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

2) of the Income Tax Act, 1961 was issued to the assessee on 01.08.2012 which was duly served to the assessee. The case was referred to the Transfer Pricing Officer (TPO) as the Assessing Officer noticed that the assessee has entered into international transactions with it’s associated concerns. The TPO vide order dated 01.01.2015 under Section 92CA(3) made

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

2. The ld. AO and Hon'ble DRP Members have erred in law and facts by upholding the action of the Ld. TPO wherein the Ld. TPO has erred in law and in facts, for not providing any reasons for disregarding the assessee’s approach of determining the arm’s length price at an entity level in the Transfer Pricing

M/S. BHATIA GLOBAL TRADING LTD.,INDORE vs. THE DCIT 1(1), INDORE

In the result, appeal of assessee is partly allowed

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanibhatia Global Trading Ltd. Dcit 1(1) Through Official Liquidator Indore Old Cia Building, 1St Floor Vs. Opp. G.P.O. Residency Area, Indore (Appellant / Assessee) (Respondent/ Revenue) Pan: Aaacb6751 C Assessee By None Revenue By Shri P.K. Mishra, Cit-Dr Date Of Hearing 10.05.2023 Date Of Pronouncement 26 .07.2023

transfer pricing regulations 5. The TPO rejected the TP Study analysis of the assesse and carried out his own search for selecting comparable for determination of arm’s length price. The TPO selected three comparable companies for determination of arm’s length price against which the assessee has raised objection before the DRP which are reproduced

THE ACIT, CIRCLE 2(1), INDORE vs. DR. SHRI RAJEEV CHAUDHARY, INDORE

In the result, the appeal of the revenue is allowed and cross objection of the assessee is partly allowed

Bench: Hon'Ble I Kul Bharat & Hon'Ble Manish Boradassessment Year 2008-09 Pan : Abkpc5729K Assistant Commissioner Of V/S Dr.Rajeev Choudhary Income Tax, 1, Shiv Vilas Palace Circle-2(1), Indore Indore

price, without anything more, is consistent with the realization of capital investment and surplus received by the assessee will not be trading or business profit. 02. That the learned CIT(A) has confirmed the disallowance made by the learned AO of Rs. 2,15,542/- by invoking the provision of section 14A to be read with Rule

DEPUTY COMMISSIONER OF INCOME TAX - 3(1), INDORE vs. SHRI RAJEEV AJMERA, INDORE

In the result, the appeal of Revenue is partly allowed for statistical purposes

Bench: Ms.Suchitra Kamble & Shrib.M. Biyani(Conducted Through Virtual Court) Assessment Year: 2010-11 Dcit-3(1) Shri Rajeev Ajmera, Indore बनाम/ Indore Vs. (Appellant / Assessee) (Respondent / Revenue) Pan: Abgpa4930L Co No.23/Ind/2018 (Arising Out Of Ita No.51/Ind/2018) Assessment Year: 2010-11 Shri Rajeev Ajmera, Dcit-3(1) Indore Indore बनाम/ Vs. (Appellant / Assessee) (Respondent / Revenue) Pan: Abgpa4930L Assessee By Shri Mahendra Mittal, Ar Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 23.08.2022 Date Of Pronouncement 31.08.2022 आदेश/ O R D E R

14A was clearly applicable on assessee's investment in shares and mutual fund wherefrom income was exempt.” Page 2 of 17 Shri Rajeev Ajmera ITA No.51/Ind/2018& CO.No.23/Ind/2018 Assessment year 2010-11 Ground No. 1: 5. In this Ground, the issue involved is the deduction of commission- expenditure of Rs. 1,74,50,000/- claimed by the assessee. 6. Facts

M/S. BHANDARI HOSPITAL AND RESEARCH CENTRE,INDORE vs. THE PR. CIT-1, INDORE

Bench: Shri Kul Bharat & Shri Manish Boradassessment Year: 2012-13 M/S Bhandari Hospital & Pr. Cit-(I) Research Centre, Gf-21 & Indore बनाम/ 22, Opp. Meghdoot Garden, Vs. Vijay Nagar, Indore (Appellant) (Revenue ) P.A. No.Aadfb8151A

transferred to another AO u/s 127 who then issued notice u/s 142(1) on 29/7/2014. (copy of this notice is on pages 108-109 of the paper book). This was a comprehensive notice requiring compliance of various issues. viii. Reply was filed by the assessee on 12.8.2014 (placed on page 110- 116 of the apper book) with all relevant information

M/S. S.R. FERRO ALLOYS,JHABUA vs. THE PCIT, BHOPAL

In the result, the appeal of assessee is allowed

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanis.R. Ferro Alloys Pr. Cit, Central 9, Siddheswar Colony Bhopal Vs. Jhabua (Appellant / Assessee) (Revenue) Pan: Abhfs7377Q Appellant By Shri Sumit Nema, Sr. Adv. & Gagan Tiwari, Ar Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 12.10.2023 Date Of Pronouncement 09.11.2023

price. A method of accounting adopted by the trader consistently and regularly cannot be discarded by departmental authorities on the view that he should have adopted a different method of keeping accounts or of valuation. The method of accounting regularly employed may be discarded only, if, in the opinion of taxing authorities, income of the trade cannot be property Page

SEWA SAHKARI SAMMITTEE MARYADIT,BEED, MUNDI KHANDWA vs. PCIT-1, INDORE

In the result, appeal by the assesse is allowed

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanisewa Sahkari Sammittee Pr. Cit-2 Maryadit Beed Indore Vs. Beed Mundi Khandwa (Appellant / Assessee) (Revenue) Pan: Aaufs0703N Assessee By Shri Gagan Tiwari, Ar Revenue By Ms. Simran Bhullar, Cit-Dr Date Of Hearing 05.10.2023 Date Of Pronouncement 30.10.2023

price (MSP Samarthan Mulya) & other source is sale of fertilizers to farmers. (2) Please furnish the copy of following documents/detail for the AY 2016-17 (i.e. FY 2015-16). • Income Tax Return Attached for your reference • Computation of Income Attached for your reference Audit report with all annexure Attached for your reference ⚫ Profit & Loss A/c (With Schedule) Attached for your

