MARUTI SUZUKI INDIA LTD vs. COMMISSIONER OF INCOME TAX

The appeals are allowed in the above terms, but with no orders as to costs

Section 40A(2)(b) dealt with the reasonability of quantum of expenditure. (v) TNMM applied with equal force on single transaction as well as multiple transactions as per the scheme of Chapter X and the TP Rules. Thus, the word ‘transaction’ would include a series of closely linked transactions. (vi) The TPO/AO could overrule the method adopted by the Assessee

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:

40A(2)(b) and the ld. CIT(A) has also erred in determining the profit of the assessee @ 3.78% equal to the profit of one of the parties to the JV. Penalty u/s 271G: 11. Facts of the case are as under: The assessee M/s TAPI Prestressed Products Ltd. ('TPPL') and M/s JITF Water Infrastructure Ltd. ('JWIL') had entered into

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:

40A(2)(b) and the ld. CIT(A) has also erred in determining the profit of the assessee @ 3.78% equal to the profit of one of the parties to the JV. Penalty u/s 271G: 11. Facts of the case are as under: The assessee M/s TAPI Prestressed Products Ltd. ('TPPL') and M/s JITF Water Infrastructure Ltd. ('JWIL') had entered into

M/S. RELIGARE CAPITAL MARKETS LTD.,NEW DELHI vs. DCIT, NEW DELHI

Appeal is partly allowed in above terms

Bench: SHRI SATBEER SINGH GODARA (Judicial Member), SHRI S. RIFAUR RAHMAN (Accountant Member)

Pricing Guidelines 2010. 2.5 Without prejudice, the assessing officer/ DRP erred in fact and in law in not appreciating that on facts and circumstances of the case, the corporate guarantee provided by the appellant was merely a substitute for equity infusion and therefore, was pursuant to a shareholder activity for which no compensation is warranted. 2.6 Without prejudice, the assessing

SHANKER TRADING (P) LTD. vs. THE CIT

The appeals stand disposed of

40A (2) of the Income Tax Act, 1961 is applicable in respect of the lease rent paid by the Assessee to M/s Mehta Charitable Prajnalaya Trust?” 11. The following three issues arise for our consideration in these appeals:- (i) whether the lease rent of Rs 6,75,000/- per month paid by the assessee to the Trust was a capital

SHANKER TRADING (P) LTD. vs. THE CIT

The appeals stand disposed of

40A (2) of the Income Tax Act, 1961 is applicable in respect of the lease rent paid by the Assessee to M/s Mehta Charitable Prajnalaya Trust?” 11. The following three issues arise for our consideration in these appeals:- (i) whether the lease rent of Rs 6,75,000/- per month paid by the assessee to the Trust was a capital

SHANKER TRADING (P) LTD. vs. THE CIT

The appeals stand disposed of

40A (2) of the Income Tax Act, 1961 is applicable in respect of the lease rent paid by the Assessee to M/s Mehta Charitable Prajnalaya Trust?” 11. The following three issues arise for our consideration in these appeals:- (i) whether the lease rent of Rs 6,75,000/- per month paid by the assessee to the Trust was a capital

SHANKER TRADING (P) LTD. vs. THE CIT

The appeals stand disposed of

40A (2) of the Income Tax Act, 1961 is applicable in respect of the lease rent paid by the Assessee to M/s Mehta Charitable Prajnalaya Trust?” 11. The following three issues arise for our consideration in these appeals:- (i) whether the lease rent of Rs 6,75,000/- per month paid by the assessee to the Trust was a capital

SHANKER TRADING (P) LTD. vs. THE CIT

The appeals stand disposed of

40A (2) of the Income Tax Act, 1961 is applicable in respect of the lease rent paid by the Assessee to M/s Mehta Charitable Prajnalaya Trust?” 11. The following three issues arise for our consideration in these appeals:- (i) whether the lease rent of Rs 6,75,000/- per month paid by the assessee to the Trust was a capital

SHANKER TRADING (P) LTD. vs. THE CIT

The appeals stand disposed of

40A (2) of the Income Tax Act, 1961 is applicable in respect of the lease rent paid by the Assessee to M/s Mehta Charitable Prajnalaya Trust?” 11. The following three issues arise for our consideration in these appeals:- (i) whether the lease rent of Rs 6,75,000/- per month paid by the assessee to the Trust was a capital

SHANKER TRADING (P) LTD. vs. THE CIT

The appeals stand disposed of

40A (2) of the Income Tax Act, 1961 is applicable in respect of the lease rent paid by the Assessee to M/s Mehta Charitable Prajnalaya Trust?” 11. The following three issues arise for our consideration in these appeals:- (i) whether the lease rent of Rs 6,75,000/- per month paid by the assessee to the Trust was a capital

SHANKER TRADING (P) LTD. vs. THE CIT

The appeals stand disposed of

40A (2) of the Income Tax Act, 1961 is applicable in respect of the lease rent paid by the Assessee to M/s Mehta Charitable Prajnalaya Trust?” 11. The following three issues arise for our consideration in these appeals:- (i) whether the lease rent of Rs 6,75,000/- per month paid by the assessee to the Trust was a capital

SHANKER TRADING (P) LTD. vs. THE CIT

The appeals stand disposed of

40A (2) of the Income Tax Act, 1961 is applicable in respect of the lease rent paid by the Assessee to M/s Mehta Charitable Prajnalaya Trust?” 11. The following three issues arise for our consideration in these appeals:- (i) whether the lease rent of Rs 6,75,000/- per month paid by the assessee to the Trust was a capital

SHANKER TRADING (P) LTD. vs. THE CIT

The appeals stand disposed of

40A (2) of the Income Tax Act, 1961 is applicable in respect of the lease rent paid by the Assessee to M/s Mehta Charitable Prajnalaya Trust?” 11. The following three issues arise for our consideration in these appeals:- (i) whether the lease rent of Rs 6,75,000/- per month paid by the assessee to the Trust was a capital

SHANKER TRADING (P) LTD. vs. THE CIT

The appeals stand disposed of

40A (2) of the Income Tax Act, 1961 is applicable in respect of the lease rent paid by the Assessee to M/s Mehta Charitable Prajnalaya Trust?” 11. The following three issues arise for our consideration in these appeals:- (i) whether the lease rent of Rs 6,75,000/- per month paid by the assessee to the Trust was a capital

SHANKER TRADING (P) LTD. vs. THE CIT

The appeals stand disposed of

40A (2) of the Income Tax Act, 1961 is applicable in respect of the lease rent paid by the Assessee to M/s Mehta Charitable Prajnalaya Trust?” 11. The following three issues arise for our consideration in these appeals:- (i) whether the lease rent of Rs 6,75,000/- per month paid by the assessee to the Trust was a capital

SHANKER TRADING (P) LTD. vs. THE CIT

The appeals stand disposed of

40A (2) of the Income Tax Act, 1961 is applicable in respect of the lease rent paid by the Assessee to M/s Mehta Charitable Prajnalaya Trust?” 11. The following three issues arise for our consideration in these appeals:- (i) whether the lease rent of Rs 6,75,000/- per month paid by the assessee to the Trust was a capital

SHANKER TRADING (P) LTD. vs. THE CIT

The appeals stand disposed of

40A (2) of the Income Tax Act, 1961 is applicable in respect of the lease rent paid by the Assessee to M/s Mehta Charitable Prajnalaya Trust?” 11. The following three issues arise for our consideration in these appeals:- (i) whether the lease rent of Rs 6,75,000/- per month paid by the assessee to the Trust was a capital