GLAXOSMITHKLINE ASIA PVT. LTD.,GURGAON vs. DCIT, CHANDIGARH

In the result, all the appeals of the assessee and the Revenue, stand partly allowed for statistical purposes

price of international transaction of export of goods. Re: Incorrect exclusion of comparable by the TPO In this regard, it is respectfully submitted that while applying TNMM, the following companies excluded by the TPO in the impugned order ought to be considered as comparable for the reasons tabulated as under: Company Reasons for Remarks of the applicant Name Remarks

M/S GLAXO SMITHKLINE ASIA PVT. LTD.,GURGAON vs. ACIT, C-4(1), CHANDIGARH

In the result, all the appeals of the assessee and the Revenue, stand partly allowed for statistical purposes

price of international transaction of export of goods. Re: Incorrect exclusion of comparable by the TPO In this regard, it is respectfully submitted that while applying TNMM, the following companies excluded by the TPO in the impugned order ought to be considered as comparable for the reasons tabulated as under: Company Reasons for Remarks of the applicant Name Remarks

GLAXOSMITHKLINE ASIA PVT. LTD.,GURGAON vs. ACIT, CHANDIGARH

In the result, all the appeals of the assessee and the Revenue, stand partly allowed for statistical purposes

price of international transaction of export of goods. Re: Incorrect exclusion of comparable by the TPO In this regard, it is respectfully submitted that while applying TNMM, the following companies excluded by the TPO in the impugned order ought to be considered as comparable for the reasons tabulated as under: Company Reasons for Remarks of the applicant Name Remarks

ACIT, CHANDIGARH vs. M/S GLAXO SMITHKLINE ASIA PVT. LTD., GURGAON

In the result, all the appeals of the assessee and the Revenue, stand partly allowed for statistical purposes

price of international transaction of export of goods. Re: Incorrect exclusion of comparable by the TPO In this regard, it is respectfully submitted that while applying TNMM, the following companies excluded by the TPO in the impugned order ought to be considered as comparable for the reasons tabulated as under: Company Reasons for Remarks of the applicant Name Remarks

GLAXOSMITHKLINE ASIA PVT. LTD.,GURGAON vs. DCIT, CHANDIGARH

In the result, all the appeals of the assessee and the Revenue, stand partly allowed for statistical purposes

price of international transaction of export of goods. Re: Incorrect exclusion of comparable by the TPO In this regard, it is respectfully submitted that while applying TNMM, the following companies excluded by the TPO in the impugned order ought to be considered as comparable for the reasons tabulated as under: Company Reasons for Remarks of the applicant Name Remarks

M/S GLAXOSMITHKLINE ASIA PVT. LTD.,GURGAON vs. ACIT, CHANDIGARH

In the result, all the appeals of the assessee and the Revenue, stand partly allowed for statistical purposes

price of international transaction of export of goods. Re: Incorrect exclusion of comparable by the TPO In this regard, it is respectfully submitted that while applying TNMM, the following companies excluded by the TPO in the impugned order ought to be considered as comparable for the reasons tabulated as under: Company Reasons for Remarks of the applicant Name Remarks

ACIT, CHANDIGARH vs. M/S GLAXO SMITHKLINE ASIA PVT. LTD., GURGAON

In the result, all the appeals of the assessee and the Revenue, stand partly allowed for statistical purposes

price of international transaction of export of goods. Re: Incorrect exclusion of comparable by the TPO In this regard, it is respectfully submitted that while applying TNMM, the following companies excluded by the TPO in the impugned order ought to be considered as comparable for the reasons tabulated as under: Company Reasons for Remarks of the applicant Name Remarks

ACIT, CHANDIGARH vs. M/S GLAXO SMITHKLINE ASIA PVT. LTD., GURGAON

In the result, all the appeals of the assessee and the Revenue, stand partly allowed for statistical purposes

price of international transaction of export of goods. Re: Incorrect exclusion of comparable by the TPO In this regard, it is respectfully submitted that while applying TNMM, the following companies excluded by the TPO in the impugned order ought to be considered as comparable for the reasons tabulated as under: Company Reasons for Remarks of the applicant Name Remarks

