SH. AMAR SINGH,JAGADHARI vs. ITO, YAMUNANAGAR

In the result, both the appeal of different assessees are allowed

Bench: Shri Sanjay Garg & Dr. B.R.R. Kumar

Section 54 of Transfer Property Act, it is clear that when the price is partly paid and partly promised, the immovable property is deemed to have been transferred on execution and registration of Sale Deed if the possession of property has been given to the buyer. The assessee’s claim that the possession of the property remained with the seller

SH. JAI RAM,JAGADHARI vs. ITO, YAMUNANAGAR

In the result, both the appeal of different assessees are allowed

Bench: Shri Sanjay Garg & Dr. B.R.R. Kumar

Section 54 of Transfer Property Act, it is clear that when the price is partly paid and partly promised, the immovable property is deemed to have been transferred on execution and registration of Sale Deed if the possession of property has been given to the buyer. The assessee’s claim that the possession of the property remained with the seller

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

The appeal of the Assessee is Allowed

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. Similar guidance in respect of transfer pricing provisions pertaining

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

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 Officer made a variation to the Arm's Length\nPrice and valued the transaction at Rs.517.82 per share. In other words, he\nrecommended a variation in the Arm's Length Price. In these circumstances, the\nPetitioner would certainly be an eligible Assessee as contemplated under Section\n144C(15

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 Officer made a variation to the Arm's Length\nPrice and valued the transaction at Rs.517.82 per share. In other words, he\nrecommended a variation in the Arm's Length Price. In these circumstances, the\nPetitioner would certainly be an eligible Assessee as contemplated under Section\n144C(15

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 Officer made a variation to the Arm's Length\nPrice and valued the transaction at Rs.517.82 per share. In other words, he\nrecommended a variation in the Arm's Length Price. In these circumstances, the\nPetitioner would certainly be an eligible Assessee as contemplated under Section\n144C(15

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

15 % of Sale Price + Stamp Duty & Registration Charges 3.1 The Vendee has made a payment of Rs.2,60,00,000/- vide cheque No. 023655 on 25.01.2011. There was some dispute between the assessee and the vendee and ultimately Sale Deed was executed during the Accounting Year relevant to assessment year 2014-15. The ld. AO has confronted the assessee

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

15 % of Sale Price + Stamp Duty & Registration Charges 3.1 The Vendee has made a payment of Rs.2,60,00,000/- vide cheque No. 023655 on 25.01.2011. There was some dispute between the assessee and the vendee and ultimately Sale Deed was executed during the Accounting Year relevant to assessment year 2014-15. The ld. AO has confronted the assessee

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

15 % of Sale Price + Stamp Duty & Registration Charges 3.1 The Vendee has made a payment of Rs.2,60,00,000/- vide cheque No. 023655 on 25.01.2011. There was some dispute between the assessee and the vendee and ultimately Sale Deed was executed during the Accounting Year relevant to assessment year 2014-15. The ld. AO has confronted the assessee

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

15 % of Sale Price + Stamp Duty & Registration Charges 3.1 The Vendee has made a payment of Rs.2,60,00,000/- vide cheque No. 023655 on 25.01.2011. There was some dispute between the assessee and the vendee and ultimately Sale Deed was executed during the Accounting Year relevant to assessment year 2014-15. The ld. AO has confronted the assessee

M/S HIND CONSTRUCTION ENGINEERS CONTRCTORS,SANGRUR vs. PR.CIT, PATIALA

In the result, all the appeals of the respective assessees stands allowed

15 to 26 of the paper book. Our attention was further drawn to the replies furnished by the assessee in response to the said notices and questionnaires and which were placed at pages 27 to 50 of the paper book. It was submitted that, thus, the allegation of the Ld. PCIT that the AO had not carried out any inquiries

M/S ADARSH CONSTRUCTIONS AND ENGINEERS,SANGRUR vs. PR.CIT, PATIALA

In the result, all the appeals of the respective assessees stands allowed

15 to 26 of the paper book. Our attention was further drawn to the replies furnished by the assessee in response to the said notices and questionnaires and which were placed at pages 27 to 50 of the paper book. It was submitted that, thus, the allegation of the Ld. PCIT that the AO had not carried out any inquiries

M/S GANGA CONSTRUCTIONS,SANGURUR vs. PCIT, PATIALA

In the result, all the appeals of the respective assessees stands allowed

15 to 26 of the paper book. Our attention was further drawn to the replies furnished by the assessee in response to the said notices and questionnaires and which were placed at pages 27 to 50 of the paper book. It was submitted that, thus, the allegation of the Ld. PCIT that the AO had not carried out any inquiries

M/S AMBEY ENGINEERS AND CONTRACTORS,NEW DELHI vs. PR.CIT, PATIALA

In the result, all the appeals of the respective assessees stands allowed

15 to 26 of the paper book. Our attention was further drawn to the replies furnished by the assessee in response to the said notices and questionnaires and which were placed at pages 27 to 50 of the paper book. It was submitted that, thus, the allegation of the Ld. PCIT that the AO had not carried out any inquiries

M/S ANAND ENGINEERS & CONTRACTORS,SANGURUR vs. PR.CIT, PATIALA

In the result, all the appeals of the respective assessees stands allowed

15 to 26 of the paper book. Our attention was further drawn to the replies furnished by the assessee in response to the said notices and questionnaires and which were placed at pages 27 to 50 of the paper book. It was submitted that, thus, the allegation of the Ld. PCIT that the AO had not carried out any inquiries

M/S AMAR CONTRUCTION AND ENGINEER ,SANGRUR vs. PCTI, PATIALA

In the result, all the appeals of the respective assessees stands allowed

15 to 26 of the paper book. Our attention was further drawn to the replies furnished by the assessee in response to the said notices and questionnaires and which were placed at pages 27 to 50 of the paper book. It was submitted that, thus, the allegation of the Ld. PCIT that the AO had not carried out any inquiries

M/S HIMALYAN CONSTRUCTION AND ENGINEERS,SANGRUR vs. PCIT, PATIALA

In the result, all the appeals of the respective assessees stands allowed

15 to 26 of the paper book. Our attention was further drawn to the replies furnished by the assessee in response to the said notices and questionnaires and which were placed at pages 27 to 50 of the paper book. It was submitted that, thus, the allegation of the Ld. PCIT that the AO had not carried out any inquiries