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52 results for “transfer pricing”+ Section 250(6)clear

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Key Topics

Section 26365Section 143(3)29Section 143(2)27Addition to Income24Section 250(6)20Section 25315Section 153A15Section 142(1)14Section 14811

A.B. SUGARS LIMITED,PUNJAB vs. PRINCIPAL COMMISSIONER OF INCOME TAX-1, CHANDIGARH

In the result, the appeal of the assessee is allowed

ITA 300/CHANDI/2024[2017-2018]Status: DisposedITAT Chandigarh16 Dec 2024AY 2017-2018

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member), SHRI. PARESH M. JOSHI (Judicial Member)

For Appellant: Shri T.N. Singla, C.AFor Respondent: Shri Rohit Sharma, CIT DR
Section 143(3)Section 263Section 80ISection 92C

6. That all the details related to depreciation as per Companies Act, 2013 and depreciation as per Income Tax Act, 1964 were provided in the Balance Sheet, Tax Audit Report, ITR and also before the Assessing Officer and Transfer Pricing Officer during the assessment proceedings. 7. That the detail, bifurcation and evidence of all expenses attributable to the exempted

Showing 1–20 of 52 · Page 1 of 3

Disallowance6
Cash Deposit5
Depreciation5

A.B. SUGARS LIMITED,PUNJAB vs. PRINCIPAL COMMISSIONER OF INCOME TAX -1, CHANDIGARH, CHANDIGARH

In the result, the appeal of the assessee is allowed

ITA 299/CHANDI/2024[2018-2019]Status: DisposedITAT Chandigarh16 Dec 2024AY 2018-2019

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member), SHRI. PARESH M. JOSHI (Judicial Member)

For Appellant: Shri T.N. Singla, C.AFor Respondent: Shri Rohit Sharma, CIT DR
Section 143(3)Section 263Section 80ISection 92C

6. That all the details related to depreciation as per Companies Act, 2013 and depreciation as per Income Tax Act, 1964 were provided in the Balance Sheet, Tax Audit Report, ITR and also before the Assessing Officer and Transfer Pricing Officer during the assessment proceedings. 7. That the detail, bifurcation and evidence of all expenses attributable to the exempted

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

In the result, all appeals of the assessee are allowed

ITA 900/CHANDI/2025[2018-19]Status: DisposedITAT Chandigarh15 Dec 2025AY 2018-19

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

For Appellant: Shri Rohit Kapoor, Advocate &For Respondent: Shri Manav Bansal, CIT, DR
Section 10(3)Section 153ASection 245D(4)

250/- on account of the alleged difference between salary receipts credited in the bank account and the income declared in the appellant's Income Tax Return (ITR), without appreciating the following: a. That a detailed reconciliation of salary, along with documentary evidence, was submitted by the appellant during the appellate proceedings, which unequivocally proves that the actual salary earned

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

In the result, all appeals of the assessee are allowed

ITA 902/CHANDI/2025[2020-21]Status: DisposedITAT Chandigarh15 Dec 2025AY 2020-21
Section 10(3)Section 153ASection 245D(4)

250/-\non account of the alleged difference between salary receipts\ncredited in the bank account and the income declared in the appellant's\nIncome Tax Return (ITR), without appreciating the following:\na. That a detailed reconciliation of salary, along with documentary evidence,\nwas submitted by the appellant during the appellate proceedings, which\nunequivocally proves that the actual salary earned

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

In the result, all appeals of the assessee are allowed

ITA 899/CHANDI/2025[2016-17]Status: DisposedITAT Chandigarh15 Dec 2025AY 2016-17
For Appellant: Shri Rohit Kapoor, Advocate &For Respondent: Shri Manav Bansal, CIT, DR
Section 10(3)Section 153ASection 245D(4)

250/- on account of the alleged difference between salary receipts\ncredited in the bank account and the income declared in the appellant's\nIncome Tax Return (ITR), without appreciating the following:\n\na. That a detailed reconciliation of salary, along with documentary evidence,\nwas submitted by the appellant during the appellate proceedings, which\nunequivocally proves that the actual salary earned