M/S GLAXO SMITHKLINE ASIA PVT. LTD.,GURGAON vs. ACIT, C-4(1), CHANDIGARH

In the result, all the appeals of the assessee and the Revenue, stand partly allowed for statistical purposes

price of international transaction of export of goods. Re: Incorrect exclusion of comparable by the TPO In this regard, it is respectfully submitted that while applying TNMM, the following companies excluded by the TPO in the impugned order ought to be considered as comparable for the reasons tabulated as under: Company Reasons for Remarks of the applicant Name Remarks

M/S GLAXO SMITHKLINE ASIA PVT. LTD.,NABHA vs. DCIT, C-4(1), CHANDIGARH

In the result, all the appeals of the assessee and the Revenue, stand partly allowed for statistical purposes

price of international transaction of export of goods. Re: Incorrect exclusion of comparable by the TPO In this regard, it is respectfully submitted that while applying TNMM, the following companies excluded by the TPO in the impugned order ought to be considered as comparable for the reasons tabulated as under: Company Reasons for Remarks of the applicant Name Remarks

GLAXOSMITHKLINE ASIA PVT. LTD.,GURGAON vs. ACIT, CHANDIGARH

In the result, all the appeals of the assessee and the Revenue, stand partly allowed for statistical purposes

price of international transaction of export of goods. Re: Incorrect exclusion of comparable by the TPO In this regard, it is respectfully submitted that while applying TNMM, the following companies excluded by the TPO in the impugned order ought to be considered as comparable for the reasons tabulated as under: Company Reasons for Remarks of the applicant Name Remarks

ACIT, CHANDIGARH vs. M/S GLAXO SMITHKLINE ASIA PVT. LTD., GURGAON

In the result, all the appeals of the assessee and the Revenue, stand partly allowed for statistical purposes

price of international transaction of export of goods. Re: Incorrect exclusion of comparable by the TPO In this regard, it is respectfully submitted that while applying TNMM, the following companies excluded by the TPO in the impugned order ought to be considered as comparable for the reasons tabulated as under: Company Reasons for Remarks of the applicant Name Remarks

LAKHVIR KAUR,MOHALI vs. DCIT/ACIT(CEN)-2, CHANDIGARH

In the result, both the above appeals of the Assessee are\nallowed

transferred to the office of Ld. A.O. - ACIT- Central\nCircle II, Chandigarh vide order under section 127of the Income\nTax Act, 1961.\n5.2 Accordingly, assessment in the case under consideration\nhas been made u/s 153A r.w.s 143(3) of the Act, vide order dated\n31.03.2022 by the Ld. A.O.\n5.3 During the course of assessment for AY 2020-21, total

LAKHVIR KAUR,MOHALI, CHANDIGARH vs. DCIT/ACIT(CEN)-2 CHD, CHANDIGARH

In the result, both the above appeals of the Assessee are\nallowed

transferred to the office of Ld. A.O. - ACIT- Central\nCircle II, Chandigarh vide order under section 127of the Income\nTax Act, 1961.\n5.2 Accordingly, assessment in the case under consideration\nhas been made u/s 153A r.w.s 143(3) of the Act, vide order dated\n31.03.2022 by the Ld. A.O.\n5.3 During the course of assessment for AY 2020-21, total

MAXPORT INDIA PRIVATE LIMITED,CHANDIGARH vs. DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1,CHANDIGARH, CHANDIGARH

price fluctuations. The reliance in\nthis respect can be placed on the following decisions:\n“(i) [Assistant Commissioner of Income Tax, Central Circle-1(3), Kolkata v. Narula\nEducational Trust [2021] 126 taxmann.com 158 (Kolkata - Trib.)\n(ii) Champaklal S. Kasat v. Deputy Commissioner of Income-tax, Cent. Cir. 1(3),\nAhmedabad [2017] 82 taxmann.com 243 (Ahmedabad - Trib

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

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

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

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

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

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