DCIT,CIRCLE-1(EXEMPTION), CHANDIGARH vs. M/S MANAV MANGAL SCHOOL( MANAV MANGAL SOCIETY), CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

transferred to the members or to these people or concerns and they had procured bogus commission income. No such document has been brought to my notice by the AO or Survey Report that establishes trail of transfer of cash clandestinely to the members of the society. Hence, if there is bogus commission raised by the members of the society, Ld.AO

M/S MANAV MANGAL SOCIETY,CHANDIGARH vs. DCIT, C-1, (E), CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

transferred to the members or to these people or concerns and they had procured bogus commission income. No such document has been brought to my notice by the AO or Survey Report that establishes trail of transfer of cash clandestinely to the members of the society. Hence, if there is bogus commission raised by the members of the society, Ld.AO

DCIT, C-1, (E), CHANDIGARH vs. M/S MANAV MANGAL SOCIETY, CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

transferred to the members or to these people or concerns and they had procured bogus commission income. No such document has been brought to my notice by the AO or Survey Report that establishes trail of transfer of cash clandestinely to the members of the society. Hence, if there is bogus commission raised by the members of the society, Ld.AO

DCIT, C-1, (E), CHANDIGARH vs. M/S MANAV MANGAL SOCIETY, CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

transferred to the members or to these people or concerns and they had procured bogus commission income. No such document has been brought to my notice by the AO or Survey Report that establishes trail of transfer of cash clandestinely to the members of the society. Hence, if there is bogus commission raised by the members of the society, Ld.AO

M/S MANAV MANGAL SOCIETY,CHANDIGARH vs. DCIT, C-1, (E), CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

transferred to the members or to these people or concerns and they had procured bogus commission income. No such document has been brought to my notice by the AO or Survey Report that establishes trail of transfer of cash clandestinely to the members of the society. Hence, if there is bogus commission raised by the members of the society, Ld.AO

DCIT, C-1, (E), CHANDIGARH vs. M/S MANAV MANGAL SOCIETY, CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

transferred to the members or to these people or concerns and they had procured bogus commission income. No such document has been brought to my notice by the AO or Survey Report that establishes trail of transfer of cash clandestinely to the members of the society. Hence, if there is bogus commission raised by the members of the society, Ld.AO

A.B. SUGARS LIMITED,PUNJAB vs. PRINCIPAL COMMISSIONER OF INCOME TAX -1, CHANDIGARH, CHANDIGARH

In the result, the appeal of the assessee is allowed

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

Transfer Pricing Officer has already examined the records and accepted the returned income. The copy of the order passed by TPO is attached as per Annexure-D and Reply submitted before TPO and A.O. along with annexures is enclosed as per Annexure-E for your honors kind perusal. "In the annexed reply submitted to TPO dated 17.11.2020- Annexure

A.B. SUGARS LIMITED,PUNJAB vs. PRINCIPAL COMMISSIONER OF INCOME TAX-1, CHANDIGARH

In the result, the appeal of the assessee is allowed

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

Transfer Pricing Officer has already examined the records and accepted the returned income. The copy of the order passed by TPO is attached as per Annexure-D and Reply submitted before TPO and A.O. along with annexures is enclosed as per Annexure-E for your honors kind perusal. "In the annexed reply submitted to TPO dated 17.11.2020- Annexure

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

Section 54 of Transfer Property Act, it is clear that when the price is partly paid and partly promised, the immovable property is deemed to have been transferred on execution and registration of Sale Deed if the possession of property has been given to the buyer. The assessee’s claim that the possession of the property remained with the seller

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

Section 54 of Transfer Property Act, it is clear that when the price is partly paid and partly promised, the immovable property is deemed to have been transferred on execution and registration of Sale Deed if the possession of property has been given to the buyer. The assessee’s claim that the possession of the property remained with the seller

M/S JSK INTERNATIONAL,BADDI vs. PR. CIT, SHIMLA

The appeal of the Assessee is Allowed

13. Reference to Transfer Pricing Officer (TPO) 3.1 The power to determine the Arm’s Length Price (ALP) in an international transaction is contained in sub-section

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

In the result, appeal of the assessee is allowed

section 92C of the Act to the TPO for determining the arms length price in respect of specific domestic transaction undertaken by the assessee. The TPO after examining the transfer pricing adjustment and analyzing the specific domestic transaction with associated enterprises, proceeded to bench mark the power from eligible unit to non eligible unit specifically supply of electricity and steam

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 uses two independent limbs – one for transfer-pricing cases and one for any non-resident assessee. It was emphasized that the AO having proposed variations prejudicial to the assessee, draft assessment order u/s 144C(1) became mandatory. 13

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)

Sections 144C(13), 143(3A) and 143(3B) of the Act to the extent prejudicial to the Appellant, is bad in law and is liable to be quashed. 2. On the facts and in the circumstances of the case and in law, the Ld. Panel erred in upholding the action of the Ld. Transfer Pricing

DCIT, C-1 (EXEMPTIONS), CHANDIGARH vs. CT EDUCATIONAL SOCIETY, JALANDHAR

In the result, both the appeals of the Revenue are

transfer for property and as per scheme that doesn't reflect altruism on part of the members selling land to their own society. ITA 1135/CHD/2017 & ITA 700/CHD/2019 A.Y. 2014-15 & 2015-16 Page 3 of 12 7. That the Id. CIT(A)-2 Jalandhar has erred in law in deleting interest amount even when the advances paid were made

DCIT, C-1 (EXEMPTIONS), CHANDIGARH vs. CT EDUCATIONAL SOCIETY, JALANDHAR

In the result, both the appeals of the Revenue are

transfer for property and as per scheme that doesn't reflect altruism on part of the members selling land to their own society. ITA 1135/CHD/2017 & ITA 700/CHD/2019 A.Y. 2014-15 & 2015-16 Page 3 of 12 7. That the Id. CIT(A)-2 Jalandhar has erred in law in deleting interest amount even when the advances paid were made

M/S HIMALYAN CONSTRUCTION AND ENGINEERS,SANGRUR vs. PCIT, PATIALA

In the result, all the appeals of the respective assessees stands allowed

13. Since the issues involved in all the appeals were similar, they were heard together and are being disposed off by this consolidated order. 2.0 With the consent of both the parties, the case of the assessee, M/s Ambey Engineers and Contractors in ITA No. 473/Chd/2022 was taken as the lead case for the purposes of present discussions

M/S ANAND ENGINEERS & CONTRACTORS,SANGURUR vs. PR.CIT, PATIALA

In the result, all the appeals of the respective assessees stands allowed

13. Since the issues involved in all the appeals were similar, they were heard together and are being disposed off by this consolidated order. 2.0 With the consent of both the parties, the case of the assessee, M/s Ambey Engineers and Contractors in ITA No. 473/Chd/2022 was taken as the lead case for the purposes of present discussions