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

In the result, all appeals of the assessee are allowed

ITA 901/CHANDI/2025[2019-20]Status: DisposedITAT Chandigarh15 Dec 2025AY 2019-20
Section 10(3)Section 153ASection 245D(4)

250/- on account of the alleged difference between salary receipts\ncredited in the bank account and the income declared in the appellant's\nIncome Tax Return (ITR), without appreciating the following:\na. That a detailed reconciliation of salary, along with documentary evidence,\nwas submitted by the appellant during the appellate proceedings, which\nunequivocally proves that the actual salary earned

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

ITA 699/CHANDI/2024[2019-20]Status: DisposedITAT Chandigarh19 Feb 2025AY 2019-20

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

For Appellant: Shri Mohit Dhiman, C.AFor Respondent: Dr. Ranjeet Kaur, Sr. DR
Section 250(6)Section 50C

250(6) dated 30.04.2024 is erroneous, contrary to the facts of the case and is bad in Law. 2) That the Id. CIT(Appeals) has erred in confirming the action of the Assessing Officer in disallowing the capital loss of Rs. 25,75,000/- claimed by the Appellant and by adding this amount in the sale consideration already declared

DCIT, C-1(1) , CHANDIGARH vs. M/S FIDELITY INFORMATION SERVICES INDIA PVT. LTD., CHANDIGARH

In the result, the cross-objection filed by the assessee is dismissed

ITA 1328/CHANDI/2019[2014-15]Status: DisposedITAT Chandigarh07 Jun 2024AY 2014-15

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

For Appellant: Shri Vishal Kalra, Advocate and Ms. Sumisha, C.AFor Respondent: Shri Rohit Sharma, CIT DR
Section 37(1)

transfer pricing study report prepared for those assessment years and the orders passed in Assessee company’s case in the earlier years. In a nutshell, the Hon'ble Tribunal while passing the order for assessment years 2011-12 and 2012-13 had considered all the relevant documents and after considering the arguments of Revenue and Assessee company had decided

M/S SEL MANUFACTURING CO. LTD.,LUDHIANA vs. DCIT, CC-3, LUDHIANA

In the result, appeal is allowed

ITA 362/CHANDI/2023[2011-12]Status: DisposedITAT Chandigarh27 May 2024AY 2011-12

Bench: SHRI A.D.JAIN (Vice President), SHRI KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Ashwani Kumar, CAFor Respondent: Smt. Kusum Bansal, CIT DR
Section 148Section 250(6)Section 5(20)Section 5(21)Section 69CSection 7

250(6) of the Income Tax Act, 1961 by the learned Commissioner of Income Tax (Appeals) – 5, Ludhiana is against law and facts on the file in as much as the same has been passed ignoring the provisions of the Insolvency and Bankruptcy code, 2016, which overrides the provisions of the other laws for the time being in force

JATIN GARG,CHANDIGARH vs. ASSTT. COMMISSIONER OF INCOME TAX, CC-2,, CHANDIGARH

In the result, the appeal of the assessee is allowed

ITA 1019/CHANDI/2024[2018-19]Status: DisposedITAT Chandigarh12 Feb 2025AY 2018-19

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member), SHRI. PARESH M. JOSHI (Judicial Member)

For Appellant: Shri T.N. Singla, C.AFor Respondent: Shri Rohit Sharma, CIT DR
Section 132(1)Section 139(1)Section 142(1)Section 143(2)Section 69

250(6) of the Act on the directions of ld CIT (A) and in this regard, the following documents were submitted and are placed on record: a) The lender submitted reply u/s 133(6) on 10.05.2022 with the Assessing officer (Copy at P.B. page no.1). b)The copy of our reply in response to remand report of the Assessing officer

DEPUTY COMMISSIONER OF INCOME TAX, CHANDIGARH vs. JAMES HOTELS LTD, CHANDIGARH

ITA 552/CHANDI/2023[2012-13]Status: DisposedITAT Chandigarh01 Oct 2024AY 2012-13

Bench: The Said Resolution To Enhance Authorized Share Capital.

