THE DCIT1(1), INDORE vs. M/S. AGRAWAL COAL CORPORATION P LTD., INDORE

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

Section 92(1) of the Act states that – “Any income arising from an international transaction shall be computed having regard to the arm’s length price…” Further, Sec 92C (1) of the Act states that – “The arm’s length price in relation to an international transaction or specified domestic transaction shall be determined by any of the following methods, being

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

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

Section 92(1) of the Act states that – “Any income arising from an international transaction shall be computed having regard to the arm’s length price…” Further, Sec 92C (1) of the Act states that – “The arm’s length price in relation to an international transaction or specified domestic transaction shall be determined by any of the following methods, being

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

transfer provisions could apply if the aggregate of such transactions entered into by the assessee in the previous year exceeds a sum of Rs.5 crores. But in the instant case the specified domestic pricing figure is Rs.3,46,13,572/- which is less than Rs.5 crores hence the provision of Section 92BA of the Act does not apply

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 proceedings of subsequent year i.e. AY 2016-17 has also been since completed by the TP0-2, Ahemdabad, where-in the CUP method adopted by the appellant company has been accepted as the most appropriate method. Copy of the order passed by the TPO for AY’s 2013- 14, 2014-15 and 2016-17 is enclosed at page

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 proceedings of subsequent year i.e. AY 2016-17 has also been since completed by the TP0-2, Ahemdabad, where-in the CUP method adopted by the appellant company has been accepted as the most appropriate method. Copy of the order passed by the TPO for AY’s 2013- 14, 2014-15 and 2016-17 is enclosed at page

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 proceedings of subsequent year i.e. AY 2016-17 has also been since completed by the TP0-2, Ahemdabad, where-in the CUP method adopted by the appellant company has been accepted as the most appropriate method. Copy of the order passed by the TPO for AY’s 2013- 14, 2014-15 and 2016-17 is enclosed at page

ACIT-2(1), UJJAIN, UJJAIN vs. M/S RUCHI J OIL PVT. LTD,, MUMBAI

In the result, Revenue’s appeal ITANo

Bench: Shri Mahavir Prasad & Shri Manish Boradvirtual Hearing Assessment Year: 2014-15

Transfer Pricing Officer (TPO) and stated that the TPO has considered purchase of undertaking by way of slump sale from Ruchi Soya Industries Ltd. as a Specified Domestic Transaction. ii) Thereafter, in para 5.5.2 of the order the AO stated “Therefore, the order of Ld. TPO u/s 92CA as regards valuation of the above transaction and the categorization

THE ACIT, CENTRAL-1, INDORE vs. M/S. MANISH AGRO TECH PVT. LTD., INDORE

In the result grounds of revenue for A

Bench: Shri Chandra Mohan Garg & Shri Bhagirath Mal Biyani

transfer pricing proceedings. Whenever a notice was received from the TPO, it was forwarded to the counsel at Ahmedabad. Cross Objection Nos.5 & 6/Ind/2020 Assessment Years: 2012-13 & 2015-16 4.8. The appellant had filed substantial documents for vindicating its transactions held with sister concern. This is also evident from the written submission filed before the TPO, copies enclosed at page

THE ACIT, CENTRAL-1, INDORE vs. M/S. MANISH AGRO TECH PVT. LTD., INDORE

In the result grounds of revenue for A

Bench: Shri Chandra Mohan Garg & Shri Bhagirath Mal Biyani

transfer pricing proceedings. Whenever a notice was received from the TPO, it was forwarded to the counsel at Ahmedabad. Cross Objection Nos.5 & 6/Ind/2020 Assessment Years: 2012-13 & 2015-16 4.8. The appellant had filed substantial documents for vindicating its transactions held with sister concern. This is also evident from the written submission filed before the TPO, copies enclosed at page

M/S SANGHVI FOODS P LTD, ,INDORE vs. ITO (IT & TP) , BHOPAL

In the result common issue raised in

Bench: Shri Kul Bharat & Shri Manish Borad

115-O. Explanation 1.—For the purposes of this section, where any interest or other sum as aforesaid is credited to any account, whether called "Interest payable account" or "Suspense account" or by any other name, in the books of account of the person liable to pay such income, such crediting shall be deemed to be credit of such income

