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

253 contemplates that the Tribunal may admit an appeal or permit filing of memorandum of cross- objections after expiry of relevant period, if it is satisfied that there was a sufficient cause for not presenting it within that period. This expression sufficient cause employed in the section has also been used identically in sub-section 3 of section

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

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

253 of the Income Tax Act, 1961 (hereinafter referred to as Act) as and by way of second appeal before this Tribunal. The assessee is aggrieved by the order OF CIT(A) bearing No. ITBA/NFAC/S/250/2023- 24/1053342436(1) dated 31.05.2023 which is ITA 454/CHD/2023 A.Y. 2011-12 2 hereinafter referred to as the “Impugned Order” which is passed under Section

SH. DINESH SOIN,LUDHIANA vs. ACIT, LUDHIANA

The appeals are partly allowed

253 contemplates that the\nTribunal may admit an appeal or permit filing of\nmemorandum of cross- objections after expiry of relevant\nperiod, if it is satisfied that there was a sufficient cause for\nnot presenting it within that period. This expression\nsufficient cause employed in the section has also been used\nidentically in sub-section 3 of section

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

The appeals are partly allowed

253 contemplates that the\nTribunal may admit an appeal or permit filing of\nmemorandum of cross- objections after expiry of relevant\nperiod, if it is satisfied that there was a sufficient cause for\nnot presenting it within that period. This expression\nsufficient cause employed in the section has also been used\nidentically in sub-section 3 of section

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

The appeals are partly allowed

253 contemplates that the\nTribunal may admit an appeal or permit filing of\nmemorandum of cross- objections after expiry of relevant\nperiod, if it is satisfied that there was a sufficient cause for\nnot presenting it within that period. This expression\nsufficient cause employed in the section has also been used\nidentically in sub-section 3 of section

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2,, LUDHIANA vs. AB ALCOBEV PRIVATE LIMITED, DELHI

In the result, appeals of Revenue are dismissed, Cross\nObjections of the assessee for

253 contemplates that the\nTribunal may admit an appeal or permit filing of memorandum\nof cross- objections after expiry of relevant period, if it is\nsatisfied that there was a sufficient cause for not presenting\nit within that period. This expression sufficient cause\nemployed in the section has also been used identically in sub-\nsection 3 of section

DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2, LUDHIANA , LUDHIANA vs. AB ALCOBEV PRIVATE LIMITED, DELHI

In the result, appeals of Revenue are dismissed, Cross\nObjections of the assessee for

253 contemplates that the\nTribunal may admit an appeal or permit filing of memorandum\nof cross- objections after expiry of relevant period, if it is\nsatisfied that there was a sufficient cause for not presenting\nit within that period. This expression sufficient cause\nemployed in the section has also been used identically in sub-\nsection 3 of section

DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2, LUDHIANA vs. AB ALCOBEV PRIVATE LIMITED, DELHI

In the result, appeals of Revenue are dismissed, Cross\nObjections of the assessee for

253 contemplates that the\nTribunal may admit an appeal or permit filing of memorandum\nof cross- objections after expiry of relevant period, if it is\nsatisfied that there was a sufficient cause for not presenting\nit within that period. This expression sufficient cause\nemployed in the section has also been used identically in sub-\nsection 3 of section

DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2 LUDHIANA, LUDHIANA vs. AB ALCOBEV PRIVATE LIMITED , DELHI

In the result, appeals of Revenue are dismissed, Cross\nObjections of the assessee for

253 contemplates that the\nTribunal may admit an appeal or permit filing of memorandum\nof cross- objections after expiry of relevant period, if it is\nsatisfied that there was a sufficient cause for not presenting\nit within that period. This expression sufficient cause\nemployed in the section has also been used identically in sub-\nsection 3 of section

M/S DSM SINOCHEM PHARMACEUTICALS INDIA PVT. LTD. ,TOANSA vs. DCIT, C-1(1), CHANDIGARH

In the result, appeal of the assessee is partly allowed

Bench: Shri N.K. Saini, Vice- & Shri Vikas Awasthyआअसं. 253/ चंडीगढ़/2016(िन.व. 2011-12)

Transfer Pricing Adjustment of Rs.8,05,24,450/- in respect of corporate services fees. The TPO applied CUP as the most appropriate method and determined ALP of the transaction as Nil. The TPO has further observed that no independent party would have made a similar 4 आअसं.253/ चंडीगढ़/2016(िन.व.2011-12) आअसं.1592/ चंडीगढ़/2018

