DCIT, CIRCLE-1, DIBRUGARH vs. BAJRANG LAL BAMALWA, DIBRUGARH

In the result, all the appeals of the Revenue are dismissed and that of the Cross Objections of the assessees are allowed

Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Rajesh Kumar

transfer, the shares were sent to his demat a/c for credit. HDPL was amalgamated with TFCIL by order of the Hon’ble Calcutta High Court dated 23.10.2010. By virtue of the scheme of amalgamation, the Assessee was allotted on 23.12.2010, 38 shares of TFCIL against 1 share of HDPL and credited to his demat a/c. (ii) The Assessee laid special

D.C.I.T., CIRCLE-1, DIBRUGARH vs. BACHH RAJ BAMALWA, DIBRUGARH

In the result, all the appeals of the Revenue are dismissed and that of the Cross Objections of the assessees are allowed

Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Rajesh Kumar

transfer, the shares were sent to his demat a/c for credit. HDPL was amalgamated with TFCIL by order of the Hon’ble Calcutta High Court dated 23.10.2010. By virtue of the scheme of amalgamation, the Assessee was allotted on 23.12.2010, 38 shares of TFCIL against 1 share of HDPL and credited to his demat a/c. (ii) The Assessee laid special

D.C.I.T., CIRCLE-1, DIBRUGARH vs. BACHH RAJ BAMALWA, DIBRUGARH

In the result, all the appeals of the Revenue are dismissed and that of the Cross Objections of the assessees are allowed

Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Rajesh Kumar

transfer, the shares were sent to his demat a/c for credit. HDPL was amalgamated with TFCIL by order of the Hon’ble Calcutta High Court dated 23.10.2010. By virtue of the scheme of amalgamation, the Assessee was allotted on 23.12.2010, 38 shares of TFCIL against 1 share of HDPL and credited to his demat a/c. (ii) The Assessee laid special

D.C.I.T., CIRCLE- 1, DIBRUGARH vs. HANS RAJ BAMALWA, DIBRUGARH

In the result, all the appeals of the Revenue are dismissed and that of the Cross Objections of the assessees are allowed

Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Rajesh Kumar

transfer, the shares were sent to his demat a/c for credit. HDPL was amalgamated with TFCIL by order of the Hon’ble Calcutta High Court dated 23.10.2010. By virtue of the scheme of amalgamation, the Assessee was allotted on 23.12.2010, 38 shares of TFCIL against 1 share of HDPL and credited to his demat a/c. (ii) The Assessee laid special

D.C.I.T., CIRCLE- 1, DIBRUGARH vs. HANS RAJ BAMALWA (HUF), DIBRUGARH

In the result, all the appeals of the Revenue are dismissed and that of the Cross Objections of the assessees are allowed

Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Rajesh Kumar

transfer, the shares were sent to his demat a/c for credit. HDPL was amalgamated with TFCIL by order of the Hon’ble Calcutta High Court dated 23.10.2010. By virtue of the scheme of amalgamation, the Assessee was allotted on 23.12.2010, 38 shares of TFCIL against 1 share of HDPL and credited to his demat a/c. (ii) The Assessee laid special

D.C.I.T., CIRCLE- 1, DIBRUGARH vs. USHA BAMALWA, DIBRUGARH

In the result, all the appeals of the Revenue are dismissed and that of the Cross Objections of the assessees are allowed

Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Rajesh Kumar

transfer, the shares were sent to his demat a/c for credit. HDPL was amalgamated with TFCIL by order of the Hon’ble Calcutta High Court dated 23.10.2010. By virtue of the scheme of amalgamation, the Assessee was allotted on 23.12.2010, 38 shares of TFCIL against 1 share of HDPL and credited to his demat a/c. (ii) The Assessee laid special

D.C.I.T., CIRCLE- 1, DIBRUGARH vs. MEENAKSHI BAMALWA SONI, DIBRUGARH

In the result, all the appeals of the Revenue are dismissed and that of the Cross Objections of the assessees are allowed

Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Rajesh Kumar

transfer, the shares were sent to his demat a/c for credit. HDPL was amalgamated with TFCIL by order of the Hon’ble Calcutta High Court dated 23.10.2010. By virtue of the scheme of amalgamation, the Assessee was allotted on 23.12.2010, 38 shares of TFCIL against 1 share of HDPL and credited to his demat a/c. (ii) The Assessee laid special

D.C.I.T., CIRCLE- 1, DIBRUGARH vs. BHAGWATI DEVII BAMALWA , DIBRUGARH

In the result, all the appeals of the Revenue are dismissed and that of the Cross Objections of the assessees are allowed

Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Rajesh Kumar

transfer, the shares were sent to his demat a/c for credit. HDPL was amalgamated with TFCIL by order of the Hon’ble Calcutta High Court dated 23.10.2010. By virtue of the scheme of amalgamation, the Assessee was allotted on 23.12.2010, 38 shares of TFCIL against 1 share of HDPL and credited to his demat a/c. (ii) The Assessee laid special

D.C.I.T., CIRCLE- 1, DIBRUGARH vs. VISHAL BAMALWA , DIBRUGARH

In the result, all the appeals of the Revenue are dismissed and that of the Cross Objections of the assessees are allowed

Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Rajesh Kumar

transfer, the shares were sent to his demat a/c for credit. HDPL was amalgamated with TFCIL by order of the Hon’ble Calcutta High Court dated 23.10.2010. By virtue of the scheme of amalgamation, the Assessee was allotted on 23.12.2010, 38 shares of TFCIL against 1 share of HDPL and credited to his demat a/c. (ii) The Assessee laid special

D.C.I.T., CIRCLE-1, DIBRUGARH vs. SHEETAL BAMALWA, DIBRUGARH

In the result, all the appeals of the Revenue are dismissed and that of the Cross Objections of the assessees are allowed

Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Rajesh Kumar

transfer, the shares were sent to his demat a/c for credit. HDPL was amalgamated with TFCIL by order of the Hon’ble Calcutta High Court dated 23.10.2010. By virtue of the scheme of amalgamation, the Assessee was allotted on 23.12.2010, 38 shares of TFCIL against 1 share of HDPL and credited to his demat a/c. (ii) The Assessee laid special

D.C.I.T., CIRCLE-1, DIBRUGARH vs. PRAMOD KUMAR BAMALWA, DIBRUGARH

In the result, all the appeals of the Revenue are dismissed and that of the Cross Objections of the assessees are allowed

Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Rajesh Kumar

transfer, the shares were sent to his demat a/c for credit. HDPL was amalgamated with TFCIL by order of the Hon’ble Calcutta High Court dated 23.10.2010. By virtue of the scheme of amalgamation, the Assessee was allotted on 23.12.2010, 38 shares of TFCIL against 1 share of HDPL and credited to his demat a/c. (ii) The Assessee laid special

D.C.I.T., CIRCLE-1, DIBRUGARH vs. VINAY BAMALWA, DIBRUGARH

In the result, all the appeals of the Revenue are dismissed and that of the Cross Objections of the assessees are allowed

Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Rajesh Kumar

transfer, the shares were sent to his demat a/c for credit. HDPL was amalgamated with TFCIL by order of the Hon’ble Calcutta High Court dated 23.10.2010. By virtue of the scheme of amalgamation, the Assessee was allotted on 23.12.2010, 38 shares of TFCIL against 1 share of HDPL and credited to his demat a/c. (ii) The Assessee laid special

D.C.I.T., CIRCLE-1, DIBRUGARH vs. RAVI BAMALWA, DIBRUGARH

In the result, all the appeals of the Revenue are dismissed and that of the Cross Objections of the assessees are allowed

Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Rajesh Kumar

transfer, the shares were sent to his demat a/c for credit. HDPL was amalgamated with TFCIL by order of the Hon’ble Calcutta High Court dated 23.10.2010. By virtue of the scheme of amalgamation, the Assessee was allotted on 23.12.2010, 38 shares of TFCIL against 1 share of HDPL and credited to his demat a/c. (ii) The Assessee laid special

D.C.I.T., CIRCLE-1, DIBRUGARH vs. MADAN LAL BAMALWA, DIBRUGARH

In the result, all the appeals of the Revenue are dismissed and that of the Cross Objections of the assessees are allowed

Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Rajesh Kumar

transfer, the shares were sent to his demat a/c for credit. HDPL was amalgamated with TFCIL by order of the Hon’ble Calcutta High Court dated 23.10.2010. By virtue of the scheme of amalgamation, the Assessee was allotted on 23.12.2010, 38 shares of TFCIL against 1 share of HDPL and credited to his demat a/c. (ii) The Assessee laid special

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1, DIBRUGARH vs. GREENPLY INDUSTRIES LIMITED, KOLKATA

In the result, the appeal of the Revenue is dismissed

Bench: Shri Rajesh Kumar, Am & Shrimanomohan Das, Jm Greenply Industries Ltd Acit, Circle-1 Madgul Lounge, 5 Th Floor, 23 Aaykar Bhawan, Milan Nagar, Chetiacental Road, Kolkata- Vs. Dibrugarh-786001, Assam 700027, West Bengal (Appellant) (Respondent) Pan No. Aaacg7284R Assessee By : Shri Ashok Tulsyan, Ar Revenue By : Shri Sanjay Jha, Dr Date Of Hearing: 02.12.2025 Date Of Pronouncement: 15.12.2025

Transfer Pricing Guidelines 2010 supports this view in para 7.13 where it is explained that where higher credit rating of Associated Enterprise is due to a guarantee by another group member, such association positively enhances the profit making potential of that Associated Enterprise. We, therefore, find ourselves in agreement with the contention of the Id. D.R. that there

ACCRECENT WAY MARKETING (P) LTD.,GUWAHATI vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-3, GUWAHATI

Bench: Shri Manomohan Das & Shri Rakesh Mishra

ii) Srinu Vnimay Private Limited (iii) Improve Vintrade P Limited and (iv) Sreeyukta Mercantile Pvt limited is a Director in 8(eight) other companies. 3.3 According to the Ld. AO, the above facts indicated that these companies were only letter box companies having no actual existence and were created only to give accommodation entries to some companies in the form