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.”

section 143(2) and 142(1) were issued. Further during the course of assessment proceeding, the AO referred the matter to the Transfer Pricing

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

In the result, appeal of the assessee is allowed

143(3) of the Income Tax Act, 1961 (hereinafter referred to as ‘Act’) in pursuance to the direction given by the Dispute Resolution Panel-1 under section 144C(5) of the Act vide order dt. 25/07/2019. . 2. Following grounds have been raised in this appeal: 1. GENERAL GROUNDS 1.1 The assessment order passed by the Ld. AO in pursuance

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

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

transferred to the beneficiary at a very nominal price mostly off-line through preferential allotment or off-line sale to save STT. The beneficiary (an individual) holds the share for one year, the statutory period after which LTCG is exempt under section 10(38) of the Income tax Act 1961. In the meantime the operators rig the price

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

transferred to the beneficiary at a very nominal price mostly off-line through preferential allotment or off-line sale to save STT. The beneficiary (an individual) holds the share for one year, the statutory period after which LTCG is exempt under section 10(38) of the Income tax Act 1961. In the meantime the operators rig the price

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

transferred to the beneficiary at a very nominal price mostly off-line through preferential allotment or off-line sale to save STT. The beneficiary (an individual) holds the share for one year, the statutory period after which LTCG is exempt under section 10(38) of the Income tax Act 1961. In the meantime the operators rig the price

SMT. RITU SOIN,LUDHIANA vs. ACIT, CC-II, LUDHIANA

In the result, both the appeals are allowed

transferred to\nthe beneficiary at a very nominal price mostly off-line through\npreferential allotment or off-line sale to save STT. The beneficiary\n(an individual) holds the share for one year, the statutory period\nafter which LTCG is exempt under section 10(38) of the Income tax\nAct 1961. In the meantime the operators rig the price

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)

143(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

SMT. GINNY SOIN,LUDHIANA vs. ACIT, CC-II, LUDHIANA

The appeals are partly allowed

transferred\nto the beneficiary at a very nominal price mostly off-line through\npreferential allotment or off-line sale to save STT. The beneficiary\n(an individual) holds the share for one year, the statutory period\nafter which LTCG is exempt under section 10(38) of the Income\ntax Act 1961. In the meantime the operators rig the price

SMT. GINNY SOIN,LUDHIANA vs. ACIT, CC-II, LUDHIANA

The appeals are partly allowed

transferred\nto the beneficiary at a very nominal price mostly off-line through\npreferential allotment or off-line sale to save STT. The beneficiary\n(an individual) holds the share for one year, the statutory period\nafter which LTCG is exempt under section 10(38) of the Income\ntax Act 1961. In the meantime the operators rig the price

SH. DINESH SOIN,LUDHIANA vs. ACIT, LUDHIANA

The appeals are partly allowed

transferred\nto the beneficiary at a very nominal price mostly off-line through\npreferential allotment or off-line sale to save STT. The beneficiary\n(an individual) holds the share for one year, the statutory period\nafter which LTCG is exempt under section 10(38) of the Income\ntax Act 1961. In the meantime the operators rig the price

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)

section 143(3) was passed on 27/12/2017 and therefore it is clear that as on the date of passing of the TP order as well as the assessment order, the requisite documents were available before the authorities and based on such documents, the transfer Pricing

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

143(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

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

In the result, all appeals of the assessee are allowed

transfer-pricing matters; that BMA proceedings are independent\nand cannot bind AO; that participation cured the defect; and in any case the\ndefect, if any, is cured u/s 292B.\n15.\nWe have heard the rival contention of the parties and perused the\nmaterial available on the record. It is an admitted factual position that the\nassessee was a Non-Resident

SH. VIBHAV JAIN,LUDHIANA vs. DCIT, CC-III, LUDHIANA

In the result, the ground no

Bench: SHRI. SANJAY GARG (Judicial Member), SHRI. VIKRAM SINGH YADAV (Accountant Member)

price have already been mentioned therein and the assessment was duly framed under section 143(1) of the Act and thus it was a case of an unabated assessment. 6.1 It was submitted that the said disclosed income / documents cannot be treated as incriminating material. It was further submitted that there is no evidence or document which was found

SH. ASHISH JAIN,LUDHIANA vs. DCIT, CC-III, LUDHIANA

In the result, the ground no

Bench: SHRI. AAKASH DEEP JAIN (Vice President), SHRI. VIKRAM SINGH YADAV (Accountant Member)

price have already been mentioned therein and the assessment was duly framed under section 143(1) of the Act and thus it was a case of an unabated assessment. 7.1 It was submitted that the said disclosed income / documents cannot be treated as incriminating material. It was further submitted that there is no evidence or document which was found

SH. AKHIL JAIN,LUDHIANA vs. DCIT, CC-III, LUDHIANA

In the result, the ground no

Bench: SHRI. AAKASH DEEP JAIN (Vice President), SHRI. VIKRAM SINGH YADAV (Accountant Member)

price have already been mentioned therein and the assessment was duly framed under section 143(1) of the Act and thus it was a case of an unabated assessment. 7.1 It was submitted that the said disclosed income / documents cannot be treated as incriminating material. It was further submitted that there is no evidence or document which was found

SH. ASHISH JAIN,LUDHIANA vs. DCIT, CC-III, LUDHIANA

In the result, the ground no

Bench: SHRI. AAKASH DEEP JAIN (Vice President), SHRI. VIKRAM SINGH YADAV (Accountant Member)

price have already been mentioned therein and the assessment was duly framed under section 143(1) of the Act and thus it was a case of an unabated assessment. 7.1 It was submitted that the said disclosed income / documents cannot be treated as incriminating material. It was further submitted that there is no evidence or document which was found