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.”

Transfer Pricing Officer the aggregate value of specified domestic transactions has been taken from the Form 3CEB filed by the appellant. Perusal of Form 3CEB, prescribed under Rule 10E, states as "Report from an accountant to be furnished under section 92E relating to International Transaction(s) and Specified domestic transaction(s). The particulars of the above transaction(s) required

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

In the result, appeal of the assessee is allowed

section 92C of the Act to the TPO for determining the arms length price in respect of specific domestic transaction undertaken by the assessee. The TPO after examining the transfer pricing adjustment and analyzing the specific domestic transaction with associated enterprises, proceeded to bench mark the power from eligible unit to non eligible unit specifically supply of electricity and steam

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

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

In the result, all appeals of the assessee are allowed

price considered as Nil by Petitioner and to that extent the said\nadjustment was evidently prejudicial to the interest of the Petitioner. Depriving\nPetitioner of this valuable right to raise objection before Dispute Resolution Panel\nwould be denial of substantive rights to the assessee, for which, in our view, the\nAssessing Officer has no power under the statute

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

In the result, all appeals of the assessee are allowed

price considered as Nil by Petitioner and to that extent the said\nadjustment was evidently prejudicial to the interest of the Petitioner. Depriving\nPetitioner of this valuable right to raise objection before Dispute Resolution Panel\nwould be denial of substantive rights to the assessee, for which, in our view, the\nAssessing Officer has no power under the statute

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

In the result, all appeals of the assessee are allowed

price considered as Nil by Petitioner and to that extent the said\nadjustment was evidently prejudicial to the interest of the Petitioner. Depriving\nPetitioner of this valuable right to raise objection before Dispute Resolution Panel\nwould be denial of substantive rights to the assessee, for which, in our view, the\nAssessing Officer has no power under the statute

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

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

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

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

section 57.\nThe said provision reads thus:\n\"57. Deductions.-The income chargeable under the head 'Income from other\nsources' shall be computed after making the following deductions, namely :.\n(iv) in the case of income of the nature referred to in clause (viii) of sub-\nsection (2) of section 56, a deduction of a sum equal to fifty

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

transfer pricing adjustment to be made as per 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 45 of 120 provisions of the Act, but at the same time directed that for treating the same as international transaction delay beyond 60 days is to be considered and the interest rate

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

transfer pricing adjustment to be made as per 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 45 of 120 provisions of the Act, but at the same time directed that for treating the same as international transaction delay beyond 60 days is to be considered and the interest rate

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

transfer pricing adjustment to be made as per 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 45 of 120 provisions of the Act, but at the same time directed that for treating the same as international transaction delay beyond 60 days is to be considered and the interest rate

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

transfer pricing adjustment to be made as per 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 45 of 120 provisions of the Act, but at the same time directed that for treating the same as international transaction delay beyond 60 days is to be considered and the interest rate

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

transfer pricing adjustment to be made as per 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 45 of 120 provisions of the Act, but at the same time directed that for treating the same as international transaction delay beyond 60 days is to be considered and the interest rate

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

transfer pricing adjustment to be made as per 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 45 of 120 provisions of the Act, but at the same time directed that for treating the same as international transaction delay beyond 60 days is to be considered and the interest rate

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

transfer pricing adjustment to be made as per 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 45 of 120 provisions of the Act, but at the same time directed that for treating the same as international transaction delay beyond 60 days is to be considered and the interest rate

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

transfer pricing adjustment to be made as per 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 45 of 120 provisions of the Act, but at the same time directed that for treating the same as international transaction delay beyond 60 days is to be considered and the interest rate