DSM SINOCHEM PHARMACEUTICALS INDIA PRIVATE LIMITED,NAWANSHAHR vs. DCIT, CHANDIGARH

In the result, appeal of the assessee is partly allowed

Bench: Shri N.K. Saini, Vice- & Shri Vikas Awasthyआअसं. 253/ चंडीगढ़/2016(िन.व. 2011-12)

Transfer Pricing Adjustment of Rs.8,05,24,450/- in respect of corporate services fees. The TPO applied CUP as the most appropriate method and determined ALP of the transaction as Nil. The TPO has further observed that no independent party would have made a similar 4 आअसं.253/ चंडीगढ़/2016(िन.व.2011-12) आअसं.1592/ चंडीगढ़/2018

GLAXOSMITHKLINE ASIA PVT. LTD.,GURGAON vs. ACIT, CHANDIGARH

In the result, all the appeals of the assessee and the Revenue, stand partly allowed for statistical purposes

253 of the Act grants right of appeal to the assessee, aggrieved by any of the orders specified therein , to the ITAT. As per Section 254 of the Act, the ITAT may after giving both the parties to the appeal an opportunity of being heard, pass such orders thereon as it deems fit. Rule 11 of the ITAT Rules

M/S GLAXO SMITHKLINE ASIA PVT. LTD.,NABHA vs. DCIT, C-4(1), CHANDIGARH

In the result, all the appeals of the assessee and the Revenue, stand partly allowed for statistical purposes

253 of the Act grants right of appeal to the assessee, aggrieved by any of the orders specified therein , to the ITAT. As per Section 254 of the Act, the ITAT may after giving both the parties to the appeal an opportunity of being heard, pass such orders thereon as it deems fit. Rule 11 of the ITAT Rules

M/S GLAXOSMITHKLINE ASIA PVT. LTD.,GURGAON vs. ACIT, CHANDIGARH

In the result, all the appeals of the assessee and the Revenue, stand partly allowed for statistical purposes

253 of the Act grants right of appeal to the assessee, aggrieved by any of the orders specified therein , to the ITAT. As per Section 254 of the Act, the ITAT may after giving both the parties to the appeal an opportunity of being heard, pass such orders thereon as it deems fit. Rule 11 of the ITAT Rules

ACIT, CHANDIGARH vs. M/S GLAXO SMITHKLINE ASIA PVT. LTD., GURGAON

In the result, all the appeals of the assessee and the Revenue, stand partly allowed for statistical purposes

253 of the Act grants right of appeal to the assessee, aggrieved by any of the orders specified therein , to the ITAT. As per Section 254 of the Act, the ITAT may after giving both the parties to the appeal an opportunity of being heard, pass such orders thereon as it deems fit. Rule 11 of the ITAT Rules

GLAXOSMITHKLINE ASIA PVT. LTD.,GURGAON vs. ACIT, CHANDIGARH

In the result, all the appeals of the assessee and the Revenue, stand partly allowed for statistical purposes

253 of the Act grants right of appeal to the assessee, aggrieved by any of the orders specified therein , to the ITAT. As per Section 254 of the Act, the ITAT may after giving both the parties to the appeal an opportunity of being heard, pass such orders thereon as it deems fit. Rule 11 of the ITAT Rules

ACIT, CHANDIGARH vs. M/S GLAXO SMITHKLINE ASIA PVT. LTD., GURGAON

In the result, all the appeals of the assessee and the Revenue, stand partly allowed for statistical purposes

253 of the Act grants right of appeal to the assessee, aggrieved by any of the orders specified therein , to the ITAT. As per Section 254 of the Act, the ITAT may after giving both the parties to the appeal an opportunity of being heard, pass such orders thereon as it deems fit. Rule 11 of the ITAT Rules

GLAXOSMITHKLINE ASIA PVT. LTD.,GURGAON vs. DCIT, CHANDIGARH

In the result, all the appeals of the assessee and the Revenue, stand partly allowed for statistical purposes

253 of the Act grants right of appeal to the assessee, aggrieved by any of the orders specified therein , to the ITAT. As per Section 254 of the Act, the ITAT may after giving both the parties to the appeal an opportunity of being heard, pass such orders thereon as it deems fit. Rule 11 of the ITAT Rules