For Appellant: Shri R.K. KapoorFor Respondent: Shri Rohit Sharma, CIT, DR
Section 143(2)Section 269SSection 271D

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

DESH MITTER GAIND,PANCHKULA vs. INCOME TAX OFFICER, WARD-1, PANCHKULA, PANCHKULA, HARYANA

ITA 454/CHANDI/2023[2011-12]Status: DisposedITAT Chandigarh29 Jan 2025AY 2011-12

Bench: This Tribunal. The Assessee Is Aggrieved By The Order Of Cit(A) Bearing No. Itba/Nfac/S/250/2023-

For Appellant: Shri Yogesh Monga, CAFor Respondent: Shri Vivek Vardhan, JCIT-Sr.DR
Section 143(2)Section 148Section 250Section 253Section 48Section 50C

250 of the Act at first appellate stage. The relevant assessment year is 2011-12 and the corresponding previous year period is from 01.04.2010 to 31.03.2011. Factual Matrix Proceedings before ld. AO 2. The information was available with the Income Tax Department that the assessee had sold immovable property for a consideration of Rs.2,42,00,000/- during the Financial

M/S ASHA TECHNOLOGIES,KALA AMB vs. ITO, SIRMOUR

In the result, both the above appeals of the Assessee are partly allowed as aforesaid in respect of impugned orders dt

ITA 61/CHANDI/2013[2009-10]Status: DisposedITAT Chandigarh19 Jul 2024AY 2009-10

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member), SHRI. PARESH M. JOSHI (Judicial Member)

For Appellant: Shri Vishal Mohan, Sr. Advocate with Shri Aditya Sood, AdvocateFor Respondent: Shri Sarabjeet Singh, CIT, DR
Section 142(1)Section 143(2)Section 250Section 253Section 80I

transfer to a new business of machinery or plant previously used for any purpose." The perusal of relevant provisions of Section 80IC reveals that to become eligible for 80IC deduction, an assessee must satisfy the conditions mentioned in sub section (2) & (4), which are, in other words, qualifying provisions for exemption u/s 80IC of the Income Tax Act 1961. Eligibility

M/S ASHA TECHNOLOGIES,SIRMOUR vs. ADDL. CIT, SOLAN

In the result, both the above appeals of the Assessee are partly allowed as aforesaid in respect of impugned orders dt

ITA 388/CHANDI/2012[2007-08]Status: DisposedITAT Chandigarh19 Jul 2024AY 2007-08

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member), SHRI. PARESH M. JOSHI (Judicial Member)

For Appellant: Shri Vishal Mohan, Sr. Advocate with Shri Aditya Sood, AdvocateFor Respondent: Shri Sarabjeet Singh, CIT, DR
Section 142(1)Section 143(2)Section 250Section 253Section 80I

transfer to a new business of machinery or plant previously used for any purpose." The perusal of relevant provisions of Section 80IC reveals that to become eligible for 80IC deduction, an assessee must satisfy the conditions mentioned in sub section (2) & (4), which are, in other words, qualifying provisions for exemption u/s 80IC of the Income Tax Act 1961. Eligibility

CT EDUCATIONAL SOCIETY,JALANDHAR vs. DCIT, CHANDIGARH

In the result, the appeal filed by the Assessee is Partly Allowed for\nStatistical Purposes as per the directions above

ITA 396/CHANDI/2024[2016-17]Status: DisposedITAT Chandigarh10 Dec 2025AY 2016-17
For Appellant: Shri Ashray Sarna, CA(Virtual Mode)For Respondent: Shri Manav Bansal, CIT, DR
Section 11Section 12ASection 13(1)(c)Section 13(2)Section 143(2)Section 143(3)Section 2(15)Section 250

250 of the Income\nTax Act, 1961, for the Assessment Year 2016-17.\n2.\nIn the present appeal Assessee has raised the following grounds:\n1.\nThat the order passed by the Hon'ble CIT(A) dated 19'02'2024 is against\nthe law and facts of the case.\n2.\nThat having regard to the facts and circumstances of the case

SANJAY SINGAL,CHANDIGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CC-1, CHANDIGARH

