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.”

Transfer Pricing Officer the aggregate value of specified domestic transactions has been taken from the Form 3CEB filed by the appellant. Perusal of Form 3CEB, prescribed under Rule 10E, states as "Report from an accountant to be furnished under section 92E relating to International Transaction(s) and Specified domestic transaction(s). The particulars of the above transaction(s) required

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)

14. Per contra the Revenue argued that the assessee originally filed return as resident and therefore AO proceeded accordingly; that Section 144C was intended for transfer-pricing

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 Study was illegally disregarded and ignored. Further, though the ld. DRP initially upheld the CUP in principle, it upheld the CPM, as applied by the TPO, and it went on to ultimately make the TNMM the basis for the adjustment to determine the arm’s length price of the transaction. It also has rightly been called in question

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

In the result, all appeals of the assessee are allowed

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 by all revenue authorities including the CIT(A) and\nthe BMA authority.\n\n12.\nThe assessee in written submissions has contended that once she is\naccepted as a non-resident, she automatically falls

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

In the result, all appeals of the assessee are allowed

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 by all revenue authorities including the CIT(A) and\nthe BMA authority.\n12.\nThe assessee in written submissions has contended that once she is\naccepted as a non-resident, she automatically falls in the definition

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

14. Considering the language of sub section (2) of Section 12B of the 1922 Act, we are of the opinion that the judgment applies to Section 48 of the 1961 Act. The language of sub section (2) in this regard is 'similar to the language of the opening part of Section 48 of the Act. 15. The judgment undoubtedly holds

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 documentation which contained the functional and economic analysis of the assessee and the comparables and no adverse inference was drawn in respect of International and Specified Domestic Transactions so undertaken by the assessee in terms of his order passed under section 92CA(3) dt. 28/09/2017. At the same time, the TPO in his order has stated that

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)

14. Ld. AR also submitted that the collector rate is always fixed as minimum rate in order to collect stamp duty and FMV cannot be compared with collector rate.Ld. AR submitted that the FMV of construction of house depends upon the quality of construction and collector rate cannot applied blankly on all type of construction and your honour shall appreciate

KAKA SINGH ALIAS GULJAR SINGH,PATIALA vs. INCOME TAX OFFICER , PATIALA

14 provide\n\n39\n\nthe heads of income and Clause F provide income from other sources and\nincome from other sources is provided under section 56 of the Act. Thus,\nonce the interest on enhanced compensation is included as income from\nother sources under section 56 then the same is chargeable to tax under\nsection 4 being the deemed

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

Transfer Pricing Grounds: Legal grounds Ground 1: That on the facts and circumstances of the case and in law, the impugned order passes by the Ld. AO is barred by limitation in terms of section 153(1)/(4) and therefore, is liable to be quashed. Ground 2: Based on the facts and circumstances of the present case

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 and the Tribunal held that AO has no power to reclassify the transaction from the share application money to loan. 8.3 It was further submitted that while levying the penalty, Additional

NARENDER KAUR,KURUKSHETRA, HARYANA vs. INCOME TAX OFFICER WARD-1 , KURUKSHETRA

14 provide\nthe heads of income and Clause F provide income from other sources and\nincome from other sources is provided under section 56 of the Act. Thus,\nonce the interest on enhanced compensation is included as income from\nother sources under section 56 then the same is chargeable to tax under\nsection 4 being the deemed income

INCOME TAX OFFICER, WARD-5(5), CHANDIGARH, CHANDIGARH vs. AVTAR SINGH, VILLAGE- KAIMBWALA

section\n28 or section 41 or section 59;\n53[(va) any sum chargeable to income-tax under clause (iiia) of section 28 ;]\n54[(vb) any sum chargeable to income-tax under clause (iiib) of section 28 ;]\n55[(vc) any sum chargeable to income-tax under clause (iiic) of section 28 ;]\n56[(vd)] the value of any benefit or perquisite taxable

SURESH KUMAR,YAMUNANAGAR vs. ITO, W-4, YAMUNANAGAR

In the result, appeal of the assessee is allowed

Bench: Shri Rajpal Yadav & Shri Krinwant Sahay

price during the pendency of the land acquisition proceedings. It is a measure to offset the effect of inflation and the continuous rise in the value of properties. [See: State of Tamil Nadu and others etc. v. L. Krishnan and others etc. - AIR 1996 SC 497]. Therefore, the amount payable under Section

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

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

14 provide the heads of income and Clause F provide income from other sources and income from other sources is provided under section 56 of the Act. Thus, once the interest on enhanced compensation is included as income from other sources under section 56 then the same is chargeable to tax under section 4 being the deemed income

RANJIT SINGH,PANCHKULA vs. DEPUTY DIRECTOR, CPC DEPARTMENT

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

14 provide the heads of income and Clause F provide income from other sources and income from other sources is provided under section 56 of the Act. Thus, once the interest on enhanced compensation is included as income from other sources under section 56 then the same is chargeable to tax under section 4 being the deemed income

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

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

14 provide the heads of income and Clause F provide income from other sources and income from other sources is provided under section 56 of the Act. Thus, once the interest on enhanced compensation is included as income from other sources under section 56 then the same is chargeable to tax under section 4 being the deemed income

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

14 provide the heads of income and Clause F provide income from other sources and income from other sources is provided under section 56 of the Act. Thus, once the interest on enhanced compensation is included as income from other sources under section 56 then the same is chargeable to tax under section 4 being the deemed income