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

price is paid and the deed is delivered . In the percent case, from the statement of case itself as drawn up by the Tribunal, it is apparent that the parties had clearly intended that despite the execution and registration of sale deeds, transfer by way of sale will become effective only on payment of the entire consideration amount

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

price is paid and the deed is delivered . In the percent case, from the statement of case itself as drawn up by the Tribunal, it is apparent that the parties had clearly intended that despite the execution and registration of sale deeds, transfer by way of sale will become effective only on payment of the entire consideration amount

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 92BA on account of the fact that the provisions of the transfer pricing do not apply to investment in equity shares amounting to Rs. 5,42,29,540/- and Dividend paid amounting to Rs. 1,19

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

In the result, appeal of the assessee is allowed

transferred to Electricity Units Consumption Manufacturing Processes Apr-14 3,900,800 932,400 2,968,400 6.72 19,947,648 May-14 3,901,000 981,900 2,919,100 6.72 19

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 passed under sub-section (3) of section 92CA. For this class of assessees, it prescribes a collegium of three commissioners, once objections are preferred. The Dispute Resolution Panel's powers are coterminous with the Commissioner of Income-tax (Appeals), including the power to confirm, reduce or enhance the variation proposed and to consider the issues not agitated

M/S SHIV SHAKTI CONSTRUCTION,SANGRUR vs. PCIT, PATIALA

The appeals of the assessees stand allowed

Bench: Shri Sudhanshu Srivastava & Shri Vikram Singh Yadav

19 and credit entries of almost the same amounts and there was no entry pertaining to expenditure incurred by the assessee. 5.1 The Ld. CIT DR reiterated that the AO should have brought the entire amount to tax because if the assessee was not carrying out any sub contract work, the entire income was to be taxed, being the compensation

M/S MAA BHAGWATI ENTERPRISES,SANGRUR vs. PCIT, PATIALA

The appeals of the assessees stand allowed

Bench: Shri Sudhanshu Srivastava & Shri Vikram Singh Yadav

19 and credit entries of almost the same amounts and there was no entry pertaining to expenditure incurred by the assessee. 5.1 The Ld. CIT DR reiterated that the AO should have brought the entire amount to tax because if the assessee was not carrying out any sub contract work, the entire income was to be taxed, being the compensation

M/S OM CONTRACTOR AND ENGINEERS,SANGRUR vs. PCIT, PATIALA

The appeals of the assessees stand allowed

Bench: Shri Sudhanshu Srivastava & Shri Vikram Singh Yadav

19 and credit entries of almost the same amounts and there was no entry pertaining to expenditure incurred by the assessee. 5.1 The Ld. CIT DR reiterated that the AO should have brought the entire amount to tax because if the assessee was not carrying out any sub contract work, the entire income was to be taxed, being the compensation

M/S OMKAR ENGINEER AND CONTRACTOR,SANGRUR vs. PCTI, PATIALA

The appeals of the assessees stand allowed

Bench: Shri Sudhanshu Srivastava & Shri Vikram Singh Yadav

19 and credit entries of almost the same amounts and there was no entry pertaining to expenditure incurred by the assessee. 5.1 The Ld. CIT DR reiterated that the AO should have brought the entire amount to tax because if the assessee was not carrying out any sub contract work, the entire income was to be taxed, being the compensation

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

In the result, all appeals of the assessee are allowed

19-07-2015 | 21-12-2015 | 154 | | | \n| | 05-01-2016 | 31.03.2016 | 86 | | | \n| | 01.04.2016 | 01-06-2016 | 61 | | | \n| 2016-17 | 10-08-2016 | 16-12-2016 | 127 | 271 | 94 | Non-Resident\n| | 07-01-2017 | 31.03.2017 | 83 | | | \n| 2017-18 | 01.04.2017 | 18-07-2017 | 108 | 328 | 37 | Non-Resident

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

In the result, all appeals of the assessee are allowed

19-07-2015 | 21-12-2015 | 154 | | | |\n| | 05-01-2016 | 31.03.2016 | 86 | | | |\n| 2016-17 | 01.04.2016 | 01-06-2016 | 61 | 271 | 94 | Non-Resident |\n| | 10-08-2016 | 16-12-2016 | 127 | | | |\n| | 07-01-2017 | 31.03.2017 | 83 | | | |\n| 2017-18 | 01.04.2017 | 18-07-2017 | 108 | 328 | 37 | Non-Resident

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

In the result, all appeals of the assessee are allowed

19-07-2015\n21-12-2015 | 154 | | |\n| | 05-01-2016\n31.03.2016 | 86 | | |\n| | 01.04.2016\n01-06-2016 | 61 | | |\n| 2016-17 | 10-08-2016\n16-12-2016 | 127 | 271 | 94 | Non-Resident\n| | 07-01-2017\n31.03.2017 | 83 | | |\n| 2017-18 | 01.04.2017\n18-07-2017 | 108 | 328 | 37 | Non-Resident\n\n| | 23-08-2017\n31.03.2018

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)

Section 92C(1) of the Act, the most appropriate method shall be the method best suited to the facts and circumstances of each particular international transaction and which method provides the most reliable measure of an arm’s length price in relation to the international transaction. The Rule further provides that while selecting the most appropriate method, the nature

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

transfer of the capital asset. 18. The Hon’ble High Court has held that the full value of consideration is neither the market value nor necessarily the price stated in the document for sale but the price actually arrived at between the parties to the transactions. It was further held that where it is found by the Assessing officer 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)

price with low level of construction which cannot be compared with residential house on independent plot in posh area. 15. The Ld. AR further submitted that PCIT has placed reliance on gift deed dated 8/10/2009 executed in favour of the assessee by his father. Stamp duty is charged on minimum collector for stamp duty purposes and it cannot reflect

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. Hon'ble ITAT held that AO has no power to reclassify the transaction from the share application money to loan. 12.18 It was further submitted that while levying the penalty, Additional

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

19. The cumulative effect of section 145A(b) and section 56(2)(viii) would be\nthat\nany interest received\non compensation or\non enhanced compensation shall be taxable under the head \"Income from\nother sources\" in the year of receipt.\n20. However, by section 27 of the 2009 Act, a new clause (iv) in section 57\nhas been inserted with