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

The appeal of the Assessee is Allowed

transfer pricing mechanism. Therefore, on account of these facts and position of law the review order passed by the CIT was held fully justified. 10. The Hon'ble Apex Court in the case of Malabar Industrial Co. Ltd. vs CIT in 243 ITR 83 (SC) has held that a bare reading of section 263 of the Act makes it clear

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

In the result, appeal of the assessee is allowed

set up two electricity power plant of 6 MW each in Dera Bassi (Punjab) for fulfilling its captive needs. The said plants generating both electricity and steam aiding in the manufacturing process. The electricity produced by the said power plants was partly consumed for running the said plants and the remaining was distributed for carrying out the operation

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 SHUBHAM COTTON MILLS PVT. LTD.,ELLENABAD vs. DCIT, CIRCLE, SIRSA

In the result appeal of the assessee is allowed

set off of loss of Rs. 65,46,393/- is eligible under section 70 of the Act against income of Rs. 105,19,500/-, therefore, the income declared by the assessee of Rs. 39,73,107/- in the return of income filed in section 139(1) of the Act may kindly be accepted as such. Should your goodself require

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

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

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

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

Loss Account on account of orders passed by the Service Tax Authorities denying benefit of set off to the said claim. In the backdrop of these undisputed facts, it is clear that the CENVAT Credits represented cost of services availed, which was not claimed in the relevant years since they were eligible to be set off against output service

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

Loss Account on account of orders passed by the Service Tax Authorities denying benefit of set off to the said claim. In the backdrop of these undisputed facts, it is clear that the CENVAT Credits represented cost of services availed, which was not claimed in the relevant years since they were eligible to be set off against output service

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

Loss Account on account of orders passed by the Service Tax Authorities denying benefit of set off to the said claim. In the backdrop of these undisputed facts, it is clear that the CENVAT Credits represented cost of services availed, which was not claimed in the relevant years since they were eligible to be set off against output service

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

Loss Account on account of orders passed by the Service Tax Authorities denying benefit of set off to the said claim. In the backdrop of these undisputed facts, it is clear that the CENVAT Credits represented cost of services availed, which was not claimed in the relevant years since they were eligible to be set off against output service

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

Loss Account on account of orders passed by the Service Tax Authorities denying benefit of set off to the said claim. In the backdrop of these undisputed facts, it is clear that the CENVAT Credits represented cost of services availed, which was not claimed in the relevant years since they were eligible to be set off against output service

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

Loss Account on account of orders passed by the Service Tax Authorities denying benefit of set off to the said claim. In the backdrop of these undisputed facts, it is clear that the CENVAT Credits represented cost of services availed, which was not claimed in the relevant years since they were eligible to be set off against output service

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

Loss Account on account of orders passed by the Service Tax Authorities denying benefit of set off to the said claim. In the backdrop of these undisputed facts, it is clear that the CENVAT Credits represented cost of services availed, which was not claimed in the relevant years since they were eligible to be set off against output service

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

Loss Account on account of orders passed by the Service Tax Authorities denying benefit of set off to the said claim. In the backdrop of these undisputed facts, it is clear that the CENVAT Credits represented cost of services availed, which was not claimed in the relevant years since they were eligible to be set off against output service

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

Loss Account on account of orders passed by the Service Tax Authorities denying benefit of set off to the said claim. In the backdrop of these undisputed facts, it is clear that the CENVAT Credits represented cost of services availed, which was not claimed in the relevant years since they were eligible to be set off against output service