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

35. Ld. D.R. vehemently argued supporting the orders of ld. Transfer Pricing Officer and the ld. Assessing Officer. 36. Per contra, ld. counsel for the assessee reiterated the submissions made before the ld. CIT(Appeals), the finding of the ld. CIT(Appeals) are also referred to the following decisions of Coordinate Benches determining the arm’s length guarantee fees within

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

Bench: Shri Manomohan Das & Shri Rakesh Mishra

iv) -Page 15-25 of the CIT(A) Order): I.T.A. No.: 358/GTY/2018 Assessment Year: 2010-11 Accrecent Way Marketing Private Limited. a) The primary onus is on the assessee to prove the identity and creditworthiness of the party and the genuineness of the transaction in respect of the cash credit in the books of account. b) The Appellant