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

92,01,875/- will take effect at two different points of time when two different amounts for Rs. 17,45,65/- and Rs. 1,74,55,250/- were en-cashed, were not in consonance with the existing law. The assessee himself offered for tax an amount of Rs. 17,45,65/- ( cash and cheque) and for balance amount

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

92,01,875/- will take effect at two different points of time when two different amounts for Rs. 17,45,65/- and Rs. 1,74,55,250/- were en-cashed, were not in consonance with the existing law. The assessee himself offered for tax an amount of Rs. 17,45,65/- ( cash and cheque) and for balance 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.”

section 92CA(1) to Transfer Pricing Officer to determine the Arm's Length Prices in respect of the above specified domestic transactions of Rs. 8,92

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

The appeal of the Assessee is Allowed

section 92 to 92F of the I.T. Act, any income arising from an international transaction or specified domestic transactions between two or more associated enterprises is to be computed having regard to the arms-length price. Instruction No. 3 was issued on 20.05.2003 to provide guidance to the TPO and the AO to operationalise_the insfer pricing provisions

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

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

section 144A; (ii) an order made by the Joint Commissioner in exercise of the powers or in the performance of the functions of an Assessing Officer 92[or the Transfer Pricing

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

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

section 144A; (ii) an order made by the Joint Commissioner in exercise of the powers or in the performance of the functions of an Assessing Officer 92[or the Transfer Pricing

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

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

section 144A; (ii) an order made by the Joint Commissioner in exercise of the powers or in the performance of the functions of an Assessing Officer 92[or the Transfer Pricing

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

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

section 144A; (ii) an order made by the Joint Commissioner in exercise of the powers or in the performance of the functions of an Assessing Officer 92[or the Transfer Pricing

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

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

section 144A; (ii) an order made by the Joint Commissioner in exercise of the powers or in the performance of the functions of an Assessing Officer 92[or the Transfer Pricing

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

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

section 144A; (ii) an order made by the Joint Commissioner in exercise of the powers or in the performance of the functions of an Assessing Officer 92[or the Transfer Pricing

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

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

section 144A; (ii) an order made by the Joint Commissioner in exercise of the powers or in the performance of the functions of an Assessing Officer 92[or the Transfer Pricing

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

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

section 144A; (ii) an order made by the Joint Commissioner in exercise of the powers or in the performance of the functions of an Assessing Officer 92[or the Transfer Pricing

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

The appeals of the assessees stand allowed

Bench: Shri Sudhanshu Srivastava & Shri Vikram Singh Yadav

section 144A; (ii) an order made by the Joint Commissioner in exercise of the powers or in the performance of the Officer 92[or functions of an Assessing the Transfer Pricing

M/S MAA BHAGWATI ENTERPRISES,SANGRUR vs. PCIT, PATIALA

The appeals of the assessees stand allowed

Bench: Shri Sudhanshu Srivastava & Shri Vikram Singh Yadav

section 144A; (ii) an order made by the Joint Commissioner in exercise of the powers or in the performance of the Officer 92[or functions of an Assessing the Transfer Pricing

M/S OMKAR ENGINEER AND CONTRACTOR,SANGRUR vs. PCTI, PATIALA

The appeals of the assessees stand allowed

Bench: Shri Sudhanshu Srivastava & Shri Vikram Singh Yadav

section 144A; (ii) an order made by the Joint Commissioner in exercise of the powers or in the performance of the Officer 92[or functions of an Assessing the Transfer Pricing

M/S OM CONTRACTOR AND ENGINEERS,SANGRUR vs. PCIT, PATIALA

The appeals of the assessees stand allowed

Bench: Shri Sudhanshu Srivastava & Shri Vikram Singh Yadav

section 144A; (ii) an order made by the Joint Commissioner in exercise of the powers or in the performance of the Officer 92[or functions of an Assessing the Transfer Pricing

M/S YAMUNA POWER & INFRASTRUCTURE LTD.,JAGADHRI vs. DCIT, CIRCLE, YAMUNANAGAR

In the result, the appeal of the assessee is allowed

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

Section-92D are applicable only on such transactions, as are above the specified amount for such transactions individually (the quantum of specified amount o f transaction(s) was Rs. 500.00 Lakh during the year under review). The above contention of the appellant finds support from the fact that such professional(s)/Auditors in the report u/s.92E (in form No.3CEBi

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