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

6(ii) The Assessing Officer further observed that as per provisions of Section 54 of Transfer of Property Act, it is clear that when price

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

6(ii) The Assessing Officer further observed that as per provisions of Section 54 of Transfer of Property Act, it is clear that when price

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

M/S JSK INTERNATIONAL,BADDI vs. PR. CIT, SHIMLA

The appeal of the Assessee is Allowed

6) That the Learned Principal CIT has grossly erred in invoking provisions of section 263 of the Act ignoring the fact that a specific query had been raised by the Assessing Officer during the course of assessment proceedings vide notice dated 06.01.2016 order sheet entry dated 29.02.2016 and in response to which a copy of the transfer pricing

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)

6 12. The assessee in written submissions has contended that once she is accepted as a non-resident, she automatically falls in the definition of “eligible assessee” u/s 144C(15)(b). It was argued that Section 144C uses two independent limbs – one for transfer-pricing

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

In the result, all appeals of the assessee are allowed

Transfer Pricing Officer made a variation to the Arm's Length\nPrice and valued the transaction at Rs.517.82 per share. In other words, he\nrecommended a variation in the Arm's Length Price. In these circumstances, the\nPetitioner would certainly be an eligible Assessee as contemplated under Section\n144C(15)(b) (i) of the IT Act. Since this variation

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

In the result, all appeals of the assessee are allowed

Transfer Pricing Officer made a variation to the Arm's Length\nPrice and valued the transaction at Rs.517.82 per share. In other words, he\nrecommended a variation in the Arm's Length Price. In these circumstances, the\nPetitioner would certainly be an eligible Assessee as contemplated under Section\n144C(15)(b) (i) of the IT Act. Since this variation

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

In the result, all appeals of the assessee are allowed

Transfer Pricing Officer made a variation to the Arm's Length\nPrice and valued the transaction at Rs.517.82 per share. In other words, he\nrecommended a variation in the Arm's Length Price. In these circumstances, the\nPetitioner would certainly be an eligible Assessee as contemplated under Section\n144C(15)(b) (i) of the IT Act. Since this variation

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

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

Transfer Pricing Officer" shall have the same meaning as assigned to it in the Explanation to section 92CA.] (2) No order shall be made under sub-section (1) after the expiry of two years from the end of the financial year in which the order sought to be revised was passed. (3) Notwithstanding anything contained in sub-section

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

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

Transfer Pricing Officer" shall have the same meaning as assigned to it in the Explanation to section 92CA.] (2) No order shall be made under sub-section (1) after the expiry of two years from the end of the financial year in which the order sought to be revised was passed. (3) Notwithstanding anything contained in sub-section

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

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

Transfer Pricing Officer" shall have the same meaning as assigned to it in the Explanation to section 92CA.] (2) No order shall be made under sub-section (1) after the expiry of two years from the end of the financial year in which the order sought to be revised was passed. (3) Notwithstanding anything contained in sub-section

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

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

Transfer Pricing Officer" shall have the same meaning as assigned to it in the Explanation to section 92CA.] (2) No order shall be made under sub-section (1) after the expiry of two years from the end of the financial year in which the order sought to be revised was passed. (3) Notwithstanding anything contained in sub-section

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

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

Transfer Pricing Officer" shall have the same meaning as assigned to it in the Explanation to section 92CA.] (2) No order shall be made under sub-section (1) after the expiry of two years from the end of the financial year in which the order sought to be revised was passed. (3) Notwithstanding anything contained in sub-section

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

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

Transfer Pricing Officer" shall have the same meaning as assigned to it in the Explanation to section 92CA.] (2) No order shall be made under sub-section (1) after the expiry of two years from the end of the financial year in which the order sought to be revised was passed. (3) Notwithstanding anything contained in sub-section

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

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

Transfer Pricing Officer" shall have the same meaning as assigned to it in the Explanation to section 92CA.] (2) No order shall be made under sub-section (1) after the expiry of two years from the end of the financial year in which the order sought to be revised was passed. (3) Notwithstanding anything contained in sub-section

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

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

Transfer Pricing Officer" shall have the same meaning as assigned to it in the Explanation to section 92CA.] (2) No order shall be made under sub-section (1) after the expiry of two years from the end of the financial year in which the order sought to be revised was passed. (3) Notwithstanding anything contained in sub-section

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

The appeals of the assessees stand allowed

Bench: Shri Sudhanshu Srivastava & Shri Vikram Singh Yadav

Transfer Pricing Officer" shall have the same meaning as assigned to it in the Explanation to section 92CA.] (2) No order shall be made under sub-section (1) after the expiry of two years from the end of the financial year in which the order sought to be revised was passed. (3) Notwithstanding anything contained in sub-section