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.”

40,29,540/- as Investment in equity shares, Rs. 2,32,00,000/- as Salary paid & Rs. 1,19,94,666/- as Dividend paid) with its associated enterprises during the year under consideration. Subsequently, the AO made a reference under section 92CA(1) to Transfer Pricing

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

In the result, appeal of the assessee is allowed

40,12,290 claimed by the assessee u/s 80-IA for transfer of steam. 4. That the Ld. AO/TPO erred on facts and in law in initiating penalty proceedings u/s 271(l)(c) of the Income Tax Act 1961 despite the fact that complete information was disclosed and nothing was concealed. 5. The assessee craves leave to alter, amend

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

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

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

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

40 of the paper book). The Ld. AR submitted that no details or vouchers for expenses were maintained / provided for the reason that the return had been filed u/s 44AD of the Act and in that terms of this provision, the assessee was not required to maintain any books of account or bills / vouchers etc. as the income declared under

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

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

40 of the paper book). The Ld. AR submitted that no details or vouchers for expenses were maintained / provided for the reason that the return had been filed u/s 44AD of the Act and in that terms of this provision, the assessee was not required to maintain any books of account or bills / vouchers etc. as the income declared under

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

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

40 of the paper book). The Ld. AR submitted that no details or vouchers for expenses were maintained / provided for the reason that the return had been filed u/s 44AD of the Act and in that terms of this provision, the assessee was not required to maintain any books of account or bills / vouchers etc. as the income declared under

M/S CHENAB CONSTRUCTION,SANGRUR vs. PCIT, PATIALA

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

40 of the paper book). The Ld. AR submitted that no details or vouchers for expenses were maintained / provided for the reason that the return had been filed u/s 44AD of the Act and in that terms of this provision, the assessee was not required to maintain any books of account or bills / vouchers etc. as the income declared under

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

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

40 of the paper book). The Ld. AR submitted that no details or vouchers for expenses were maintained / provided for the reason that the return had been filed u/s 44AD of the Act and in that terms of this provision, the assessee was not required to maintain any books of account or bills / vouchers etc. as the income declared under

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

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

40 of the paper book). The Ld. AR submitted that no details or vouchers for expenses were maintained / provided for the reason that the return had been filed u/s 44AD of the Act and in that terms of this provision, the assessee was not required to maintain any books of account or bills / vouchers etc. as the income declared under

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

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

40 of the paper book). The Ld. AR submitted that no details or vouchers for expenses were maintained / provided for the reason that the return had been filed u/s 44AD of the Act and in that terms of this provision, the assessee was not required to maintain any books of account or bills / vouchers etc. as the income declared under

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

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

40 of the paper book). The Ld. AR submitted that no details or vouchers for expenses were maintained / provided for the reason that the return had been filed u/s 44AD of the Act and in that terms of this provision, the assessee was not required to maintain any books of account or bills / vouchers etc. as the income declared under

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

In the result, the appeal of the assessee is partly allowed

transfer pricing exercise for the purpose of Arm's Length Price determination. Yet, the fact remains that the overseas owner did not set up any other licensee, at least in the area where the assessee operated, to operate as a rival. Under the Trade Mark Act, especially Section 48, as long as [he arrangement existed, the assessee

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

section 40(a)(ii) of the Act. There is no scope for any other interpretation/ view on the issue considering the decision of the apex court in K. Srinivasan (supra) read with the Finance Bill levying education cess. ITA Nos.219 to 222,225 to 227,242, 228, 344/Chd/2017 ITA No.1495/Chd/2019 A.Ys. 2007-08 to 2015-16 Page

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

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

section 40(a)(ii) of the Act. There is no scope for any other interpretation/ view on the issue considering the decision of the apex court in K. Srinivasan (supra) read with the Finance Bill levying education cess. ITA Nos.219 to 222,225 to 227,242, 228, 344/Chd/2017 ITA No.1495/Chd/2019 A.Ys. 2007-08 to 2015-16 Page

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

section 40(a)(ii) of the Act. There is no scope for any other interpretation/ view on the issue considering the decision of the apex court in K. Srinivasan (supra) read with the Finance Bill levying education cess. ITA Nos.219 to 222,225 to 227,242, 228, 344/Chd/2017 ITA No.1495/Chd/2019 A.Ys. 2007-08 to 2015-16 Page

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

section 40(a)(ii) of the Act. There is no scope for any other interpretation/ view on the issue considering the decision of the apex court in K. Srinivasan (supra) read with the Finance Bill levying education cess. ITA Nos.219 to 222,225 to 227,242, 228, 344/Chd/2017 ITA No.1495/Chd/2019 A.Ys. 2007-08 to 2015-16 Page

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

section 40(a)(ii) of the Act. There is no scope for any other interpretation/ view on the issue considering the decision of the apex court in K. Srinivasan (supra) read with the Finance Bill levying education cess. ITA Nos.219 to 222,225 to 227,242, 228, 344/Chd/2017 ITA No.1495/Chd/2019 A.Ys. 2007-08 to 2015-16 Page