PAREXEL INTERNATIONAL SERVICES INDIA PVT.LTD,,CHANDIGARH vs. ACIT,CIRCLE-5(1),(NEAC), CHANDIGARH

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

Bench: SHRI. AAKASH DEEP JAIN (Vice President), SHRI. SHRI. KRINWANT SAHAY (Accountant Member)

set of 20 companies engaged in IT enabled services were considered by the TPO, holding them to be comparable to the assessee. To arrive at the arm’s length price, the net margin, i.e., the Operating Profit / Operating Cost (OP/OC) of these 20 companies, as earned during the regular course of their business, was considered

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)

loss was resulted to the revenue, no penalty ids.271AA is warranted on it. The penalty levied b y the Ld. Assessing Officer deserved to be deleted.” 3.1 The submissions so filed were considered but not found acceptable to the Ld. CIT(A) and levy of penalty under section 271AA was upheld. As per the Ld. CIT(A), the assessee company

PUNJAB CHEMICALS & CROP PROTECTION LTD.,MOHALI vs. THE ADDITIONAL COMMISSIONER OF INCOME TAX, RANGE 1, CHANDIGARH

The appeal stands partly allowed

Bench: Hon’Ble Shri Laliet Kumar, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपीलसं./ Ita No. 316/Chandi/2022 (िनधा"रणवष" / Assessment Year: 2017-18) Punjab Chemicals & Crop Protection Ltd. Addl. Cit बनाम/ Milestone-18, Ambala-Kalka Road, Range-1 Vpo Bhankharpur, Derabassi Chandigarh Vs. District Sas Nagar Mohali-140201 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaacp-9904-H (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Sh. Anil Khanna (Ca). – Ld. Ar ""थ"कीओरसे/Respondent By : Ms. Tarundeep Kaur (Cit) – Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 24-06-2025 घोषणाकीतारीख /Date Of Pronouncement : 01-07-2025 आदेश / O R D E R

Transfer Pricing (TP) adjustment on Corporate Guarantee; (iv) Set-off of brought forward losses. These grounds are adjudicated as under

SAHIBZADA TIMBER AND PLY PRIVATE LIMITED ,MOHALI vs. DCIT, ACIT CENTRAL CIRCLE-2, CHANDIGARH, CHANDIGARH

In the result, the appeal of the assessee is dismissed

Bench: SHRI. VIKRAM SINGH YADAV, AM आयकर अपील सं./ ITA No. 699/Chd/2024 निर्धारण वर्ष / Assessment Year : 2019-20 M/s Sahibzada Timber & Ply Private Limited B41-42, Phase-3, Indl. Aera, SAS Nagar Mohali, Punjab बनाम The DCIT Central Circle-2 Chandigarh स्थायी लेखा सं./PAN NO: AAQCS2239G अपीलार्थी/Appellant प्रत्यर्थी/Respondent निर्धारिती की ओर से/Assessee by : Shri Mohit Dhiman, C.A राजस्व की ओर से/ Revenue by : Dr. Ranjeet Kaur, Sr. DR Shri Dharam Vir, Addl. CIT, Sr.DR सुनवाई की तारीख/Date of He

setting off the same with future capital gains. In view of the above facts and discussion, it was held by the ld CIT(A) that disallowance of capital loss of Rs. 25,75,000/- made by the AO was justified and the appeal of the assessee was dismissed. 6. Against the said findings and directions

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 covers this receipt. Since, the basic premise of the assessee that the said expenses are laid out and subsequently reimbursed on the basis of the 'Master Services Agreement' is found to be false, the claim of the assessee of the expenditure on foreign travel also becomes void. v) It needs to be reiterated that foreign travel expense claimed

JANTA LAND PROMOTERS PVT LTD,MOHALI vs. THE PRINICIPAL COMMISSIONER OF INCOME TAX ,CHANDIGARH-1, CHANDIGARH

In the result, appeal of the Assessee is allowed

transfer pricing adjustment, it is not permissible to generalise the matter and hold that there was lack of enquiry on the part of the Assessing Officer rendering the assessment order prejudicial to the interests of the Revenue. In our considered view, the learned PCIT is required to specifically identify the transaction which, in his opinion, falls within the scope

MAXPORT INDIA PRIVATE LIMITED,CHANDIGARH vs. DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1,CHANDIGARH, CHANDIGARH

price fluctuations. The reliance in\nthis respect can be placed on the following decisions:\n“(i) [Assistant Commissioner of Income Tax, Central Circle-1(3), Kolkata v. Narula\nEducational Trust [2021] 126 taxmann.com 158 (Kolkata - Trib.)\n(ii) Champaklal S. Kasat v. Deputy Commissioner of Income-tax, Cent. Cir. 1(3),\nAhmedabad [2017] 82 taxmann.com 243 (Ahmedabad - Trib

