CT EDUCATIONAL SOCIETY,JALANDHAR vs. DCIT, CHANDIGARH

In the result, the appeal filed by the Assessee is Partly Allowed for\nStatistical Purposes as per the directions above

price and no\ninterest bearing loan was used for the purpose, the addition on such account is\nnot justified. Thus, for the shake of principle of natural justice the AO should also\nget an opportunity to examine the contention of the appellant and therefore, I\ndirect the AO to verify the claim of the appellant on this issue

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)

Transfer Pricing Officer made a variation to the Arm's Length Price and valued the transaction at Rs. 517.82 per share. In other words, he recommended a variation in the Arm's Length Price. In these circumstances, the Petitioner would certainly be an eligible Assessee as contemplated under Section 144C(15)(b) (i) of the IT Act. Since this variation

SHRI SATISH SOIN,LUDHIANA vs. ACIT, CC-II, LUDHIANA

In the result, appeal of the assessee is allowed

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwalआयकर अपील सं./ Ita No. 303/Chd/2019 "नधा"रण वष" / Assessment Year : 2012-13 Shri Satish Soin, बनाम The Acit, House No.31, Garden Enclave, Central Circle-2, Vs South City-Ii, Ludhiana. Ludhiana. "थायी लेखा सं./Pan /Tan No: Advps6254N अपीलाथ"/Appellant ""यथ"/Respondent "नधा"रती क" ओर से/Assessee By : Shri Ashwani Kumar & Ms. Muskan Garg, Cas राज"व क" ओर से/ Revenue By : Smt. Kusum Bansal, Cit Dr तार"ख/Date Of Hearing : 26.05.2025 उदघोषणा क" तार"ख/Date Of Pronouncement : 23.07.2025 Hybrid Hearing आदेश/Order Per Rajpal Yadav, Vp

13. The contention of learned counsel for the appellant that the order dated 18.03.2014 was passed under Section 143(3) read with Section 263 of the Act is not well founded. Though in the heading Section 143(3)/ 263 of the Act are referred to from the order it is clear that it has been passed under Section 153A read

SHRI ABHISHEK SOIN,LUDHIANA vs. DCIT, CC-II, LUDHIANA

The appeals are partly allowed

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 321 & 322/Chd/2019 "नधा"रण वष" / Assessment Year: 2010-11, 2011-12 Shri Abhishek Soin, The Dcit, C/O Sigma Cartons Pvt. Ltd., Vs Central Circle-Ii, Unit-Ii, Industrial Area-C, Ludhiana. Sua Road, Ludhiana. "थायी लेखा सं./Pan No: Anbps9446A अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Aditya Kumar, Ca Revenue By : Shri Manav Bansal, Cit Dr Date Of Hearing : 03.06.2025 Date Of Pronouncement : 29.07.2025 Hybrid Hearing O R D E R

13. The contention of learned counsel for the appellant that the order dated 18.03.2014 was passed under Section 143(3) read with Section 263 of the Act is not well founded. Though in the heading Section 143(3)/ 263 of the Act are referred to from the order it is clear that it has been passed under Section 153A read

SHRI ABHISHEK SOIN,LUDHIANA vs. DCIT, CC-II, LUDHIANA

The appeals are partly allowed

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 321 & 322/Chd/2019 "नधा"रण वष" / Assessment Year: 2010-11, 2011-12 Shri Abhishek Soin, The Dcit, C/O Sigma Cartons Pvt. Ltd., Vs Central Circle-Ii, Unit-Ii, Industrial Area-C, Ludhiana. Sua Road, Ludhiana. "थायी लेखा सं./Pan No: Anbps9446A अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Aditya Kumar, Ca Revenue By : Shri Manav Bansal, Cit Dr Date Of Hearing : 03.06.2025 Date Of Pronouncement : 29.07.2025 Hybrid Hearing O R D E R

13. The contention of learned counsel for the appellant that the order dated 18.03.2014 was passed under Section 143(3) read with Section 263 of the Act is not well founded. Though in the heading Section 143(3)/ 263 of the Act are referred to from the order it is clear that it has been passed under Section 153A read

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)

Transfer Pricing adjustment order, which is under challenge before us. 3 5. Vide order dt. 31/03/2021, assessment was finalised by the National e- Assessment Centre, Delhi, pursuant to directions of the Dispute Resolution Panel, under section 143(3) r.w.s. 144C(13

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)

section 37(1) of the Act. 3. In this regard, briefly the facts of the case are that during the course of assessment proceedings, the AO observed that out of total travelling expenses debited in the P&L Account, an amount of Rs. 9,21,58,400/- has been claimed by the assesssee in respect of foreign travelling expenses. Thereafter

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)

transfer pricing charged by the assessee and in absence of reporting the same, the issue may escape the attention of the AO and given the fact that the assessee has claimed deduction under section 80IA which is under challenge by the Revenue before the Judicial Forum for the past several years, the compliance by the assessee company with