ITA 655/CHANDI/2023[2015-16]Status: DisposedITAT Chandigarh08 Oct 2024AY 2015-16

Bench: SHRI A.D.JAIN (Vice President), SHRI KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Ashwani Kumar, CAFor Respondent: Smt. Kusum Bansal, CIT, DR
Section 132Section 132(4)Section 250(6)Section 68Section 69ASection 69C

250 after, inter-alia, claiming exemption of Rs.l8,31,36,042 under section 10(38) of the Act in respect of long-term capital gains earned on transfer of shares held in M/s Maa Jagdambe Trade Link Limited, as under: Name of No. of Purchase of shares Sale of shares Long term Share shares Date of Cost Price Date

M/S SANJAY SINGAL HUF,CHANDIGARH vs. DCIT, CC-1, CHANDIGARH

ITA 610/CHANDI/2023[2015-16]Status: DisposedITAT Chandigarh08 Oct 2024AY 2015-16

Bench: SHRI A.D.JAIN (Vice President), SHRI KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Ashwani Kumar, CAFor Respondent: Smt. Kusum Bansal, CIT, DR
Section 132Section 132(4)Section 250(6)Section 68Section 69ASection 69C

250 after, inter-alia, claiming exemption of Rs.l8,31,36,042 under section 10(38) of the Act in respect of long-term capital gains earned on transfer of shares held in M/s Maa Jagdambe Trade Link Limited, as under: Name of No. of Purchase of shares Sale of shares Long term Share shares Date of Cost Price Date

LAKHVIR KAUR,MOHALI vs. DCIT/ACIT(CEN)-2, CHANDIGARH

In the result, both the above appeals of the Assessee are\nallowed

ITA 1165/CHANDI/2024[2021-22]Status: DisposedITAT Chandigarh10 Sept 2025AY 2021-22
For Appellant: \nShri Rohit Kapoor, Advocate &For Respondent: \nShri Manav Bansal, CIT, DR
Section 143(3)Section 250(6)Section 65B

250(6) of the Income Tax\nAct, 1961 is bad in law and against the facts of the case.\n2.\nThat the CIT (A) has erred in confirming addition to the tune of\nRs.400000/- out of total addition of Rs.800000/- made by the AO u/s\n69C on account of unexplained expenditure on foreign travelling.\n2.1 That

LAKHVIR KAUR,MOHALI, CHANDIGARH vs. DCIT/ACIT(CEN)-2 CHD, CHANDIGARH

In the result, both the above appeals of the Assessee are\nallowed

ITA 1164/CHANDI/2024[2020-21]Status: DisposedITAT Chandigarh10 Sept 2025AY 2020-21
For Appellant: \nShri Rohit Kapoor, Advocate &For Respondent: \nShri Manav Bansal, CIT, DR
Section 143(3)Section 250(6)Section 65B

250(6) of the Income Tax\nAct, 1961 is bad in law and against the facts of the case.\n2. That the CIT (A) has erred in confirming addition to the tune of\nRs.400000/- out of total addition of Rs.800000/- made by the AO u/s\n69C on account of unexplained expenditure on foreign travelling.\n2.1 That

AJMER SINGH,MOHALI vs. ITO, W-6(5), MOHAL

In the result, the appeal of the Revenue is dismissed

ITA 1439/CHANDI/2019[2011-12]Status: DisposedITAT Chandigarh03 May 2024AY 2011-12

Bench: Disposal Of Appeal.”

For Appellant: Shri Tej Mohan Singh, AdvocateFor Respondent: Smt. Amanpreet Kaur, Sr. DR
Section 143(2)Section 144Section 148

250 PB Pages 97- Agriculture Land measuring 138 Kanal7 Maria 101 (Eng ver. 156-160) 5 08.09.2010 2,75,000 PB Pages 102- 1/3 share in 1 Kanal 2 Maria land in Village Raipur Kalan (Ancestor land) 105 (Eng ver. 161-163) 6 11.03.2011 Sale of 8 2/3 marla of land 6,20,000 11. It was submitted that after