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

143(3) read with Section 263 of the Act on 20.12.2017. A perusal of his order would reveal that ld. AO has observed that assessee has sold shares of M/s Oasis Cine Communication Ltd. for a consideration of Rs.3,72,79,089/- and claimed exemption under Section 10(38) of the Income Tax Act. The AO, thereafter, made reference

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

143(3) read with Section 263 of the Act on 20.12.2017. A perusal of his order would reveal that ld. AO has observed that assessee has sold shares of M/s Oasis Cine Communication Ltd. for a consideration of Rs.3,72,79,089/- and claimed exemption under Section 10(38) of the Income Tax Act. The AO, thereafter, made reference

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

143(3) read with Section 263 of the Act on 20.12.2017. A perusal of his order would reveal that ld. AO has observed that assessee has sold shares of M/s Oasis Cine Communication Ltd. for a consideration of Rs.3,72,79,089/- and claimed exemption under Section 10(38) of the Income Tax Act. The AO, thereafter, made reference

M/S JSK INTERNATIONAL,BADDI vs. PR. CIT, SHIMLA

The appeal of the Assessee is Allowed

3 of 2003 was replaced with this (Instruction No. 15 of 2015) dated 16.10.2015 to provide updated and adequate guidance on the transfer pricing provisions pertaining to international transitions. 7. Further, in para -7 of the said instruction dated 16.10.2015, the Board has further clarified that this guidance is applicable only to transfer pricing provisions in respect of international transactions

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

In the result, both the appeals are allowed

143(3) read with Section 263 of the Act on\n20.12.2017. A perusal of his order would reveal that ld. AO\nhas observed that assessee has sold shares of M/s Oasis\nCine Communication Ltd. for consideration\nof\nRs.3,72,79,089/- and claimed exemption under Section\n10(38) of the Income Tax Act. The AO, thereafter, made\nreference

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

The appeals are partly allowed

143(3) read with Section 263 of the Act on\n20.12.2017. A perusal of his order would reveal that 1d. AO\nhas observed that assessee has sold shares of M/s Oasis\nCine Communication Ltd. for a consideration of\nRs.3,72,79,089/- and claimed exemption under Section\n10(38) of the Income Tax Act. The AO, thereafter, made\nreference

SH. DINESH SOIN,LUDHIANA vs. ACIT, LUDHIANA

The appeals are partly allowed

143(3) read with Section 263 of the Act on\n20.12.2017. A perusal of his order would reveal that 1d. AO\nhas observed that assessee has sold shares of M/s Oasis\nCine Communication Ltd. for a consideration of\nRs.3,72,79,089/- and claimed exemption under Section\n10(38) of the Income Tax Act.\nThe AO, thereafter, made\nreference

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

The appeals are partly allowed

143(3) read with Section 263 of the Act on\n20.12.2017. A perusal of his order would reveal that 1d. AO\nhas observed that assessee has sold shares of M/s Oasis\nCine Communication Ltd. for a consideration of\nRs.3,72,79,089/- and claimed exemption under Section\n10(38) of the Income Tax Act.\nThe AO, thereafter, made\nreference

DCIT,CIRCLE-1(EXEMPTION), CHANDIGARH vs. M/S MANAV MANGAL SCHOOL( 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

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

M/S SHUBHAM COTTON MILLS PVT. LTD.,ELLENABAD vs. DCIT, CIRCLE, SIRSA

In the result appeal of the assessee is allowed

143(3) on 29-12-2017 at an income of Rs. 1,31,72,653/-. During the assessment proceedings it was noticed from the books of the assessee company that assessee has shown higher purchase price in respect of some commodities against the market price. Similarly, assessee company has shown lower sales value as compared to market price. Moreover

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(3) r.w.s 144C(1) of the Act. 4. Being aggrieved, the Assessee carried the matter in appeal before the Ld. CIT(A) who has sustained the said Transfer Pricing