MARUTI SUZUKI INDIA LTD vs. COMMISSIONER OF INCOME TAX

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

3 is in favour of the Revenue, whether the Income Tax Appellate Tribunal was right in holding that transfer pricing adjustment in respect of AMP Expenses should be computed by applying Cost Plus Method. (v) Whether the Income Tax Appellate Tribunal was right in directing that fresh bench marking/comparability analysis should be undertaken by the Transfer Pricing Officer by applying

KRBL LIMITED,DELHI vs. DCIT CENTRAL CIRCLE- 07, NEW DELHI

In the result, the appeal of the assessee on this ground is allowed

Bench: Sh. A.D. Jaindr. B. R. R. Kumarita No. 1196/Del/2020 : Asstt. Year: 2010-11 Ita No. 1197/Del/2020 : Asstt. Year: 2011-12

Section 2(p)] (1) When any question arises as to whether any person is a producer or not for the purposes of the Act, the Director on receipt of a complaint in this behalf, shall make enquiries from ITA Nos.1338 to 1344/Del/2020 KRBL Ltd. the Tahsildar concerned, whether the person against whom complaint has been made, either cultivates the land

KRBL LIMITED,DELHI vs. DCIT CENTRAL CIRCLE- 07, NEW DELHI

In the result, the appeal of the assessee on this ground is allowed

Bench: Sh. A.D. Jaindr. B. R. R. Kumarita No. 1196/Del/2020 : Asstt. Year: 2010-11 Ita No. 1197/Del/2020 : Asstt. Year: 2011-12

Section 2(p)] (1) When any question arises as to whether any person is a producer or not for the purposes of the Act, the Director on receipt of a complaint in this behalf, shall make enquiries from ITA Nos.1338 to 1344/Del/2020 KRBL Ltd. the Tahsildar concerned, whether the person against whom complaint has been made, either cultivates the land

DCIT CENTRAL CIRCLE- 19, NEW DELHI vs. KRBL LIMITED, DELHI

In the result, the appeal of the assessee on this ground is allowed

Bench: Sh. A.D. Jaindr. B. R. R. Kumarita No. 1196/Del/2020 : Asstt. Year: 2010-11 Ita No. 1197/Del/2020 : Asstt. Year: 2011-12

Section 2(p)] (1) When any question arises as to whether any person is a producer or not for the purposes of the Act, the Director on receipt of a complaint in this behalf, shall make enquiries from ITA Nos.1338 to 1344/Del/2020 KRBL Ltd. the Tahsildar concerned, whether the person against whom complaint has been made, either cultivates the land

DCIT CENTRAL CIRCLE- 19, NEW DELHI vs. KRBL LIMITED, DELHI

In the result, the appeal of the assessee on this ground is allowed

Bench: Sh. A.D. Jaindr. B. R. R. Kumarita No. 1196/Del/2020 : Asstt. Year: 2010-11 Ita No. 1197/Del/2020 : Asstt. Year: 2011-12

Section 2(p)] (1) When any question arises as to whether any person is a producer or not for the purposes of the Act, the Director on receipt of a complaint in this behalf, shall make enquiries from ITA Nos.1338 to 1344/Del/2020 KRBL Ltd. the Tahsildar concerned, whether the person against whom complaint has been made, either cultivates the land

KRBL LIMITED,DELHI vs. DCIT CENTRAL CIRCLE- 07, NEW DELHI

In the result, the appeal of the assessee on this ground is allowed

Bench: Sh. A.D. Jaindr. B. R. R. Kumarita No. 1196/Del/2020 : Asstt. Year: 2010-11 Ita No. 1197/Del/2020 : Asstt. Year: 2011-12

Section 2(p)] (1) When any question arises as to whether any person is a producer or not for the purposes of the Act, the Director on receipt of a complaint in this behalf, shall make enquiries from ITA Nos.1338 to 1344/Del/2020 KRBL Ltd. the Tahsildar concerned, whether the person against whom complaint has been made, either cultivates the land

