M/S. AGRAWAL COAL CORPORATION P. LTD.,INDORE vs. THE DCIT RANGE 1(1), INDORE

Bench: Shri D.T. Garasia & Shri O.P. Meena

transfer pricing documentation and economic analysis contained therein, passed an order dt.30.01.2013 for assessment year 2009-10 and dt. 28.01.2014 for assessment year 2010-11 u/s 92CA(3) of the Income-tax Act, 1961, therein determining the Arm’s length price margin in respect of Coal purchased from its AE at Rs. 9,73,14,004/- for assessment year

M/S. AGRAWAL COAL CORPORATION P. LTD.,INDORE vs. THE DCIT -CIRCLE 1(1), INDORE

Bench: Shri D.T. Garasia & Shri O.P. Meena

transfer pricing documentation and economic analysis contained therein, passed an order dt.30.01.2013 for assessment year 2009-10 and dt. 28.01.2014 for assessment year 2010-11 u/s 92CA(3) of the Income-tax Act, 1961, therein determining the Arm’s length price margin in respect of Coal purchased from its AE at Rs. 9,73,14,004/- for assessment year

THE DCIT-1(1), INDORE vs. M/S. AGRAWAL COAL CORPORATION P. LTD., INDORE

Bench: Shri D.T. Garasia & Shri O.P. Meena

transfer pricing documentation and economic analysis contained therein, passed an order dt.30.01.2013 for assessment year 2009-10 and dt. 28.01.2014 for assessment year 2010-11 u/s 92CA(3) of the Income-tax Act, 1961, therein determining the Arm’s length price margin in respect of Coal purchased from its AE at Rs. 9,73,14,004/- for assessment year

COMPUTER SCIENCES CORPORATION INDIA PRIVATE LIMITED,CHENNAI vs. ACIT, CHENNAI

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaniassessment Year: 2007-08 Computer Sciences Acit, Corporation India Private Company Circle 1(3), Limited, Chennai [Formerly Covansys (India) Private Limited], बनाम/ Unit 13, Block 2, Sdf Buildings, Vs. Madras Export Processing Zone, Tambaram, Chennai (Assessee / Appellant) (Revenue / Respondent) Pan: Aaacc1351M Assessee By Shri Neeraj Jain, Adv. Shri Abhishek Agrawal, Ca Revenue By Shri P.K. Mishra, Cit Dr Date Of Hearing 12.07.2023 Date Of Pronouncement

addition to the returned income on account of Transfer Pricing adjustment is only a notional income and not actual earned

M/S NIKHIL ESTATE P LTD,INDORE vs. THE ACIT CENTRAL CIRCLE (3) INDORE, INDORE

In the result, appeal of assessee is allowed

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanim/S. Nikhil Estate Pvt. Ltd. Acit (Central)-3 M-102, Mezzanine, Floor, Indore Dhan Trident, P. No.B-3 Pu- Vs. 4, Sch. No.54, Vijay Nagar Square, Indore (Appellant / Assessee) (Respondent/ Revenue) Pan: Aabcn 8056 D Assessee By Shri S.S. Solanki, Ar Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 01.05.2023 Date Of Pronouncement 09.06.2023

price but on the basis of Delhi rates which are universally accepted on higher side. Therefore since no defects were pointed out in the books of accounts regularly maintained by the assessee and are duly audited and no incriminating material was found in the search to show that unaccounted investment in the building project has been made, addition made purely

M/S SUPREMO INDIA LTD ,INDORE vs. THE AIT CENTRAL 3, INDORE

In the result, appeal of assessee is allowed

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanim/S. Supremo India Pvt. Ltd. Acit Central-3 400/2, Halka Patwari No.52 Indore Vs. Badiakeema Dudhiya, B.O. Indore (Appellant / Assessee) (Respondent/ Revenue) Pan: Aafcs 9822 C Assessee By Shri S.S. Solanki, Ar Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 01.05.2023 Date Of Pronouncement 07.06.2023

additional income as business income in his return of income and paid due taxes thereon. During the course of assessment proceedings, the Assessing officer has specifically taken cognizance of these facts, as apparent on the face of the assessment order, that assessee has voluntarily surrendered Rs 1,02,00,000/- over and above the normal business income in his return

THE ACIT, - 4(1), INDORE vs. M/S. YASH TECHNOLOGIES PVT. LTD., INDORE

In the result appeal of the revenue is dismissed

Bench: Hon'Ble Kul Bharat & Hon'Ble Manish Boradassessment Year 2014-15 Pan : Aaacy1868M

pricing. (ii) The A.O. violated the income tax provisions and made addition which were not in his power. Adjustment in salary between Non SEZ and SEZ is a specified domestic transaction u/s 92BA clause (v) of the Income Tax Act, 1961, and a subject matter of transfer

M/S ANDRITZ HYDRO PRIVATE LIMITED (EARLIER KNOWN AS V A TECH HYDRO INDAI PVT. LTD.),MANDIDEEP vs. THE ACIT 1(1), BHOPAL

In the result, grounds taken by the assessee in all the years with respect to provision of warranty are allowed

Bench: Shri D.T. Garasia & Shri O.P. Meena

Income-Tax Rules, 1962 . c) Applying CUP method for determining the arm`s length price in respect of appellant`s international transactions without identifying any comparable uncontrolled transaction(s) for the computation of arm`s length price which is not in accordance with Rule 10B(1)(a) d) Questioning the commercial rationale of the legitimate business expense incurred

M/S. ANDRITZ HYDRO PRIVATE LIMITED (EARLIER KNOWN AS VA TECH HYDRO INDIA PRIVATE LIMITED),BHOPAL vs. THE DCIT 1(1), BHOPAL

In the result, grounds taken by the assessee in all the years with respect to provision of warranty are allowed

