DCIT, NEW DELHI vs. M/S. NEWBURY HOLDING TWO LTD., NEW DELHI

In the result, the Cross Objections of the assessees are\nallowed and consequently the appeals of the revenue are liable\nto be dismissed

b) \"eligible assessee” means,-\n(i)\nany person in whose case the variation referred to in sub-section\n(1) arises as a consequence of the order of the Transfer Pricing\nOfficer passed under sub-section (3) of section 92CA; and\n(j) any foreign company.\n45.3 Further, consequential amendments have been made —\n(i)\nin sub-section (1

DCIT, NEW DELHI vs. I ENERGIZER HOLDINGS LTD., NEW DELHI

In the result, the Cross Objections of the assessees are allowed and consequently the appeals of the revenue are liable to be dismissed

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

b) “eligible assessee” means,- (i) any person in whose case the variation referred to in sub-section (1) arises as a consequence of the order of the Transfer Pricing Officer passed under sub-section (3) of section 92CA; and (j) any foreign company. 45.3 Further, consequential amendments have been made – (i) in sub-section (1) of section

DCIT, NEW DELHI vs. I ENERGIZER HOLDINGS LTD., NEW DELHI

In the result, the Cross Objections of the assessees are allowed and consequently the appeals of the revenue are liable to be dismissed

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

b) “eligible assessee” means,- (i) any person in whose case the variation referred to in sub-section (1) arises as a consequence of the order of the Transfer Pricing Officer passed under sub-section (3) of section 92CA; and (j) any foreign company. 45.3 Further, consequential amendments have been made – (i) in sub-section (1) of section

DCIT, NEW DELHI vs. I ENERGIZER HOLDINGS LTD., NEW DELHI

In the result, the Cross Objections of the assessees are allowed and consequently the appeals of the revenue are liable to be dismissed

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

b) “eligible assessee” means,- (i) any person in whose case the variation referred to in sub-section (1) arises as a consequence of the order of the Transfer Pricing Officer passed under sub-section (3) of section 92CA; and (j) any foreign company. 45.3 Further, consequential amendments have been made – (i) in sub-section (1) of section

DCIT, NEW DELHI vs. I ENERGIZER HOLDINGS LTD., NEW DELHI

In the result, the Cross Objections of the assessees are allowed and consequently the appeals of the revenue are liable to be dismissed

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

b) “eligible assessee” means,- (i) any person in whose case the variation referred to in sub-section (1) arises as a consequence of the order of the Transfer Pricing Officer passed under sub-section (3) of section 92CA; and (j) any foreign company. 45.3 Further, consequential amendments have been made – (i) in sub-section (1) of section

DCIT, NEW DELHI vs. ISERVICES INVESTMENTS LTD., NEW DELHI

In the result, the Cross Objections of the assessees are allowed and consequently the appeals of the revenue are liable to be dismissed

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

b) “eligible assessee” means,- (i) any person in whose case the variation referred to in sub-section (1) arises as a consequence of the order of the Transfer Pricing Officer passed under sub-section (3) of section 92CA; and (j) any foreign company. 45.3 Further, consequential amendments have been made – (i) in sub-section (1) of section

DCIT, NEW DELHI vs. M/S WICKWOOD DEVELOPMENT LTD.,, NEW DELHI

In the result, the Cross Objections of the assessees are allowed and consequently the appeals of the revenue are liable to be dismissed

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

b) “eligible assessee” means,- (i) any person in whose case the variation referred to in sub-section (1) arises as a consequence of the order of the Transfer Pricing Officer passed under sub-section (3) of section 92CA; and (j) any foreign company. 45.3 Further, consequential amendments have been made – (i) in sub-section (1) of 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-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, 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, 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

JET LITE (INDIA) LTD.,MUMBAI vs. DCIT, CENTRAL CIRCLE-6 (NOW CC-1), MUMBAI

In the result, the appeal of the assessee is dismissed

Bench: Shri M. Balaganesh & Shri Anubhav Sharmajet Lite (India) Ltd, Vs. Dcit, 13, Community Central Circle-6, Centre, Yusuf Sarai, (Now Cc-1), New Delhi New Delhi (Appellant) (Respondent) Pan:Aadcs4480L

246A. 9.16 As a natural corollary, it is necessary to pin point with reference to the impugned order as to where exactly the lower authority erred. However, in present case, the appellant has falled to do so. 9.17 The original assessment (quantum) order (as a part of which the action of initiation of penalty, was taken) which is sought

COMMISSIONER OF INCOME TAX vs. M/S. ABHINANDAN INVESTMENT LTD

1. Right issue of JISCO: 10.5% redeemable NCDs with DW Right issue of Max India: 12% redeemable NCDs with DW 2. NCD face value `500/- each NCD face value `250/- each 3. DW entitled holder to apply for an equity share of JISCO of `10/- face value at a premium of `190/- per share DW entitled holder to apply

COMMISSIONER OF INCOME TAX vs. M/S. ABHINANDAN INVESTMENT LTD

1. Right issue of JISCO: 10.5% redeemable NCDs with DW Right issue of Max India: 12% redeemable NCDs with DW 2. NCD face value `500/- each NCD face value `250/- each 3. DW entitled holder to apply for an equity share of JISCO of `10/- face value at a premium of `190/- per share DW entitled holder to apply

COMMISSIONER OF INCOME TAX vs. M/S. ABHINANDAN INVESTMENT LTD

1. Right issue of JISCO: 10.5% redeemable NCDs with DW Right issue of Max India: 12% redeemable NCDs with DW 2. NCD face value `500/- each NCD face value `250/- each 3. DW entitled holder to apply for an equity share of JISCO of `10/- face value at a premium of `190/- per share DW entitled holder to apply