DCIT CENTRAL CIRCLE- 19, NEW DELHI vs. KRBL LIMITED, DELHI

In the result, the appeal of the assessee on this ground is allowed

Bench: Sh. A.D. Jaindr. B. R. R. Kumarita No. 1196/Del/2020 : Asstt. Year: 2010-11 Ita No. 1197/Del/2020 : Asstt. Year: 2011-12

Section 2(p)] (1) When any question arises as to whether any person is a producer or not for the purposes of the Act, the Director on receipt of a complaint in this behalf, shall make enquiries from ITA Nos.1338 to 1344/Del/2020 KRBL Ltd. the Tahsildar concerned, whether the person against whom complaint has been made, either cultivates the land

DCIT CENTRAL CIRCLE- 19, NEW DELHI vs. KRBL LIMITED, DELHI

In the result, the appeal of the assessee on this ground is allowed

Bench: Sh. A.D. Jaindr. B. R. R. Kumarita No. 1196/Del/2020 : Asstt. Year: 2010-11 Ita No. 1197/Del/2020 : Asstt. Year: 2011-12

Section 2(p)] (1) When any question arises as to whether any person is a producer or not for the purposes of the Act, the Director on receipt of a complaint in this behalf, shall make enquiries from ITA Nos.1338 to 1344/Del/2020 KRBL Ltd. the Tahsildar concerned, whether the person against whom complaint has been made, either cultivates the land

KRBL LIMITED,DELHI vs. DCIT CENTRAL CIRCLE- 07, NEW DELHI

In the result, the appeal of the assessee on this ground is allowed

Bench: Sh. A.D. Jaindr. B. R. R. Kumarita No. 1196/Del/2020 : Asstt. Year: 2010-11 Ita No. 1197/Del/2020 : Asstt. Year: 2011-12

Section 2(p)] (1) When any question arises as to whether any person is a producer or not for the purposes of the Act, the Director on receipt of a complaint in this behalf, shall make enquiries from ITA Nos.1338 to 1344/Del/2020 KRBL Ltd. the Tahsildar concerned, whether the person against whom complaint has been made, either cultivates the land

DCIT CENTRAL CIRCLE- 19, NEW DELHI vs. KRBL LIMITED, DELHI

In the result, the appeal of the assessee on this ground is allowed

Bench: Sh. A.D. Jaindr. B. R. R. Kumarita No. 1196/Del/2020 : Asstt. Year: 2010-11 Ita No. 1197/Del/2020 : Asstt. Year: 2011-12

Section 2(p)] (1) When any question arises as to whether any person is a producer or not for the purposes of the Act, the Director on receipt of a complaint in this behalf, shall make enquiries from ITA Nos.1338 to 1344/Del/2020 KRBL Ltd. the Tahsildar concerned, whether the person against whom complaint has been made, either cultivates the land

KRBL LIMITED,DELHI vs. DCIT CENTRAL CIRCLE- 07, NEW DELHI

In the result, the appeal of the assessee on this ground is allowed

Bench: Sh. A.D. Jaindr. B. R. R. Kumarita No. 1196/Del/2020 : Asstt. Year: 2010-11 Ita No. 1197/Del/2020 : Asstt. Year: 2011-12

Section 2(p)] (1) When any question arises as to whether any person is a producer or not for the purposes of the Act, the Director on receipt of a complaint in this behalf, shall make enquiries from ITA Nos.1338 to 1344/Del/2020 KRBL Ltd. the Tahsildar concerned, whether the person against whom complaint has been made, either cultivates the land

DCIT CENTRAL CIRCLE- 19, NEW DELHI vs. KRBL LIMITED, DELHI

In the result, the appeal of the assessee on this ground is allowed

Bench: Sh. A.D. Jaindr. B. R. R. Kumarita No. 1196/Del/2020 : Asstt. Year: 2010-11 Ita No. 1197/Del/2020 : Asstt. Year: 2011-12

Section 2(p)] (1) When any question arises as to whether any person is a producer or not for the purposes of the Act, the Director on receipt of a complaint in this behalf, shall make enquiries from ITA Nos.1338 to 1344/Del/2020 KRBL Ltd. the Tahsildar concerned, whether the person against whom complaint has been made, either cultivates the land