Bench: Shri D.T. Garasia & Shri O.P. Meena

Income-Tax Rules, 1962 . c) Applying CUP method for determining the arm`s length price in respect of appellant`s international transactions without identifying any comparable uncontrolled transaction(s) for the computation of arm`s length price which is not in accordance with Rule 10B(1)(a) d) Questioning the commercial rationale of the legitimate business expense incurred

THE DCIT, 1(1), BHOPAL vs. M/S. ANDRITZ HYDRO PVT. LTD., RAISEN

In the result, grounds taken by the assessee in all the years with respect to provision of warranty are allowed

Bench: Shri D.T. Garasia & Shri O.P. Meena

Income-Tax Rules, 1962 . c) Applying CUP method for determining the arm`s length price in respect of appellant`s international transactions without identifying any comparable uncontrolled transaction(s) for the computation of arm`s length price which is not in accordance with Rule 10B(1)(a) d) Questioning the commercial rationale of the legitimate business expense incurred

THE ACIT, 1(1), BHOPAL vs. M/S. ANDRITZ HYDRO PVT. LTD., RAISEN

In the result, grounds taken by the assessee in all the years with respect to provision of warranty are allowed

Bench: Shri D.T. Garasia & Shri O.P. Meena

Income-Tax Rules, 1962 . c) Applying CUP method for determining the arm`s length price in respect of appellant`s international transactions without identifying any comparable uncontrolled transaction(s) for the computation of arm`s length price which is not in accordance with Rule 10B(1)(a) d) Questioning the commercial rationale of the legitimate business expense incurred

THE ACIT,CENTRAL-1, INDORE vs. M/S PRAKASH OILS LTD., DHAR

In the result, the above captioned appeals filed by the Revenue as well as the

Bench: Shri C.M. Garg & Shri Bhagirath Mal Biyani

transfer pricing is concerned with the determination of Arm’s Length Price of the specified domestic transactions carried out by the assessee with its AE. The ld.CIT-DR drawing our attention to the order of the TPO, submitted that the ld. First appellate authority has erred in rejecting the TPO’s approach of adopting the Transactional Net Margin Method (TNMM

THE ACIT ,CENTRAL-1, INDORE vs. M/S PRAKASH OILS LTD., DHAR

In the result, the above captioned appeals filed by the Revenue as well as the

Bench: Shri C.M. Garg & Shri Bhagirath Mal Biyani

transfer pricing is concerned with the determination of Arm’s Length Price of the specified domestic transactions carried out by the assessee with its AE. The ld.CIT-DR drawing our attention to the order of the TPO, submitted that the ld. First appellate authority has erred in rejecting the TPO’s approach of adopting the Transactional Net Margin Method (TNMM

THE ADDL. CIT RANGE -1, INDORE vs. M/S PRAKASH OILS LTD., DHAR

In the result, the above captioned appeals filed by the Revenue as well as the

Bench: Shri C.M. Garg & Shri Bhagirath Mal Biyani

transfer pricing is concerned with the determination of Arm’s Length Price of the specified domestic transactions carried out by the assessee with its AE. The ld.CIT-DR drawing our attention to the order of the TPO, submitted that the ld. First appellate authority has erred in rejecting the TPO’s approach of adopting the Transactional Net Margin Method (TNMM

M/S ANDRITZ HYDRO PRIVATE LIMITED,BHOPAL vs. THE DCIT CIRCLE 1(1), BHOPAL

In the result, appeal of assessee is allowed for statistical purpose

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanim/S. Andritz Hydro Private Dcit Circe 1(1) Ltd. Bhopal Vs. D-17, Mpakvn Industrial Area, Mandideep Raisen (Appellant / Assessee) (Respondent/ Revenue) Pan: Aabcv 2466 R Assessee By Shri Rahul, Kaul Ar Revenue By Shri P.K. Mishra, Cit-Dr Date Of Hearing 13.06.2023 Date Of Pronouncement 28.08.2023

addition is proposed to the income as a result of transfer pricing review. 4.4 Ld. AR has referred to the technology

SHRI DHARMENDRA KUMAR CHOUDHARY,GWALIOR vs. THE DCIT 1(1), BHOPAL

In the result these bunch of fourteen appeals of the assessee’s for Assessment Year 2009-10 are partly allowed for statistical purposes

Bench: Hon'Ble Kul Bharat & Hon'Ble Manish Borad

transfer of funds between the buyers and the sellers were found. The land was purchased at a price higher than the Guide Line Price fixed by the Collector. The land was un-diverted agricultural land and considering the location and the status of the land, it did not command such price as opined by the A.O. Under these circumstances

SHRI RAMESH CHANDRA PARASHAR,GWALIOR vs. THE DCIT 1(1), BHOPAL

In the result these bunch of fourteen appeals of the assessee’s for Assessment Year 2009-10 are partly allowed for statistical purposes

Bench: Hon'Ble Kul Bharat & Hon'Ble Manish Borad

transfer of funds between the buyers and the sellers were found. The land was purchased at a price higher than the Guide Line Price fixed by the Collector. The land was un-diverted agricultural land and considering the location and the status of the land, it did not command such price as opined by the A.O. Under these circumstances

THE ACIT- 1(1), BHOPAL vs. SHRI VINOD VAISH, BHOPAL

In the result these bunch of fourteen appeals of the assessee’s for Assessment Year 2009-10 are partly allowed for statistical purposes

Bench: Hon'Ble Kul Bharat & Hon'Ble Manish Borad

transfer of funds between the buyers and the sellers were found. The land was purchased at a price higher than the Guide Line Price fixed by the Collector. The land was un-diverted agricultural land and considering the location and the status of the land, it did not command such price as opined by the A.O. Under these circumstances