THE DCIT-1(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 -CIRCLE 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

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 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

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

1: 5. This ground is general and does not require any specific adjudication. Ground No. 2 to 19: 6. In these grounds, the assessee has challenged the transfer pricing adjustment of Rs. 37,69,02,830/- made by AO. 7. Apropos to this issue, the facts are such that the assessee-company was a wholly-owned subsidiary of “Covansys (Mauritius

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

1,06,99,464/- for A.Y. 10-11 and Rs. 3,21,61,710/- from A.Y. 11-12 may be deleted. 6.3.4. The learned Counsel for the assessee, also placed reliance in the case of Sonata Infra Technology Ltd. (2006) 75 SOT 465(Mum), Tata Consultancy Ltd. 271 ITR 401 , Lucent Technologies Institute 2009-TIOL_161-ITAT-DEL, Samsung Electronics

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

1,06,99,464/- for A.Y. 10-11 and Rs. 3,21,61,710/- from A.Y. 11-12 may be deleted. 6.3.4. The learned Counsel for the assessee, also placed reliance in the case of Sonata Infra Technology Ltd. (2006) 75 SOT 465(Mum), Tata Consultancy Ltd. 271 ITR 401 , Lucent Technologies Institute 2009-TIOL_161-ITAT-DEL, Samsung Electronics

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

1,06,99,464/- for A.Y. 10-11 and Rs. 3,21,61,710/- from A.Y. 11-12 may be deleted. 6.3.4. The learned Counsel for the assessee, also placed reliance in the case of Sonata Infra Technology Ltd. (2006) 75 SOT 465(Mum), Tata Consultancy Ltd. 271 ITR 401 , Lucent Technologies Institute 2009-TIOL_161-ITAT-DEL, Samsung Electronics

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

1,06,99,464/- for A.Y. 10-11 and Rs. 3,21,61,710/- from A.Y. 11-12 may be deleted. 6.3.4. The learned Counsel for the assessee, also placed reliance in the case of Sonata Infra Technology Ltd. (2006) 75 SOT 465(Mum), Tata Consultancy Ltd. 271 ITR 401 , Lucent Technologies Institute 2009-TIOL_161-ITAT-DEL, Samsung Electronics

MAHENDRA SINGH CHAWLA,INDORE vs. DCIT CIRCLE-1(1), INDORE

In the result, the appeal of the assessee is dismissed

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanimahendra Singh Chawla Dcit Circle -1(1) 4/35 Gram Pigdamber A.B. Indore Road Near Rao Vs. Indore (Appellant / Assessee) (Respondent/ Revenue) Pan: Aazpc0120C Assessee By None Shri Ashish Porwal, Sr. Dr Revenue By Date Of Hearing 02.09.2024 Date Of Pronouncement 04 .09.2024

price of the House. Thus, it is most humbly submitted that necessary directions be issued to the Ld. A.O. to compute the capital gain after allowing all the legitimate deductions as claimed by the appellant in the return of income. Now, the appellant is submitting the following documents in support of his explanation for deductions claimed while computing the chargeable

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

73 taxmann.com 248 (SC)(SLP dismissed). vii) Varad Mehta vs. DCIT (2019) 34 ITJ 125 (Indore Trib) Held “AO has merely mentioned the Section but the specific charge i.e. whether the penalty have been initiated for concealment of particulars of income or for furnishing inaccurate particulars of income has not been mentioned. Alleged notice issued u/s 272 r.w.s. 271(1

MAPAEX REMEDIES PVT LTD ,BHOPAL vs. THE DCIT -2- (1), BHOPAL , BHOPAL

Appeals are dismissed

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

price. P&G has constructed factory building on land and also installed plant and machinery. The plant and machinery does not belong to assessee but to P&G. Reimbursement of expenses is also made by P&G. The assessee is working for P&G, not for anybody else. These factors clearly show that the assessee is just an operator

MS MAPAEX REMEDIES PVT LTD,BHOPAL vs. ACIT 2 (1) BHOPAL, BHOPAL MADHYA PRADESH

Appeals are dismissed

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

price. P&G has constructed factory building on land and also installed plant and machinery. The plant and machinery does not belong to assessee but to P&G. Reimbursement of expenses is also made by P&G. The assessee is working for P&G, not for anybody else. These factors clearly show that the assessee is just an operator

MS MAPAEX REMEDIES PVT LTD,BHOPAL vs. ACIT 2 (1) BHOPAL, BHOPAL

Appeals are dismissed

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

price. P&G has constructed factory building on land and also installed plant and machinery. The plant and machinery does not belong to assessee but to P&G. Reimbursement of expenses is also made by P&G. The assessee is working for P&G, not for anybody else. These factors clearly show that the assessee is just an operator

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE - 5(1), BHOPAL , BHOPAL MADHYA PRADESH vs. MAPAEX REMEDIES PVT LTD, BHOPAL MADHYA PRADESH

Appeals are dismissed

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

price. P&G has constructed factory building on land and also installed plant and machinery. The plant and machinery does not belong to assessee but to P&G. Reimbursement of expenses is also made by P&G. The assessee is working for P&G, not for anybody else. These factors clearly show that the assessee is just an operator

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE -5(1), BHOPAL , BHOPAL, MADHYA PRADESH vs. MAPAEX REMEDIES PVT. LTD., BHOPAL MADHYA PRADESH

Appeals are dismissed

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

price. P&G has constructed factory building on land and also installed plant and machinery. The plant and machinery does not belong to assessee but to P&G. Reimbursement of expenses is also made by P&G. The assessee is working for P&G, not for anybody else. These factors clearly show that the assessee is just an operator

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 5 1, BHOPAL , BHOPAL MADHYA PRADESH vs. MAPAEX REMEDIES PVT LTD, BHOPAL MADHYA PRADESH

Appeals are dismissed

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

price. P&G has constructed factory building on land and also installed plant and machinery. The plant and machinery does not belong to assessee but to P&G. Reimbursement of expenses is also made by P&G. The assessee is working for P&G, not for anybody else. These factors clearly show that the assessee is just an operator

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