KRBL LIMITED,DELHI vs. DCIT CENTRAL CIRCLE- 07, NEW DELHI

In the result, the appeal of the assessee on this ground is allowed

Bench: Sh. A.D. Jaindr. B. R. R. Kumarita No. 1196/Del/2020 : Asstt. Year: 2010-11 Ita No. 1197/Del/2020 : Asstt. Year: 2011-12

Section 2(p)] (1) When any question arises as to whether any person is a producer or not for the purposes of the Act, the Director on receipt of a complaint in this behalf, shall make enquiries from ITA Nos.1338 to 1344/Del/2020 KRBL Ltd. the Tahsildar concerned, whether the person against whom complaint has been made, either cultivates the land

DCIT CENTRAL CIRCLE- 19, NEW DELHI vs. KRBL LIMITED, DELHI

In the result, the appeal of the assessee on this ground is allowed

Bench: Sh. A.D. Jaindr. B. R. R. Kumarita No. 1196/Del/2020 : Asstt. Year: 2010-11 Ita No. 1197/Del/2020 : Asstt. Year: 2011-12

Section 2(p)] (1) When any question arises as to whether any person is a producer or not for the purposes of the Act, the Director on receipt of a complaint in this behalf, shall make enquiries from ITA Nos.1338 to 1344/Del/2020 KRBL Ltd. the Tahsildar concerned, whether the person against whom complaint has been made, either cultivates the land

KRBL LIMITED,DELHI vs. DCIT CENTRAL CIRCLE- 07, NEW DELHI

In the result, the appeal of the assessee on this ground is allowed

Bench: Sh. A.D. Jaindr. B. R. R. Kumarita No. 1196/Del/2020 : Asstt. Year: 2010-11 Ita No. 1197/Del/2020 : Asstt. Year: 2011-12

Section 2(p)] (1) When any question arises as to whether any person is a producer or not for the purposes of the Act, the Director on receipt of a complaint in this behalf, shall make enquiries from ITA Nos.1338 to 1344/Del/2020 KRBL Ltd. the Tahsildar concerned, whether the person against whom complaint has been made, either cultivates the land

ACIT, CIRCLE-8(1), NEW DELHI vs. EFS FACILITIES SERVICES (INDIA) PVT. LTD., NEW DELHI

In the result, both the appeals of the Revenue for assessment year

Bench: Dr. B.R.R. Kumar & Ms. Astha Chandra

3) by the Transfer Pricing Officer.” The amended sub-section (4) provides that on receipt of the order of the TPO, the AO shall proceed to compute the total income of the assessee under section 92C(4) in conformity with the ALP as determined by the TPO. This provision is mandatory. By using the expression “shall” no discretion is provided

ACIT, CIRCLE-8(1), NEW DELHI vs. EFS FACILITIES SERVICES (INDIA) PVT. LTD., NEW DELHI

In the result, both the appeals of the Revenue for assessment year

Bench: Dr. B.R.R. Kumar & Ms. Astha Chandra

3) by the Transfer Pricing Officer.” The amended sub-section (4) provides that on receipt of the order of the TPO, the AO shall proceed to compute the total income of the assessee under section 92C(4) in conformity with the ALP as determined by the TPO. This provision is mandatory. By using the expression “shall” no discretion is provided

ITO WARD 3, PANIPAT vs. NARENDER SINGH , PANIPAT

In the result, the appeal of the revenue is dismissed

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarasstt. Year: 2017-18 Ito Ward 3, Vs. Narender Singh Panipat 217, New Shanti Nagar, Panipat, Haryana 132103 Pan Bokps2460F (Appellant) (Respondent)

transferred to the account of company i.e. Hisar Jind Co-Op. Milk Producers Union Ltd. On perusal of bank statement it was noticed that there were debit entries to the tune of Rs. 3,45,37,546/-. However the assessee showed purchase at Rs. 6,14,83,310/-. Assessee was required to furnish the source and mode of balance payment