SCOTT EDIL ADVANCE RESEARCH LABORATORIES AND EDUCATION LIMITED,CHANDIGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, CHANDIGARH

price fluctuations. The reliance in\nthis respect can be placed on the following decisions:\n“(i) [Assistant Commissioner of Income Tax, Central Circle-1(3), Kolkata v. Narula\nEducational Trust [2021] 126 taxmann.com 158 (Kolkata - Trib.)\n(ii) Champaklal S. Kasat v. Deputy Commissioner of Income-tax, Cent. Cir. 1(3),\nAhmedabad [2017] 82 taxmann.com 243 (Ahmedabad - Trib

SMT. TEENA GARG,CHANDIGARH vs. PCIT, PANCHKULA

In the result, appeal of the assessee is allowed

loss on interest rate swap\nand same was replied by assessee, it was not a case where no\nenquiry whatsoever had been conducted by Assessing Officer with\nrespect to claims under consideration and, thus, revision order\npassed under section263 was not sustainable\"\n\nReliance was also placed on judgement of ITAT Chandigarh in case\nof Pawan Kumar Vs. ITO reported

SH. BALJIT SINGH,LUDHIANA vs. PR. CIT, LUDHIANA -1, LUDHIANA

In the result, appeal of the Assessee is dismissed

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

Transfer Pricing Officer, as the case may be) is erroneous in so far as it is prejudicial to the interest of the revenue, he may, after giving the assesse an opportunity of being heard and after making or causing to be made such inquiry as he deems necessary, pass such order thereon as the circumstances of the case justify, including

ITO, W-6(5), MOHALI vs. SMT. GURDEV KAUR, KHARAR

In the result, the appeal of the Revenue is dismissed

Bench: Disposal Of Appeal.”

price of land of Rs. 2,30,00,000/- and taking the sale consideration of land at Rs. 62,70,000/- + 10,45,000/-). In fact this cash was available with the assessee only out of the sale proceeds of 54 Bigha 13 Biswa & 4 Biswasi and another piece of land of land for Rs.2

AJMER SINGH,MOHALI vs. ITO, W-6(5), MOHAL

In the result, the appeal of the Revenue is dismissed

Bench: Disposal Of Appeal.”

price of land of Rs. 2,30,00,000/- and taking the sale consideration of land at Rs. 62,70,000/- + 10,45,000/-). In fact this cash was available with the assessee only out of the sale proceeds of 54 Bigha 13 Biswa & 4 Biswasi and another piece of land of land for Rs.2

AJMER SINGH,MOHALI vs. ITO, W-6(5), MOHAL

In the result, the appeal of the Revenue is dismissed

Bench: Disposal Of Appeal.”

price of land of Rs. 2,30,00,000/- and taking the sale consideration of land at Rs. 62,70,000/- + 10,45,000/-). In fact this cash was available with the assessee only out of the sale proceeds of 54 Bigha 13 Biswa & 4 Biswasi and another piece of land of land for Rs.2

AUTHORGEN TECHNOLOGIES PVT. LTD.,MOHALI vs. ITO, WARD 6(1), CHANDIGARH

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

setting aside the order of the AO and directing assessment de-novo, on the grounds that Large share premium received during the year, without appreciating the fact that two out of three investors are foreign investors and such shares are issued above the fair value as required under foreign exchange laws of the country. The Ld. AO has asked

M/S AUTHORGEN TECHNOLOGIES PVT.LTD,MOHALI vs. PR.CIT-1, CHANDIGARH

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

setting aside the order of the AO and directing assessment de-novo, on the grounds that Large share premium received during the year, without appreciating the fact that two out of three investors are foreign investors and such shares are issued above the fair value as required under foreign exchange laws of the country. The Ld. AO has asked

SHRI HARI & CO OWNERS,KAITHAL vs. PR. CIT, CHANDIGARH -1, ROHTAK

In the result, both the above appeals of the Assessee are dismissed

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

Transfer Pricing Officer, as the case may be) is erroneous in so far as it is prejudicial to the interest of the revenue, he may, after giving the assesse an opportunity of being heard and after making or causing to be made such inquiry as he deems necessary, pass such order thereon as the circumstances of the case justify, including

SHRI HARI & CO OWNERS,KAITHAL vs. PR. CIT, CHANDIGARH -1, ROHTAK

In the result, both the above appeals of the Assessee are dismissed

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

Transfer Pricing Officer, as the case may be) is erroneous in so far as it is prejudicial to the interest of the revenue, he may, after giving the assesse an opportunity of being heard and after making or causing to be made such inquiry as he deems necessary, pass such order thereon as the circumstances of the case justify, including

M/S SEL MANUFACTURING CO. LTD.,LUDHIANA vs. DCIT, CC-3, LUDHIANA

In the result, appeal is allowed

Bench: SHRI A.D.JAIN (Vice President), SHRI KRINWANT SAHAY (Accountant Member)

transfer pricing, TDS matter, excise assessment, VAT assessment and also with regard to notices issued by the relevant Government Authority for relevant assessment years under various provisions of the Applicable Law including Income Tax Act or indirect tax laws, the relevant Government A.Y. 2011-12 14 Authorities make any further assessment with respect to resolution of losses or unabsorbed depreciation