CENTRIENT PHARMACEUTICALS INDIA PRIVATE LIMITED,PUNJAB vs. DCIT/ ACIT, CIRCLE 1(1), CHANDIGARH, CHANDIGARH

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

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ I.T.A. No. 1201/Chd/2024 "नधा"रण वष" / Assessment Year: 2021-22

3) read with section 144C read with section 1448 of the Act in pursuance of directions dated 26 September 2024 issued by Ld. Dispute Resolution Panel (DRP). In facts and circumstances of the case and in law, Ld. AO/ Transfer Pricing Officer (TPO) and Ld. DRP have: 1. erred in making transfer pricing adjustment

SANJEEV KUMAR KATHURIA,YAMUNA NAGAR vs. INCOME TAX OFFICER WARD 1 , YAMUNANAGAR

In the result, the appeal of the assessee is allowed

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

3) is neither erroneous nor prejudicial to interest of revenue. 10. It was submitted that the Ld. PCIT has taken schedule of residential land for conversion lands rate of DDA for residential purposes. There are 2 elements in schedule referred by her that (i) It is conversion rate (ii) It is land rate of DDA for residential purposes. We strongly

ACIT,CIRCLE--2(1), CHANDIGARH vs. CSJ INFRASTRUCTURE PVT.LTD, CHANDIGARH

In the result, both the appeals of the assessee are allowed and that of the Revenue are dismissed

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 131,132 /Chd/2020 "नधा"रण वष" / A.Y.: 2014-15, 2015-16, M/S Csj Infrastructure Pvt.Ltd., The Acit, C/O C.A. Ajay Kumar Jain, Vs Circle 2(1), Sco 80-81, 4Th Floor, Sector 17-C, Chandigarh. Chandigarh. "थायी लेखा सं./Pan No: Aaccc8021G अपीलाथ"/Appellant ""यथ"/Respondent आयकर अपील सं./ Ita No. 146, 147/Chd/2020 "नधा"रण वष" / A.Y.: 2014-15, 2015-16, The Acit, Vs M/S Csj Infrastructure Pvt. Ltd., Circle 2(1), C/O C.A. Ajay Kumar Jain, Chandigarh. Sco 80-81, 4Th Floor, Sector 17-C, Chandigarh. "थायी लेखा सं./Pan No: Aaccc8021G अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Ajay Jain, Ca Revenue By : Shri Manav Bansal, Cit, Dr Date Of Hearing : 19.05.2025 Date Of Pronouncement : 28.05.2025 Physical Hearing O R D E R

Price + Stamp Duty & Registration Charges 3.1 The Vendee has made a payment of Rs.2,60,00,000/- vide cheque No. 023655 on 25.01.2011. There was some dispute between the assessee and the vendee and ultimately Sale Deed was executed during the Accounting Year relevant to assessment year 2014-15. The ld. AO has confronted the assessee qua Section 43CA

CSJ INFRASTRUCTURE PVT.LTD,CHANDIGARH vs. ACIT,CIRCLE--2(1), CHANDIGARH

In the result, both the appeals of the assessee are allowed and that of the Revenue are dismissed

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 131,132 /Chd/2020 "नधा"रण वष" / A.Y.: 2014-15, 2015-16, M/S Csj Infrastructure Pvt.Ltd., The Acit, C/O C.A. Ajay Kumar Jain, Vs Circle 2(1), Sco 80-81, 4Th Floor, Sector 17-C, Chandigarh. Chandigarh. "थायी लेखा सं./Pan No: Aaccc8021G अपीलाथ"/Appellant ""यथ"/Respondent आयकर अपील सं./ Ita No. 146, 147/Chd/2020 "नधा"रण वष" / A.Y.: 2014-15, 2015-16, The Acit, Vs M/S Csj Infrastructure Pvt. Ltd., Circle 2(1), C/O C.A. Ajay Kumar Jain, Chandigarh. Sco 80-81, 4Th Floor, Sector 17-C, Chandigarh. "थायी लेखा सं./Pan No: Aaccc8021G अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Ajay Jain, Ca Revenue By : Shri Manav Bansal, Cit, Dr Date Of Hearing : 19.05.2025 Date Of Pronouncement : 28.05.2025 Physical Hearing O R D E R

Price + Stamp Duty & Registration Charges 3.1 The Vendee has made a payment of Rs.2,60,00,000/- vide cheque No. 023655 on 25.01.2011. There was some dispute between the assessee and the vendee and ultimately Sale Deed was executed during the Accounting Year relevant to assessment year 2014-15. The ld. AO has confronted the assessee qua Section 43CA

ACIT,CIRCLE--2(1), CHANDIGARH vs. CSJ INFRASTRUCTURE PVT.LTD, CHANDIGARH

In the result, both the appeals of the assessee are allowed and that of the Revenue are dismissed

