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

133(6) of the Act by the AO were duly complied and represented before the AO during the assessment proceedings. This fact has also not been controverted by the ld.CIT-DR. From the assessment order, we observe that the main allegation of the AO was that the assessee has incurred only losses on NMCE which are artificial losses through synchronized

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

Transfer Pricing order. 3. The ld. AO and Hon'ble DRP Members have erred in law and facts by rejecting the entity wide operating profit margin and by bifurcating the single transaction involving provision of software development services on a unit wise basis for computing arm’s length price. 4. The ld. AO and Hon'ble DRP Members have erred

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 adjustment of Rs. 9, 73, 14,004/- made by TPO is hereby deleted.” M/s. Agrawal Coal Corporation vs. DCIT and DCIT Vs. Agrawal Coal Corporation T.P.A. Nos.601 & 602/Ind/2015 and 607 & 622/Ind/2015/A.Y.2009-10 & 10-11Page 74 of 127 2.5.9. We have given our careful thoughts to above findings and fully subscribe the same. In the light of the above

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

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

transfer pricing adjustment of Rs. 9, 73, 14,004/- made by TPO is hereby deleted.” M/s. Agrawal Coal Corporation vs. DCIT and DCIT Vs. Agrawal Coal Corporation T.P.A. Nos.601 & 602/Ind/2015 and 607 & 622/Ind/2015/A.Y.2009-10 & 10-11Page 74 of 127 2.5.9. We have given our careful thoughts to above findings and fully subscribe the same. In the light of the above

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 adjustment of Rs. 9, 73, 14,004/- made by TPO is hereby deleted.” M/s. Agrawal Coal Corporation vs. DCIT and DCIT Vs. Agrawal Coal Corporation T.P.A. Nos.601 & 602/Ind/2015 and 607 & 622/Ind/2015/A.Y.2009-10 & 10-11Page 74 of 127 2.5.9. We have given our careful thoughts to above findings and fully subscribe the same. In the light of the above

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 adjustment of Rs. 9, 73, 14,004/- made by TPO is hereby deleted.” M/s. Agrawal Coal Corporation vs. DCIT and DCIT Vs. Agrawal Coal Corporation T.P.A. Nos.601 & 602/Ind/2015 and 607 & 622/Ind/2015/A.Y.2009-10 & 10-11Page 74 of 127 2.5.9. We have given our careful thoughts to above findings and fully subscribe the same. In the light of the above

DCIT-4(1), INDORE vs. M/S. YAKSHA INFRASTRUCTURE COM. PVT. LTD., TALOJA, RAIGARH

Appeal is dismissed

Bench: Ms. Madhumita Roy & Shri Bhagirath Mal Biyani

transfer of shares by the assessee is in the name of NSIL Infotech Ltd. and NSIL Power Ltd. There is no doubt that such transactions were related to sale of shares of Mid India Steel & Power Ltd. by the assessee to NSIL Infotech Ltd. and NSIL Power Ltd. which took place only in A.Y.2010-2011. The Ld. DR at the time

YAKSHA INFRASTRUCTURE COMPANY (P) LTD. (FORMERLY KNOWN FROLIC REALTY (P) LTD.),MUMBAI vs. DCIT-3(1) , INDORE

Appeal is dismissed

Bench: Ms. Madhumita Roy & Shri Bhagirath Mal Biyani

transfer of shares by the assessee is in the name of NSIL Infotech Ltd. and NSIL Power Ltd. There is no doubt that such transactions were related to sale of shares of Mid India Steel & Power Ltd. by the assessee to NSIL Infotech Ltd. and NSIL Power Ltd. which took place only in A.Y.2010-2011. The Ld. DR at the time

M/S TESLA TRANSFORMERS ,BHOPAL vs. ITO(INTERNATIONAL TAXATION),, BHOPAL

In the result, Ground Numbers 1 to 4 of assessee’s appeal are dismissed

133(6) of the Act, ABB India Ltd has completely denied any role at the India level on acting on behalf on the non-resident entity, the facts placed on record by the AR of the assessee during the course of 201 proceedings are completely different. Hence, the statement of ABB India Ltd also cannot be relied upon

HARPREET KAUR,BHOPAL vs. INCOME-TAX OFFICER, 5(2), BHOPAL, BHOPAL

Appeal is allowed in terms mentioned above

133(6) of the\n'Act' as well as while making statement u/s 131 of the 'Act' although it\nwas not found fully convincible but from the facts so surfaced it is\nevident that the buyer has not adequate source of fund to buy the\nproperty even at the consideration of Rs.4,10,000/-". If that be the\ncase

THE DCIT1(1), INDORE vs. M/S. AVILABLE FINANCE LTD., INDORE

Bench: Hon’Ble Kul Bharat & Hon’Ble Manish Boradassessment Year 2010-11

transferred to the assessee i.e. M/s. Agrawal Transport Corporation Ltd. Thus the source of source is proved on record. Ld. Counsel for the assessee further submitted that the assessments in the case of M/s. Chamak Traxim Pvt. Ltd for Assessment Years 2009-10 to 2012-13 have been completed after the search on Mr. Deepak Kalani and after considering

