ACIT, CENTRAL CIRCLE- 30, NEW DELHI vs. PARKASH INDUSTRIES LTD, HISAR

Bench: Shri Amit Shukla & Shri B.R.R. Kumar

section 153a qua the assessee was not justified in law. [para 39]” d. CIT v. Lachman Dass Bhatia [2012] 26 taxmann.com 167 (Delhi) “It has also been recorded by the commissioner (appeals), whose decision has been confirmed by the tribunal, that the documents upon which the assessing officer placed reliance relate to a subsequent period and not to the years

ACIT, CENTRAL CIRCLE- 30, NEW DELHI vs. PRAKASH INDUSTRIES LTD., HISAR

Bench: Shri Amit Shukla & Shri B.R.R. Kumar

section 153a qua the assessee was not justified in law. [para 39]” d. CIT v. Lachman Dass Bhatia [2012] 26 taxmann.com 167 (Delhi) “It has also been recorded by the commissioner (appeals), whose decision has been confirmed by the tribunal, that the documents upon which the assessing officer placed reliance relate to a subsequent period and not to the years

PRAKASH INDUSTRIES LTD.,NEW DELHI vs. ACIT, CC- 30,, NEW DELHI

Bench: Shri Amit Shukla & Shri B.R.R. Kumar

section 153a qua the assessee was not justified in law. [para 39]” d. CIT v. Lachman Dass Bhatia [2012] 26 taxmann.com 167 (Delhi) “It has also been recorded by the commissioner (appeals), whose decision has been confirmed by the tribunal, that the documents upon which the assessing officer placed reliance relate to a subsequent period and not to the years

PRAKASH INDUSTRIES LTD.,NEW DELHI vs. ACIT, CENTRAL CIRCLE- 30, NEW DELHI

Bench: Shri Amit Shukla & Shri B.R.R. Kumar

section 153a qua the assessee was not justified in law. [para 39]” d. CIT v. Lachman Dass Bhatia [2012] 26 taxmann.com 167 (Delhi) “It has also been recorded by the commissioner (appeals), whose decision has been confirmed by the tribunal, that the documents upon which the assessing officer placed reliance relate to a subsequent period and not to the years

ACIT, CENTRAL CIRCLE- 30, NEW DELHI vs. PARKASH INDUSTRIES LTD, HISAR

Bench: Shri Amit Shukla & Shri B.R.R. Kumar

section 153a qua the assessee was not justified in law. [para 39]” d. CIT v. Lachman Dass Bhatia [2012] 26 taxmann.com 167 (Delhi) “It has also been recorded by the commissioner (appeals), whose decision has been confirmed by the tribunal, that the documents upon which the assessing officer placed reliance relate to a subsequent period and not to the years

ACIT, CENTRAL CIRCLE- 30, NEW DELHI vs. PARKASH INDUSTRIES LTD, HISAR

Bench: Shri Amit Shukla & Shri B.R.R. Kumar

section 153a qua the assessee was not justified in law. [para 39]” d. CIT v. Lachman Dass Bhatia [2012] 26 taxmann.com 167 (Delhi) “It has also been recorded by the commissioner (appeals), whose decision has been confirmed by the tribunal, that the documents upon which the assessing officer placed reliance relate to a subsequent period and not to the years

PRAKASH INDUSTRIES LTD.,NEW DELHI vs. ACIT, CC- 30,, NEW DELHI

Bench: Shri Amit Shukla & Shri B.R.R. Kumar

section 153a qua the assessee was not justified in law. [para 39]” d. CIT v. Lachman Dass Bhatia [2012] 26 taxmann.com 167 (Delhi) “It has also been recorded by the commissioner (appeals), whose decision has been confirmed by the tribunal, that the documents upon which the assessing officer placed reliance relate to a subsequent period and not to the years

PRAKASH INDUSTRIES LTD.,NEW DELHI vs. ACIT, CC- 30,, NEW DELHI

Bench: Shri Amit Shukla & Shri B.R.R. Kumar

section 153a qua the assessee was not justified in law. [para 39]” d. CIT v. Lachman Dass Bhatia [2012] 26 taxmann.com 167 (Delhi) “It has also been recorded by the commissioner (appeals), whose decision has been confirmed by the tribunal, that the documents upon which the assessing officer placed reliance relate to a subsequent period and not to the years

PRAKASH INDUSTRIES LTD.,NEW DELHI vs. ACIT, CC- 30,, NEW DELHI

Bench: Shri Amit Shukla & Shri B.R.R. Kumar

section 153a qua the assessee was not justified in law. [para 39]” d. CIT v. Lachman Dass Bhatia [2012] 26 taxmann.com 167 (Delhi) “It has also been recorded by the commissioner (appeals), whose decision has been confirmed by the tribunal, that the documents upon which the assessing officer placed reliance relate to a subsequent period and not to the years

