms Length Price in respect of certain specified domestic transactions entered into by the assessee with its associate enterprises. 3.1 During the course of Transfer Pricing proceedings, there was no compliance

DAMANDEEP KAUR,MOHALI vs. ASSISTANT COMMISSIONER OF INCOME TAX (CENTRAL CIRCLE-2), CHANDIGARH, CHANDIGARH

In the result, all appeals of the assessee are allowed

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

Section 144C was intended for transfer-pricing matters; that BMA proceedings are independent and cannot bind AO; that participation cured the defect; and in any case the defect, if any, is cured u/s 292B. 15. We have heard the rival contention of the parties and perused the material available on the record. It is an admitted factual position that

PAWAN KUMAR,FATEHABAD vs. INCOME TAX OFFICER WARD-1, FATEHABAD

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

10 deals with deductions and sub-section (37) thereof deals with capital gains arising from transfer of agricultural land, it no where provides as to what is to be included under the head "Capital gains". The argument raised is not well founded. 11. Learned counsel has relied on Circular No. 5 of 2010 by merely reading clause 46.1. The said

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

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

10 deals with deductions and sub-section (37) thereof deals with capital gains arising from transfer of agricultural land, it no where provides as to what is to be included under the head "Capital gains". The argument raised is not well founded. 11. Learned counsel has relied on Circular No. 5 of 2010 by merely reading clause 46.1. The said

RANJIT SINGH,PANCHKULA vs. DEPUTY DIRECTOR, CPC DEPARTMENT

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

10 deals with deductions and sub-section (37) thereof deals with capital gains arising from transfer of agricultural land, it no where provides as to what is to be included under the head "Capital gains". The argument raised is not well founded. 11. Learned counsel has relied on Circular No. 5 of 2010 by merely reading clause 46.1. The said

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

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

10 deals with deductions and sub-section (37) thereof deals with capital gains arising from transfer of agricultural land, it no where provides as to what is to be included under the head "Capital gains". The argument raised is not well founded. 11. Learned counsel has relied on Circular No. 5 of 2010 by merely reading clause 46.1. The said

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

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

10 deals with deductions and sub-section (37) thereof deals with capital gains arising from transfer of agricultural land, it no where provides as to what is to be included under the head "Capital gains". The argument raised is not well founded. 11. Learned counsel has relied on Circular No. 5 of 2010 by merely reading clause 46.1. The said

INCOME TAX OFFICER, FATEHABAD vs. MAHESH NAGPAL, FATEHABAD

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

10 deals with deductions and sub-section (37) thereof deals with capital gains arising from transfer of agricultural land, it no where provides as to what is to be included under the head "Capital gains". The argument raised is not well founded. 11. Learned counsel has relied on Circular No. 5 of 2010 by merely reading clause 46.1. The said

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

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

10 deals with deductions and sub-section (37) thereof deals with capital gains arising from transfer of agricultural land, it no where provides as to what is to be included under the head "Capital gains". The argument raised is not well founded. 11. Learned counsel has relied on Circular No. 5 of 2010 by merely reading clause 46.1. The said

BALBIR KUMAR HUF,CHANDIGARH vs. ITO , CHANDIGARH

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

10 deals with deductions and sub-section (37) thereof deals with capital gains arising from transfer of agricultural land, it no where provides as to what is to be included under the head "Capital gains". The argument raised is not well founded. 11. Learned counsel has relied on Circular No. 5 of 2010 by merely reading clause 46.1. The said

ARJESH KUMAR,PATIALA vs. ITO NATIONAL E-ASSESSMENT CENTRE , DELHI

10 deals with deductions and sub-section (37) thereof deals with capital gains arising from transfer of agricultural land, it no where provides as to what is to be included under the head "Capital gains". The argument raised is not well founded. 11. Learned counsel has relied on Circular No. 5 of 2010 by merely reading clause 46.1. The said

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 shown in the documents. The question before the Court was whether the Assessing Officer was justified in making the reference to the DVO under section 55A for ascertaining the market value of the capital assets which were transferred. The Division Bench referred to the judgments which we already noted and held:- "10

DAMANDEEP KAUR,MOHALI vs. ASSISTANT COMMISSIONER OF INCOME TAX (CENTRAL CIRCLE-2), CHANDIGARH, CHANDIGARH

In the result, all appeals of the assessee are allowed

transfer-pricing matters; that BMA proceedings are independent\nand cannot bind AO; that participation cured the defect; and in any case the\ndefect, if any, is cured u/s 292B.\n15.\nWe have heard the rival contention of the parties and perused the\nmaterial available on the record. It is an admitted factual position that the\nassessee was a Non-Resident

DAMANDEEP KAUR,MOHALI vs. ASSISTANT COMMISSIONER OF INCOME TAX (CENTRAL CIRCLE-2), CHANDIGARH, CHANDIGARH

In the result, all appeals of the assessee are allowed

transfer-pricing matters; that BMA proceedings are independent\nand cannot bind AO; that participation cured the defect; and in any case the\ndefect, if any, is cured u/s 292B.\n15. We have heard the rival contention of the parties and perused the\nmaterial available on the record. It is an admitted factual position that the\nassessee was a Non-Resident

DAMANDEEP KAUR,MOHALI vs. ASSISTANT COMMISSIONER OF INCOME TAX (CENTRAL CIRCLE-2), CHANDIGARH, CHANDIGARH

In the result, all appeals of the assessee are allowed

transfer-pricing matters; that BMA proceedings are independent\nand cannot bind AO; that participation cured the defect; and in any case the\ndefect, if any, is cured u/s 292B.\n\n15.\nWe have heard the rival contention of the parties and perused the\nmaterial available on the record. It is an admitted factual position that the\nassessee

KAKA SINGH ALIAS GULJAR SINGH,PATIALA vs. INCOME TAX OFFICER , PATIALA

10 deals with\ndeductions and sub-section (37) thereof deals with capital gains arising from transfer\nof agricultural land, it no where provides as to what is to be included under the head\n\"Capital gains\". The argument raised is not well founded.\n11. Learned counsel has relied on Circular No. 5 of 2010 by merely reading clause

M/S YAMUNA POWER & INFRASTRUCTURE LTD.,JAGADHRI vs. DCIT, CIRCLE, YAMUNANAGAR

In the result, the appeal of the assessee is allowed

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

section 273B of the Act and no adverse view need to be taken penalising the assessee for its conduct in absence of any malafide being alleged by the authorities for non-reporting these transactions or disputing the explanation so furnished by the assessee. In any case, the TPO has examined these specific domestic transactions during the course of transfer pricing

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)

Section 92C(1) of the Act, the most appropriate method shall be the method best suited to the facts and circumstances of each particular international transaction and which method provides the most reliable measure of an arm’s length price in relation to the international transaction. The Rule further provides that while selecting the most appropriate method, the nature