M/S AD-MANUM FINANCE LTD.,INDORE vs. THEDCIT 1(1) , INDORE, INDORE

Bench: Hon’Ble Kul Bharat & Hon’Ble Manish Boradassessment Year 2010-11

transferred to the assessee i.e. M/s. Agrawal Transport Corporation Ltd. Thus the source of source is proved on record. Ld. Counsel for the assessee further submitted that the assessments in the case of M/s. Chamak Traxim Pvt. Ltd for Assessment Years 2009-10 to 2012-13 have been completed after the search on Mr. Deepak Kalani and after considering

DY. CIT -1(1), INDORE vs. M/S. AGRAWAL TRANSPORT CORPORATION (P) LTD., INDORE

Bench: Hon’Ble Kul Bharat & Hon’Ble Manish Boradassessment Year 2010-11

transferred to the assessee i.e. M/s. Agrawal Transport Corporation Ltd. Thus the source of source is proved on record. Ld. Counsel for the assessee further submitted that the assessments in the case of M/s. Chamak Traxim Pvt. Ltd for Assessment Years 2009-10 to 2012-13 have been completed after the search on Mr. Deepak Kalani and after considering

CUMMINS TECHNOLOGIES INDIA (P) LTD.,DEWAS vs. ACIT CIRCLE 1(1), UJJAIN

In the result, the appeal of the assesse is allowed

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanicommins Technologies India Acit, Circle -1(1) Private Limited Ujjain Vs. Industrial Area No.2, A.B. Road, M.P. (Appellant / Assessee) (Revenue) Pan: Aabct2018B Assessee By Shri Ketan Ved & Pinkesh Vakharia Ars Revenue By Ms. Simran Bhullar, Cit-Dr Date Of Hearing 29.11.2023 Date Of Pronouncement 30.11.2023

transfer pricing adjustment has been made on account of difference of opinion, interpretation of provisions of law, etc. and not due to any concealment of or furnishing of inaccurate particulars of income by the Appellant.” 2. The assessee has also filed additional grounds of appeal vide application dated 14th August 2023. The additional grounds of appeal are as under: “Ground

M/S. COMPUTER SCIENCE CORPORATION INDIA PVT. LTD.,CHENNAI vs. THE ACIT-CIRCLE 2(1), INDORE

In the result, all the three appeals are partly allowed for statistical purpose and the Stay Application is also disposed of

Bench: Ms. Suchitra Kamble & Shri Bhagirath Mal Biyani

transfer pricing study. 4.5 conducting fresh search by rejecting the objections raised by the appellant in relation to selection/rejection/modification of filters or inconsistency in application of filter/s. 4.6 using information obtained under section 133(6

M/S. COMPUTER SCIENCES CORPORATION INDIA PRIVATE LIMITED,INDORE vs. THE ASST. COMMISSIONER OF INCOME TAX-2(1), INDORE

In the result, all the three appeals are partly allowed for statistical purpose and the Stay Application is also disposed of

Bench: Ms. Suchitra Kamble & Shri Bhagirath Mal Biyani

transfer pricing study. 4.5 conducting fresh search by rejecting the objections raised by the appellant in relation to selection/rejection/modification of filters or inconsistency in application of filter/s. 4.6 using information obtained under section 133(6

M/S. COMPUTER SCIENCE CORPORATION INDIA PVT. LTD.,CHENNAI vs. DEPUTY COMMISSIONER OF INCOME TAX-CIRCLE 2(1) , INDORE

In the result, all the three appeals are partly allowed for statistical purpose and the Stay Application is also disposed of

Bench: Ms. Suchitra Kamble & Shri Bhagirath Mal Biyani

transfer pricing study. 4.5 conducting fresh search by rejecting the objections raised by the appellant in relation to selection/rejection/modification of filters or inconsistency in application of filter/s. 4.6 using information obtained under section 133(6

CHIRAYU CHARITABLE FOUNDATION,BHOPAL vs. PCIT (CENTRAL), BHOPAL

In the result appeal of the assessee stands allowed

Bench: Hon'Ble Kul Bharat & Hon'Ble Manish Boradchirayu Charitable Pcit (Central), Foundation,Bhopal Indore Bhopal Highway, Bhaisakhedi, Vs. Bhopal (Appellant) (Revenue ) Pan No.Aaaac3656P Revenue By Shri S.S. Mantri, Cit Appellant By S/Shri Sumit Nema, Sr. Advocate, Gagan Tiwari & Piyush Parashar, Advs Date Of Hearing 05.01.2021 Date Of Pronouncement .02.2021 O R D E R Per Manish Borad, Am.

transferred to the groups donation account through a journal entry passed on 29.8.2011. The assessment of the assessee was completed u/s 143(3) of the Act for Assessment Year 2011-12 on 18.3.2014 in normal course and during the course of proceedings confirmation of loan creditors were filed, copy of bank account of M/s Riviera Infoway Ltd along with