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.”

29,540/- as Investment in equity shares, Rs. 2,32,00,000/- as Salary paid & Rs. 1,19,94,666/- as Dividend paid) with its associated enterprises during the year under consideration. Subsequently, the AO made a reference under section 92CA(1) to Transfer Pricing Officer to determine the Arm's Length Prices in respect of the above specified domestic

SH. AMAR SINGH,JAGADHARI vs. ITO, YAMUNANAGAR

In the result, both the appeal of different assessees are allowed

Bench: Shri Sanjay Garg & Dr. B.R.R. Kumar

price is paid and the deed is delivered . In the percent case, from the statement of case itself as drawn up by the Tribunal, it is apparent that the parties had clearly intended that despite the execution and registration of sale deeds, transfer by way of sale will become effective only on payment of the entire consideration amount

SH. JAI RAM,JAGADHARI vs. ITO, YAMUNANAGAR

In the result, both the appeal of different assessees are allowed

Bench: Shri Sanjay Garg & Dr. B.R.R. Kumar

price is paid and the deed is delivered . In the percent case, from the statement of case itself as drawn up by the Tribunal, it is apparent that the parties had clearly intended that despite the execution and registration of sale deeds, transfer by way of sale will become effective only on payment of the entire consideration amount

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

In the result, appeal of the assessee is allowed

29,292 2,160 63,270,720 Feb-15 42.860 12.333 30,527 2,160 65,938,320 Mar-15 42,160 13.725 28,435 2,160 61,419,600 Total 501,225 152,367 348,858 753,533,280 The company has used "Comparable Uncontrolled Price Method" to arrive at the Arm's Length Price as per details below

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)

10 However for AY2016-17 the Assessing Officer had mentioned status of assessee as resident: 16. Besides the above, the assessee was a Non-Resident within the meaning of Section 6 of the Income-tax Act, 1961 during the Assessment Years under consideration. Section 6 of the Act 1961 as on 01/04/2020 which reads as under:_ Residence in India

RANJIT SINGH,PANCHKULA vs. DEPUTY DIRECTOR, CPC DEPARTMENT

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

29. The Ld. Authorised Representative (AR) submitted that there is no specific provision in Section 2(24) of the Income-tax Act, 1961, incorporating within its ambit any “other income” referred to in Section 56(2)(viii) of the Act. It was contended that unless a particular receipt is expressly brought within the inclusive definition of “income” under Section

BALBIR KUMAR HUF,CHANDIGARH vs. ITO , CHANDIGARH

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

29. The Ld. Authorised Representative (AR) submitted that there is no specific provision in Section 2(24) of the Income-tax Act, 1961, incorporating within its ambit any “other income” referred to in Section 56(2)(viii) of the Act. It was contended that unless a particular receipt is expressly brought within the inclusive definition of “income” under Section

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

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

29. The Ld. Authorised Representative (AR) submitted that there is no specific provision in Section 2(24) of the Income-tax Act, 1961, incorporating within its ambit any “other income” referred to in Section 56(2)(viii) of the Act. It was contended that unless a particular receipt is expressly brought within the inclusive definition of “income” under Section

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

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

29. The Ld. Authorised Representative (AR) submitted that there is no specific provision in Section 2(24) of the Income-tax Act, 1961, incorporating within its ambit any “other income” referred to in Section 56(2)(viii) of the Act. It was contended that unless a particular receipt is expressly brought within the inclusive definition of “income” under Section

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

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

29. The Ld. Authorised Representative (AR) submitted that there is no specific provision in Section 2(24) of the Income-tax Act, 1961, incorporating within its ambit any “other income” referred to in Section 56(2)(viii) of the Act. It was contended that unless a particular receipt is expressly brought within the inclusive definition of “income” under Section

INCOME TAX OFFICER, FATEHABAD vs. MAHESH NAGPAL, FATEHABAD

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

29. The Ld. Authorised Representative (AR) submitted that there is no specific provision in Section 2(24) of the Income-tax Act, 1961, incorporating within its ambit any “other income” referred to in Section 56(2)(viii) of the Act. It was contended that unless a particular receipt is expressly brought within the inclusive definition of “income” under Section

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

29. The Ld. Authorised Representative (AR) submitted that there is no specific provision in Section 2(24) of the Income-tax Act, 1961, incorporating within its ambit any “other income” referred to in Section 56(2)(viii) of the Act. It was contended that unless a particular receipt is expressly brought within the inclusive definition of “income” under Section

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

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

29. The Ld. Authorised Representative (AR) submitted that there is no specific provision in Section 2(24) of the Income-tax Act, 1961, incorporating within its ambit any “other income” referred to in Section 56(2)(viii) of the Act. It was contended that unless a particular receipt is expressly brought within the inclusive definition of “income” under Section

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

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

29. The Ld. Authorised Representative (AR) submitted that there is no specific provision in Section 2(24) of the Income-tax Act, 1961, incorporating within its ambit any “other income” referred to in Section 56(2)(viii) of the Act. It was contended that unless a particular receipt is expressly brought within the inclusive definition of “income” under Section

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

10 the Appellate Tribunal has observed that under Section 12-B(2) of the Income Tax Act, the Income Tax Officer has to compute the capital gains after making certain deductions from the full value of the consideration for the sale and he therefore has a right to know the full value. The Appellate Tribunal added: "The assesses cannot shut

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)

29,52,199/- by applying this average of 33.13% on the sale value of Rs. 396/- crores. As such, the cost plus mark up of 33.13% was imputed on the sale value of the intangibles. Thus, though the DRP principally held that the CUP method was the most relevant method for bench- marking the transfer of intangible assets, it upheld

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

In the result, all appeals of the assessee are allowed

29-08-2020 | 150 | | | \n| 2020-21 | 26-02-2021 | 31.03.2021 | 33 | 183 | 182 | Resident\n| | 01.04.2021 | 14-10-2021 | 196 | | | \n| 2021-22 | 23-03-2022 | 31.03.2022 | 8 | 204 | 161 | Non-Resident\n| | 01.04.2022 | 14-07-2022 | 104 | 104 | 261 | Resident\n\nThus, the assessee's non-resident status under section 6 of the Act stands\nundisputed and accepted

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

In the result, all appeals of the assessee are allowed

29-08-2020 | 150 | 183 | 182 | Resident |\n| | 26-02-2021 | 31.03.2021 | 33 | | | |\n| 2021-22 | 01.04.2021 | 14-10-2021 | 196 | 204 | 161 | Non-Resident |\n| | 23-03-2022 | 31.03.2022 | 8 | | | |\n| 2022-23 | 01.04.2022 | 14-07-2022 | 104 | 104 | 261 | Resident |\n\nThus, the assessee's non-resident status under section 6 of the Act stands\nundisputed and accepted