BG EXPLORATION & PRODUCTION INDIA LIMITED,MUMBAI vs. THE DEPUTY COMMISSIONER OF INCOME TAX, DDIT/ADIT (INTERNATIONAL TAXATION), CIRCLE -1, DEHRADUN

In the result, the appeal filed by the assessee is partly allowed for statistical purposes

transfer pricing documentation by applying the Transactional Net Margin Method (‘TNMM’). Since the profit margin of the assessee at 33.95% was higher than the median margin of 10.16% earned by the comparable companies, the transaction was considered to be at arm’s length. The TPO, however, relying upon the orders for the earlier years, rejected the TNMM method applied

KARAM SAFETY PRIVATE LIMITED,SITARGANJ vs. THE INCOME TAX OFFICER, WARD-2(3)(5), UDHAM SINGH NAGAR

In the result, both the appeals of the assessee are allowed and that of the Stay Applications are dismissed

Bench: Sh. Saktijit Deydr. B. R. R. Kumar

Transfer Pricing Officer 3(2)(2) (“TPO”) for determination of arm’s length price of the specified domestic transactions (“SDT”) / international transactions undertaken by the Applicant. 9. The TPO vide order dated 30 January 2019 held that the applicant has earned more than ordinary profits from its Section 80-IC business and proposed an adjustment of Rs.5

KARAM SAFETY PRIVATE LIMITED,UDHAM SINGH NAGAR vs. THE INCOME TAX OFFICER, WARD-2(3)(5), UDHAM SINGH NAGAR

In the result, both the appeals of the assessee are allowed and that of the Stay Applications are dismissed

Bench: Sh. Saktijit Deydr. B. R. R. Kumar

Transfer Pricing Officer 3(2)(2) (“TPO”) for determination of arm’s length price of the specified domestic transactions (“SDT”) / international transactions undertaken by the Applicant. 9. The TPO vide order dated 30 January 2019 held that the applicant has earned more than ordinary profits from its Section 80-IC business and proposed an adjustment of Rs.5

M/S. THDC INDIA LIMITED,RISHIKESH vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX, DEHRADUN

In the result, appeal of the assessee is allowed

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal[Through Virtual Mode] [Assessment Year : 2017-18] M/S. Thdc India Ltd. Vs Pcit Ganga Bhawan, Aaykar Bhawan, Pragatipuram, Bye Pass 13 A, Subhash Road, Road, Rishikesh, Uttarakhand Uttarakhand-249201 Pan-Aaact7905Q Appellant Respondent Assessee By Shri Jeetan Nagpal, Ca Shri Sanjay Arora, Ca & Ms. Pallavi, Ca Revenue By Ms. Poonam Sharma, Cit Dr Date Of Hearing 08.12.2025 Date Of Pronouncement 18.02.2026 Order Per Manish Agarwal, Am : The Present Appeal Is Filed By The Assessee Against The Order Dated 27.03.2022 By Ld. Pr. Commissioner Of Income Tax, Dehradun [“Ld. Pcit”] Passed U/S 263 Of The Income Tax Act, 1961 [“The Act”] Arising From The Assessment Order Dated 30.12.2019 Passed U/S 143(3) Of The Act Pertaining To Assessment Year 2017-18. 2. Brief Facts Of The Case Are That The Assessee Is A Joint Venture Company Of Government Of India & Government Of Uttar Pradesh & Engaged In The Business Of Generation & Supply Of Hydro- Electric As Well As Wind Power & Also Engaged In Construction Of Hydro Power Plants. The Return Of Income Was Filed On 30.10.2017, Declaring Total Income Of Inr 6,84,04,420/- After Claiming Deduction U/S 80-Ia Of The Act Of Inr 948,40,76,282/-. The Book Profits Was Shown At Inr 7,84,96,09,382/- & Mat Of Inr 1,67,52,32,236/- Was Paid. The Case Of The Assessee Was Selected For Scrutiny & After Considering The Submissions Made, Total Income Was Assessed At Inr 4,63,78,80,698/- By Making Disallowance Out Of Deduction Claimed U/S 80-Ia Of The Act To The Extent Of Inr 211,15,54,378/- & Further Making Addition Of Inr 245,79,21,900/- On Account Of Late Payment Surcharge On Outstanding Debtors For The Period Of 10 Months Holding The Same As Taxable On Accrual Basis & No Deduction U/S 80Ia Was Allowed On Such Addition.