M/S SANGHVI FOODS P LTD, ,INDORE vs. ITO (IT & TP) , BHOPAL

In the result common issue raised in

Bench: Shri Kul Bharat & Shri Manish Borad

115-O. Explanation 1.—For the purposes of this section, where any interest or other sum as aforesaid is credited to any account, whether called "Interest payable account" or "Suspense account" or by any other name, in the books of account of the person liable to pay such income, such crediting shall be deemed to be credit of such income

SHRI NARENDRA TRIPATHI,BHOPAL vs. THE DCIT-CENTRAL-1, BHOPAL

In the result the appeal of the assessee for Assessment Year

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

transfer by an assessee”. Thus the provision of Section 50C is primarily applicable on the seller of the property. There is no evidence on record which could show that the Ld. A.O carried out any investigation against the seller or took his/her statement or whether any addition has been made in the hands of the seller for the alleged amount

ACIT(CENTRAL)-1, INDORE vs. SHRI PUNIT AGRAWAL, MHOW

Appeals are dismissed

Bench: Shri Vijay Pal Rao & Shrib.M. Biyani

115 Lakhs in cash from Agroh (in short AIDPL) and in next financial year the appellant has accepted the cash loan of Rs. 3,66,25,000/- from M/s Agroh Infrastructure Developers Pvt. Ltd (In short AIDPL) and on other hand accepts the same to be cash- buyback of shares. The AO has also held that interest amounting

ACIT(CENTRAL)-1, INDORE vs. SHRI PUNIT AGRAWAL, MHOW

Appeals are dismissed

Bench: Shri Vijay Pal Rao & Shrib.M. Biyani

115 Lakhs in cash from Agroh (in short AIDPL) and in next financial year the appellant has accepted the cash loan of Rs. 3,66,25,000/- from M/s Agroh Infrastructure Developers Pvt. Ltd (In short AIDPL) and on other hand accepts the same to be cash- buyback of shares. The AO has also held that interest amounting

ACIT(CENTRAL)-1, INDORE vs. SHRI PUNIT AGRAWAL, MHOW

Appeals are dismissed

Bench: Shri Vijay Pal Rao & Shrib.M. Biyani

115 Lakhs in cash from Agroh (in short AIDPL) and in next financial year the appellant has accepted the cash loan of Rs. 3,66,25,000/- from M/s Agroh Infrastructure Developers Pvt. Ltd (In short AIDPL) and on other hand accepts the same to be cash- buyback of shares. The AO has also held that interest amounting

ACIT(CENTRAL)-1, INDORE vs. SHRI PUNIT AGRAWAL, MHOW

Appeals are dismissed

Bench: Shri Vijay Pal Rao & Shrib.M. Biyani

115 Lakhs in cash from Agroh (in short AIDPL) and in next financial year the appellant has accepted the cash loan of Rs. 3,66,25,000/- from M/s Agroh Infrastructure Developers Pvt. Ltd (In short AIDPL) and on other hand accepts the same to be cash- buyback of shares. The AO has also held that interest amounting

THE ACIT, (CENTRAL)-1, INDORE vs. M/S. PRAKASH ASHPHLTING & TOLL HIGHWAY LTD., INDORE

Appeals are dismissed

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

transferred from one side to another, addition under section 69C were not sustainable. Hon'ble Supreme Court in the case of Pr. CIT Vs. Vinita Chaurasia [2018] 98 Taxman.com 468 (SC) arising out of Order of HC in CIT Vs.VinitaChaurasia [2017] 82 Taxmann.com 153 dismissed the departmental SLP and affirm the very principle again that when a addition was made

ACIT(CENTRAL)-1, INDORE vs. SHRI PUNIT AGRAWAL, MHOW

Appeals are dismissed

Bench: Shri Vijay Pal Rao & Shrib.M. Biyani

115 Lakhs in cash from Agroh (in short AIDPL) and in next financial year the appellant has accepted the cash loan of Rs. 3,66,25,000/- from M/s Agroh Infrastructure Developers Pvt. Ltd (In short AIDPL) and on other hand accepts the same to be cash- buyback of shares. The AO has also held that interest amounting