DECENT INDUSTRIES P. LTD.,BHOPAL vs. ITO-1(2), BHOPAL

Appeal is partly allowed

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani(Virtual Hearing) Assessment Year: 2012-13 M/S Decent Industries Ito-1(2), Private Ltd, Bhopal 5Th Floor, Corporate Park, बनाम/ Db City Area Hills, Vs. Opp. M.P. Nagar Zone I, Bhopal (Assessee/Appellant) (Revenue/Respondent) Pan: Aaeca6271G Assessee By Ms. Shilpa Gupta & Shri N.K. Gupta Revenue By Shri V.K. Singh, Cit-Dr Date Of Hearing 04.06.2024 Date Of Pronouncement 20.08.2024

price of Rs. 1,000/- (inclusive of premium of Rs. 990/- per share) to two ‘Kolkata-based shell companies’ named M/s Ajay Software Pvt. Ltd. [“A”] and M/s Jay Hind Financial Advisors Ltd. [“J”] on 31.03.2012 and received proceeds of Rs. 66,91,70,000/- in financial year 2011-12 relevant to AY 2012-13 under consideration. The details

ACIT (CENTRAL UJJAIN, UJJAIN vs. M/S ARIHANT FUTURE AND COMMODITIES LTD, INDORE

Bench: Shri Mahavir Prasad, Judicialmember & Shri Manish Boradvirtual Hearing &

section 14A of Rs. 5,01,070/- and made remark for the same that this should be disallowed; and that, the assessee has filed and relied upon the said audit report, thus, clearly justifying the nature of addition made by the Assessing Officer u/s 14A of the Income Tax Act, 1961. 5. On the facts and in the circumstances

THE ACIT ,CENTRAL-UJJAIN, INDORE vs. M/S ARIHANT CAPITALS MARKETS LTD , INDORE

Bench: Shri Mahavir Prasad, Judicialmember & Shri Manish Boradvirtual Hearing &

section 14A of Rs. 5,01,070/- and made remark for the same that this should be disallowed; and that, the assessee has filed and relied upon the said audit report, thus, clearly justifying the nature of addition made by the Assessing Officer u/s 14A of the Income Tax Act, 1961. 5. On the facts and in the circumstances

THE ACIT, CENTRAL - UJJAIN, INDORE vs. M/S ARIHANT FUTURE & COMMADITIES LTD , INDORE

Bench: Shri Mahavir Prasad, Judicialmember & Shri Manish Boradvirtual Hearing &

section 14A of Rs. 5,01,070/- and made remark for the same that this should be disallowed; and that, the assessee has filed and relied upon the said audit report, thus, clearly justifying the nature of addition made by the Assessing Officer u/s 14A of the Income Tax Act, 1961. 5. On the facts and in the circumstances

AG-8 VENTURES LTD.,BHOPAL vs. ACIT, CENTRAL-1, BHOPAL

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

14A r.w.r. 8D of the Income Tax Rule. 5. Following grounds have been raised by the assessee:- IT(SS)A 90/ Ind/ 2019 A.Y. 2013-14 1. The order passed u/s. 153A/ 143(3) by lower authorities is illegal, invalid, and untenable in law. The same be kindly cancelled 2. On the facts and in the circumstances of the case

AG-8 VENTURES LTD.,BHOPAL vs. ACIT, CENTRAL-1, BHOPAL

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

14A r.w.r. 8D of the Income Tax Rule. 5. Following grounds have been raised by the assessee:- IT(SS)A 90/ Ind/ 2019 A.Y. 2013-14 1. The order passed u/s. 153A/ 143(3) by lower authorities is illegal, invalid, and untenable in law. The same be kindly cancelled 2. On the facts and in the circumstances of the case

THE ACIT 4(1), INDORE vs. M/S SUYASH EXIM P LTD , INDORE

Accordingly, departmental grounds with regard to addition of Rs.1,81,847/- are dismissed

Bench: Shri Mahavir Prasad & Shri Manish Borad(Virtual Hearing) Assessment Year: 2011-12

Transfer Pricing-Draft assessment order Draft assessment order passed without disposing of objections filed 7 Suyash Exim ITA 356 of 2020 and CO 19 of 2021 by assessee to reasons for reopening assessment- Unsustainable - Income Tax Act, 1961, section 147.” 8. We find that during the year under consideration, the assessee was engaged in the business of trading of forward

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

14A of the Act from 38,90,444/- to Rs.7,481/-. 2.Whether on the facts and in the circumstances of the case and in law, the Ld. CIT(A) was justified in deleting the addition on account of unsecured loan amounting to Rs.69,00,000/- and interest thereon of Rs.51,93,162/-. The appellant craves leave to add or deduct

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

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

14A of the Act from 38,90,444/- to Rs.7,481/-. 2.Whether on the facts and in the circumstances of the case and in law, the Ld. CIT(A) was justified in deleting the addition on account of unsecured loan amounting to Rs.69,00,000/- and interest thereon of Rs.51,93,162/-. The appellant craves leave to add or deduct

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

14A of the Act from 38,90,444/- to Rs.7,481/-. 2.Whether on the facts and in the circumstances of the case and in law, the Ld. CIT(A) was justified in deleting the addition on account of unsecured loan amounting to Rs.69,00,000/- and interest thereon of Rs.51,93,162/-. The appellant craves leave to add or deduct