TAPI JWIL JV,NEW DELHI vs. ITO, WARD-62(4), NEW DELHI

In the result, the appeals of the assessee are allowed

Bench: Sh. C. M. Gargdr. B. R. R. Kumarita No. 6722/Del/2018 : Asstt. Year : 2014-15 Ita No. 4873/Del/2019 : Asstt. Year : 2014-15 Tapi Jwil Jv, Vs Income Tax Officer, C/O C. S. Anand, Adv., Ward-62(4), 104, Pankaj Tower, 10, L.S.C. New Delhi Savita Vihar, Delhi-110092 (Appellant) (Respondent) Pan No. Aadat3744J Assessee By : Sh. C. S. Anand, Adv. Revenue By : Sh. Amitabh K. Sinha, Cit-Dr Date Of Hearing: 18.07.2023 Date Of Pronouncement: 16.10.2023 Order Per Dr. B. R. R. Kumar:

Transfer Pricing Officer as referred to in section 92CA or the Commissioner (Appeals) may direct that such person shall pay, by way of penalty, a sum equal to two per cent of the value of the international transaction or specified domestic transaction] for each such failure.” 16. Provisions of Section 273B

S.N. EXPORTS,NEW DELHI vs. ITO WARD-4, , PANIPAT

In the result, all the appeals of Revenue are dismissed

Bench: Shri M. Balaganesh & Shri Yogesh Kumar U.S.

transfer pricing (TP) adjustment made in respect of a particular transaction, there cannot be any levy of penalty u/s 271G of the Act. Reliance in this regard is placed on the decision of the Coordinate Bench of Mumbai Tribunal in the case of DCIT Vs. Firestone International Pvt. Ltd in ITA No. 5304/Mum/2016 for AY 2011-12 dated 01.12.2018 wherein

S.N. EXPORTS,NEW DELHI vs. ITO WARD-4, , PANIPAT

In the result, all the appeals of Revenue are dismissed

Bench: Shri M. Balaganesh & Shri Yogesh Kumar U.S.

transfer pricing (TP) adjustment made in respect of a particular transaction, there cannot be any levy of penalty u/s 271G of the Act. Reliance in this regard is placed on the decision of the Coordinate Bench of Mumbai Tribunal in the case of DCIT Vs. Firestone International Pvt. Ltd in ITA No. 5304/Mum/2016 for AY 2011-12 dated 01.12.2018 wherein

SONAL TANEJA,NEW DELHI vs. JOINT COMMISSIONER OF INCOME TAX, DELHI

Bench: Sh. Satbeer Singh Godara & Sh. Manish Agarwal

price of Rs.6,80,000/- in cash in violation of section 269SS 2 Sonal Taneja r.w. Explanation (iv) inserted in the Act vide Finance Act, 2015 w.e.f. 01.06.2015. 4. That being the case, the Revenue could hardly dispute that this tribunal’s recent learned co-ordinate bench order in ITO Vs. Shri R. Dhinagharan (HUF) ITA No. 3329/Chny/2019 dated

PIVOTAL INFRASTRUCTURE LTD,GURGAON vs. ADDI. CIT SPL. RANGE 76, NEW DELHI

The appeal are allowed

Bench: Dr. B.R.R. Kumar & Sh. Anubhav Sharmaita No. 6261/Del/2019, A.Y. 2014-15

price. The lands were developed by HUDA though the same were identified and acquired by Urban Estate Department, Haryana Government, but the ownership and possession was transferred to HUDA for payment of consideration. The Ld. AO also examined scope of External Development Work (EDW) as per Haryana Development and Regulation of Urban Area Act, 1975 which includes water supply, sewerage

TS REALTECH PVT LTD,NEW DELHI vs. ACIT RANGE -76, NEW DELHI

The appeals are allowed

Bench: Sh. Anil Chaturvedi & Sh. Anubhav Sharmaita No. 4940/Del/2019, A.Y. 2014-15 Ita No. 4941/Del/2019, A.Y. 2015-16 Ita No. 4942/Del/2019, A.Y. 2017-18 T.S. Realtech Private Vs. Acit, Limited Range-76 E-26, Panchsheel Park New Delhi New Delhi – 110017 Pan : Aadck3222C (Appellant) (Respondent)

price. The lands were developed by HUDA though the same were identified and acquired by Urban Estate Department, Haryana Government, but the ownership and possession was transferred to HUDA for payment of consideration. The Ld. AO also examined scope of External Development Work (EDW) as per Haryana Development and Regulation of Urban Area Act, 1975 which includes water supply, sewerage

TS REALTECH PVT LTD,NEW DELHI vs. ACIT RANGE -76, NEW DELHI

The appeals are allowed

Bench: Sh. Anil Chaturvedi & Sh. Anubhav Sharmaita No. 4940/Del/2019, A.Y. 2014-15 Ita No. 4941/Del/2019, A.Y. 2015-16 Ita No. 4942/Del/2019, A.Y. 2017-18 T.S. Realtech Private Vs. Acit, Limited Range-76 E-26, Panchsheel Park New Delhi New Delhi – 110017 Pan : Aadck3222C (Appellant) (Respondent)

price. The lands were developed by HUDA though the same were identified and acquired by Urban Estate Department, Haryana Government, but the ownership and possession was transferred to HUDA for payment of consideration. The Ld. AO also examined scope of External Development Work (EDW) as per Haryana Development and Regulation of Urban Area Act, 1975 which includes water supply, sewerage