ACIT, CENTRAL CIRCLE- 30, NEW DELHI vs. PRAKASH INDUSTRIES LTD., HISAR

Bench: Shri Amit Shukla & Shri B.R.R. Kumar

section 153a qua the assessee was not justified in law. [para 39]” d. CIT v. Lachman Dass Bhatia [2012] 26 taxmann.com 167 (Delhi) “It has also been recorded by the commissioner (appeals), whose decision has been confirmed by the tribunal, that the documents upon which the assessing officer placed reliance relate to a subsequent period and not to the years

AMOL AWASTHI,NEW DELHI vs. DCIT, CENTRAL CIRCLE-I, NEW DELHI

In the result, appeals are allowed, as indicated

Bench: Shri Saktijit Dey & Shri M Balaganesh

price fixation of the fertiliser's transactions by the concerned seller/ buyer where none had even alleged that the NRI was ever a party to the impugned transactions. Further, it is also brought to the notice that as per the satisfaction note dated 29/09/2021, the AO contends in the conclusion that "may have bearing on his income" whereas the section

AMOL AWASTHI,NEW DELHI vs. DCIT, C.C.1, NEW DELHI

In the result, appeals are allowed, as indicated

Bench: Shri Saktijit Dey & Shri M Balaganesh

price fixation of the fertiliser's transactions by the concerned seller/ buyer where none had even alleged that the NRI was ever a party to the impugned transactions. Further, it is also brought to the notice that as per the satisfaction note dated 29/09/2021, the AO contends in the conclusion that "may have bearing on his income" whereas the section

AMOL AWASTHI,NEW DELHI vs. DCIT, C.C.1, NEW DELHI

In the result, appeals are allowed, as indicated

Bench: Shri Saktijit Dey & Shri M Balaganesh

price fixation of the fertiliser's transactions by the concerned seller/ buyer where none had even alleged that the NRI was ever a party to the impugned transactions. Further, it is also brought to the notice that as per the satisfaction note dated 29/09/2021, the AO contends in the conclusion that "may have bearing on his income" whereas the section

AMOL AWASTHI,NEW DELHI vs. DCIT, C.C.1, NEW DELHI

In the result, appeals are allowed, as indicated

Bench: Shri Saktijit Dey & Shri M Balaganesh

price fixation of the fertiliser's transactions by the concerned seller/ buyer where none had even alleged that the NRI was ever a party to the impugned transactions. Further, it is also brought to the notice that as per the satisfaction note dated 29/09/2021, the AO contends in the conclusion that "may have bearing on his income" whereas the section

AMOL AWASTHI,NEW DELHI vs. DCIT, C.C.1, NEW DELHI

In the result, appeals are allowed, as indicated

Bench: Shri Saktijit Dey & Shri M Balaganesh

price fixation of the fertiliser's transactions by the concerned seller/ buyer where none had even alleged that the NRI was ever a party to the impugned transactions. Further, it is also brought to the notice that as per the satisfaction note dated 29/09/2021, the AO contends in the conclusion that "may have bearing on his income" whereas the section

AMOL AWASTHI,NEW DELHI vs. DCIT, CENTRAL CIRCLE-1, NEW DELHI

In the result, appeals are allowed, as indicated

Bench: Shri Saktijit Dey & Shri M Balaganesh

price fixation of the fertiliser's transactions by the concerned seller/ buyer where none had even alleged that the NRI was ever a party to the impugned transactions. Further, it is also brought to the notice that as per the satisfaction note dated 29/09/2021, the AO contends in the conclusion that "may have bearing on his income" whereas the section

AMOL AWASTHI,NEW DELHI vs. DCIT, CENTRAL CIRCLE-1, NEW DELHI

In the result, appeals are allowed, as indicated

Bench: Shri Saktijit Dey & Shri M Balaganesh

price fixation of the fertiliser's transactions by the concerned seller/ buyer where none had even alleged that the NRI was ever a party to the impugned transactions. Further, it is also brought to the notice that as per the satisfaction note dated 29/09/2021, the AO contends in the conclusion that "may have bearing on his income" whereas the section

PR. COMMISSIONER OF INCOME TAX -7 vs. SUMITOMO CORPORATION INDIA (P) LTD.

Bench: HON'BLE MR. JUSTICE YASHWANT VARMA,HON'BLE MR. JUSTICE RAVINDER DUDEJA

Transfer Pricing Officer is received by him.] (6) Nothing contained in sub-sections (1) [, (1-A)] and (2) shall apply to the following classes of assessments, reassessments and recomputation which may, subject to the provisions of [sub-sections (3), (5) and (5-A)], be completed— (i) where the assessment, reassessment or recomputation is made Digitally Signed By:KAMLESH KUMAR Signing