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

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

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)

8. Thereafter, another submission was filed by the assessee dt. 07/02/2024 and the contents thereof read as under: “In addition to our previous reply submitted on 05.01.2024, we may like to bring to your notice the following objection to your proposed revision of order of Transfer Pricing Order: • We would like to state that complete information along with complete details

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)

8. Thereafter, another submission was filed by the assessee dt. 07/02/2024 and the contents thereof read as under: “In addition to our previous reply submitted on 05.01.2024, we may like to bring to your notice the following objection to your proposed revision of order of Transfer Pricing Order: • We would like to state that complete information along with complete details

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

In the result, appeal of the assessee is allowed

13-14) which is less than all the three rates above. Therefore, Steam rate of Rs. 2,160/ MT can be treated as Arm's Length Price. 5.3 As regard to bench marking of transfer of steam from captive power plant to non eligible unit, the TPO noted that the assessee for the purpose of calculating the profitability of power

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

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)

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) read with sections 143(3A) and 143(3B) of the Income Tax Act. Aggrieved therewith, the assessee is in appeal

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

In the result, both the appeals of the Revenue are

13,90,00,000/-, 16,54,05,000/- 21,27,15,000 - 4.7 The appellant has further stated that no un-due benefit has been taken by these persons as the sale of land has been executed by Sh. Harpreet Singh for Rs. 9.60 crores and by Sh. Manbir Singh for Rs. 4.62 crores in the name of the society

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

In the result, both the appeals of the Revenue are

13,90,00,000/-, 16,54,05,000/- 21,27,15,000 - 4.7 The appellant has further stated that no un-due benefit has been taken by these persons as the sale of land has been executed by Sh. Harpreet Singh for Rs. 9.60 crores and by Sh. Manbir Singh for Rs. 4.62 crores in the name of the society

M/S SHIV SHAKTI CONSTRUCTION,SANGRUR vs. PCIT, PATIALA

The appeals of the assessees stand allowed

Bench: Shri Sudhanshu Srivastava & Shri Vikram Singh Yadav

13 3.1 The Ld. AR also drew our attention to the grounds filed in respect of the remaining four appeals and pointed out that these grounds were also identical. 3.2 However, for the sake of completeness the grounds in the remaining four appeals are also being reproduced as under:- ITA 482/Chd/2022 1. That order passed u/s 263 of the Income

M/S MAA BHAGWATI ENTERPRISES,SANGRUR vs. PCIT, PATIALA

The appeals of the assessees stand allowed

Bench: Shri Sudhanshu Srivastava & Shri Vikram Singh Yadav

13 3.1 The Ld. AR also drew our attention to the grounds filed in respect of the remaining four appeals and pointed out that these grounds were also identical. 3.2 However, for the sake of completeness the grounds in the remaining four appeals are also being reproduced as under:- ITA 482/Chd/2022 1. That order passed u/s 263 of the Income

M/S OMKAR ENGINEER AND CONTRACTOR,SANGRUR vs. PCTI, PATIALA

The appeals of the assessees stand allowed

Bench: Shri Sudhanshu Srivastava & Shri Vikram Singh Yadav

13 3.1 The Ld. AR also drew our attention to the grounds filed in respect of the remaining four appeals and pointed out that these grounds were also identical. 3.2 However, for the sake of completeness the grounds in the remaining four appeals are also being reproduced as under:- ITA 482/Chd/2022 1. That order passed u/s 263 of the Income

M/S OM CONTRACTOR AND ENGINEERS,SANGRUR vs. PCIT, PATIALA

The appeals of the assessees stand allowed

Bench: Shri Sudhanshu Srivastava & Shri Vikram Singh Yadav

13 3.1 The Ld. AR also drew our attention to the grounds filed in respect of the remaining four appeals and pointed out that these grounds were also identical. 3.2 However, for the sake of completeness the grounds in the remaining four appeals are also being reproduced as under:- ITA 482/Chd/2022 1. That order passed u/s 263 of the Income

M/S GANGA CONSTRUCTIONS,SANGURUR 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