TS REALTECH PVT LTD,NEW DELHI vs. ACIT RANGE -76, NEW DELHI

The appeals are allowed

Bench: Sh. Anil Chaturvedi & Sh. Anubhav Sharmaita No. 4940/Del/2019, A.Y. 2014-15 Ita No. 4941/Del/2019, A.Y. 2015-16 Ita No. 4942/Del/2019, A.Y. 2017-18 T.S. Realtech Private Vs. Acit, Limited Range-76 E-26, Panchsheel Park New Delhi New Delhi – 110017 Pan : Aadck3222C (Appellant) (Respondent)

price. The lands were developed by HUDA though the same were identified and acquired by Urban Estate Department, Haryana Government, but the ownership and possession was transferred to HUDA for payment of consideration. The Ld. AO also examined scope of External Development Work (EDW) as per Haryana Development and Regulation of Urban Area Act, 1975 which includes water supply, sewerage

TULIP INFRATECH PVT. LTD.,NEW DELHI vs. ACIT, SPECIAL RANGE-76, NEW DELHI

The appeals are allowed

Bench: Sh. G.S.Pannu, Hon’Ble & Sh. Anubhav Sharmaita No.6734/Del/2019, A.Y. 2014-15 Ita No.6735/Del/2019, A.Y. 2016-17 Ita No.6736/Del/2019, A.Y. 2017-18

price. The lands were developed by HUDA though the same were identified and acquired by Urban Estate Department, Haryana Government, but the ownership and possession was transferred to HUDA for payment of consideration. The Ld. AO also examined scope of External Development Work (EDW) as per Haryana Development and Regulation of Urban Area Act, 1975 which includes water supply, sewerage

TULIP INFRATECH PVT. LTD.,NEW DELHI vs. ACIT, SPECIAL RANGE-76, NEW DELHI

The appeals are allowed

Bench: Sh. G.S.Pannu, Hon’Ble & Sh. Anubhav Sharmaita No.6734/Del/2019, A.Y. 2014-15 Ita No.6735/Del/2019, A.Y. 2016-17 Ita No.6736/Del/2019, A.Y. 2017-18

price. The lands were developed by HUDA though the same were identified and acquired by Urban Estate Department, Haryana Government, but the ownership and possession was transferred to HUDA for payment of consideration. The Ld. AO also examined scope of External Development Work (EDW) as per Haryana Development and Regulation of Urban Area Act, 1975 which includes water supply, sewerage

TULIP INFRATECH PVT. LTD.,NEW DELHI vs. ACIT, SPECIAL RANGE-76, NEW DELHI

The appeals are allowed

Bench: Sh. G.S.Pannu, Hon’Ble & Sh. Anubhav Sharmaita No.6734/Del/2019, A.Y. 2014-15 Ita No.6735/Del/2019, A.Y. 2016-17 Ita No.6736/Del/2019, A.Y. 2017-18

price. The lands were developed by HUDA though the same were identified and acquired by Urban Estate Department, Haryana Government, but the ownership and possession was transferred to HUDA for payment of consideration. The Ld. AO also examined scope of External Development Work (EDW) as per Haryana Development and Regulation of Urban Area Act, 1975 which includes water supply, sewerage

VATIKA SOVEREIGN PARK PRIVATE LIMITED,NEW DELHI vs. ACIT CIRCLE-26(1), NEW DELHI

The appeals are allowed

Bench: Sh. G.S.Pannu, Hon’Ble & Sh. Anubhav Sharmaita No.7251 & 7252/Del/2019 (Assessment Year : 2016-17 & 2017-18) Vatika Sovereign Park Private Vs. The Assistant Commissioner Of Limited, Income Tax, 621A, 6Th Floor, Devika Towers Circle-26(1) 6-Nehru Place New Delhi New Delhi-110019 Pan No. Aafcp9383D (Appellant) (Respondent)

price. The lands were developed by HUDA though the same were identified and acquired by Urban Estate Department, Haryana Government, but the ownership and possession was transferred to HUDA for payment of consideration. The Ld. AO also examined scope of External Development Work (EDW) as per Haryana Development and Regulation of Urban Area Act, 1975 which includes water supply, sewerage

VATIKA SOVEREIGN PARK PRIVATE LIMITED,NEW DELHI vs. ACIT CIRCLE-26(1), NEW DELHI

The appeals are allowed

Bench: Sh. G.S.Pannu, Hon’Ble & Sh. Anubhav Sharmaita No.7251 & 7252/Del/2019 (Assessment Year : 2016-17 & 2017-18) Vatika Sovereign Park Private Vs. The Assistant Commissioner Of Limited, Income Tax, 621A, 6Th Floor, Devika Towers Circle-26(1) 6-Nehru Place New Delhi New Delhi-110019 Pan No. Aafcp9383D (Appellant) (Respondent)

price. The lands were developed by HUDA though the same were identified and acquired by Urban Estate Department, Haryana Government, but the ownership and possession was transferred to HUDA for payment of consideration. The Ld. AO also examined scope of External Development Work (EDW) as per Haryana Development and Regulation of Urban Area Act, 1975 which includes water supply, sewerage

TDI INFRASTRUCTURE LTD.,NEW DELHI vs. ADDI. CIT RANGE-76, NEW DELHI

The appeals are allowed

Bench: Sh. G.S.Pannu, Hon’Ble & Sh. Anubhav Sharmatdi Infrastructure Ltd. Vs. Addl. Cit, 10, Shaheed Bhagat Singh Marg, Range-76, Connaught Place, New Delhi New Delhi- 110001 Pan : Aaaci5799P (Appellant) (Respondent)

price. The lands were developed by HUDA TDI Infrastructure Ltd. 3 though the same were identified and acquired by Urban Estate Department, Haryana Government, but the ownership and possession was transferred to HUDA for payment of consideration. The Ld. AO also examined scope of External Development Work (EDW) as per Haryana Development and Regulation of Urban Area Act, 1975 which