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 131,132 /Chd/2020 "नधा"रण वष" / A.Y.: 2014-15, 2015-16, M/S Csj Infrastructure Pvt.Ltd., The Acit, C/O C.A. Ajay Kumar Jain, Vs Circle 2(1), Sco 80-81, 4Th Floor, Sector 17-C, Chandigarh. Chandigarh. "थायी लेखा सं./Pan No: Aaccc8021G अपीलाथ"/Appellant ""यथ"/Respondent आयकर अपील सं./ Ita No. 146, 147/Chd/2020 "नधा"रण वष" / A.Y.: 2014-15, 2015-16, The Acit, Vs M/S Csj Infrastructure Pvt. Ltd., Circle 2(1), C/O C.A. Ajay Kumar Jain, Chandigarh. Sco 80-81, 4Th Floor, Sector 17-C, Chandigarh. "थायी लेखा सं./Pan No: Aaccc8021G अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Ajay Jain, Ca Revenue By : Shri Manav Bansal, Cit, Dr Date Of Hearing : 19.05.2025 Date Of Pronouncement : 28.05.2025 Physical Hearing O R D E R

Price + Stamp Duty & Registration Charges 3.1 The Vendee has made a payment of Rs.2,60,00,000/- vide cheque No. 023655 on 25.01.2011. There was some dispute between the assessee and the vendee and ultimately Sale Deed was executed during the Accounting Year relevant to assessment year 2014-15. The ld. AO has confronted the assessee qua Section 43CA

CSJ INFRASTRUCTURE PVT.LTD,CHANDIGARH vs. ACIT,CIRCLE--2(1), CHANDIGARH

In the result, both the appeals of the assessee are allowed and that of the Revenue are dismissed

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 131,132 /Chd/2020 "नधा"रण वष" / A.Y.: 2014-15, 2015-16, M/S Csj Infrastructure Pvt.Ltd., The Acit, C/O C.A. Ajay Kumar Jain, Vs Circle 2(1), Sco 80-81, 4Th Floor, Sector 17-C, Chandigarh. Chandigarh. "थायी लेखा सं./Pan No: Aaccc8021G अपीलाथ"/Appellant ""यथ"/Respondent आयकर अपील सं./ Ita No. 146, 147/Chd/2020 "नधा"रण वष" / A.Y.: 2014-15, 2015-16, The Acit, Vs M/S Csj Infrastructure Pvt. Ltd., Circle 2(1), C/O C.A. Ajay Kumar Jain, Chandigarh. Sco 80-81, 4Th Floor, Sector 17-C, Chandigarh. "थायी लेखा सं./Pan No: Aaccc8021G अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Ajay Jain, Ca Revenue By : Shri Manav Bansal, Cit, Dr Date Of Hearing : 19.05.2025 Date Of Pronouncement : 28.05.2025 Physical Hearing O R D E R

Price + Stamp Duty & Registration Charges 3.1 The Vendee has made a payment of Rs.2,60,00,000/- vide cheque No. 023655 on 25.01.2011. There was some dispute between the assessee and the vendee and ultimately Sale Deed was executed during the Accounting Year relevant to assessment year 2014-15. The ld. AO has confronted the assessee qua Section 43CA

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

13. Mrs. Suri, firstly relied upon the judgment of the Supreme Court in Commissioner of Income Tax, West v. George Henderson and Co. Ltd. (1967) 66 ITR 622 where section 12B of the 1922 Act fell for consideration. Section 12B of the 1922 Act as it was in force on April, 1, 1947 read as under:- "Section

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)

13,486/-. Thus total income as per order u/s 143(3) dt. 07/12/2019 is Rs. 19,62,660/- where there is addition of Rs. 2,06,85,300/- being the amount on unsecured loan claimed to have been capitalized, as unexplained expenditure under section 69C and further addition of Rs. 36,65,528/- is added being the interest on unsecured

DEPUTY COMMISSIONER OF INCOME TAX, CHANDIGARH vs. JAMES HOTELS LTD, CHANDIGARH

Bench: The Said Resolution To Enhance Authorized Share Capital.

Transfer Pricing Officer and thereafter the Ld. AO changed the nature of transaction from share application money and treated it as loan on which notional interest was computed. Hon'ble ITAT held that AO has no power to reclassify the transaction from the share application money to loan. 12.18 It was further submitted that while levying the penalty, Additional

DESH MITTER GAIND,PANCHKULA vs. INCOME TAX OFFICER, WARD-1, PANCHKULA, PANCHKULA, HARYANA

Bench: This Tribunal. The Assessee Is Aggrieved By The Order Of Cit(A) Bearing No. Itba/Nfac/S/250/2023-

price at Rs.2,42,00,000/-. The question is when long term gain or short term gain arises. It is on the date on which an asset (whether long term or short term) is transferred. As per section 2(47) of the LT.Act, 1961:- transfer", in relation to a capital asset, includes,— (i) the sale, exchange or relinquishment