transfer price of lignite and sale price of electricity in computing relief under Section 801A/80IB? 2. If the answer to the question No. 1 is in favour of appellant, whether the notional tax reimbursement in the case of Unit VII of Thermal Power Station II whose entire income is deductible u/s 80IA should also be taken into account for computing

M/S. UJVN LIMITED,DEHRADUN vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX, DEHRADUN

In the result, the appeal of the Assessee is allowed

Bench: Sh. C. N. Prasad & Shri M. Balaganesh(Through Video Conferencing) M/S. Ujvn Limited, Vs. The Principal Commissioner C/O. Mn/S. Rra Taxindia, Of Income, D-28, South Extension, Aayakar Bhawan, 13A, Part-I, Subhash Road, Dehradun New Delhi (Appellant) (Respondent) Pan: Aaacu6672R Assessee By : Dr. Rakesh Gupta, Adv Shri Somil Aggarwal, Adv Revenue By: Shri N. S. Jangpangi, Cit Dr Date Of Hearing 24/08/2023 Date Of Pronouncement 15/09/2023

transfer price of lignite and sale price of electricity in computing relief under Section 801A/80IB? 2. If the answer to the question No. 1 is in favour of appellant, whether the notional tax reimbursement in the case of Unit VII of Thermal Power Station II whose entire income is deductible u/s 80IA should also be taken into account for computing

RUKMAN AGARWAL,U S NAGAR vs. ACIT, CENTRAL CIRCLE, HALDWANI

In the result the appeals filed by the assessee are allowed

Bench: Shri Amit Shukla & Shri B.R.R. Kumarassessment Year: 2010-11

prices of real estate in Uttarakhand and finally the assessee has forfeited the advance against sale of property and transferred the said amount to the capital account to the individual balance sheet. Apart from that, various other submissions were made. 6. Ld. CIT (A) observed that the documents which have been filed along with the petition in rule

SHIV KUMAR AGARWAL,U S NAGAR vs. ACIT, CENTRAL CIRCLE, HALDWANI

In the result the appeals filed by the assessee are allowed

Bench: Shri Amit Shukla & Shri B.R.R. Kumarassessment Year: 2010-11

prices of real estate in Uttarakhand and finally the assessee has forfeited the advance against sale of property and transferred the said amount to the capital account to the individual balance sheet. Apart from that, various other submissions were made. 6. Ld. CIT (A) observed that the documents which have been filed along with the petition in rule

SAURABH AGARWAL,U S NAGAR vs. ACIT, CENTRAL CIRCLE, HALDWANI

In the result the appeals filed by the assessee are allowed

Bench: Shri Amit Shukla & Shri B.R.R. Kumarassessment Year: 2010-11

prices of real estate in Uttarakhand and finally the assessee has forfeited the advance against sale of property and transferred the said amount to the capital account to the individual balance sheet. Apart from that, various other submissions were made. 6. Ld. CIT (A) observed that the documents which have been filed along with the petition in rule

ABHISHEK AGARWAL,U S NAGAR vs. ACIT, CENTRAL CIRCLE, HALDWANI

In the result the appeals filed by the assessee are allowed

Bench: Shri Amit Shukla & Shri B.R.R. Kumarassessment Year: 2010-11

prices of real estate in Uttarakhand and finally the assessee has forfeited the advance against sale of property and transferred the said amount to the capital account to the individual balance sheet. Apart from that, various other submissions were made. 6. Ld. CIT (A) observed that the documents which have been filed along with the petition in rule