ALMATIS ALUMINA PRIVATE LTD,KOLKATA vs. DCIT, CIRCLE-8(1), KOLKATA, KOLKATA

In the result, the instant appeals filed by the assessee are partly allowed

Bench: Sri Manish Borad & Sri Sonjoy Sarma

TDS made at Rs. 5,49,950/- assessing income at Rs. 12,32,25,170/-. Against the said additions, the assessee is in appeal before this Tribunal. For AY 2015-16 also similar type of adjustments have been made against which also the assessee is in appeal before this Tribunal. 5. At the outset, ld. Counsel for the assessee requested

ALMATIS ALUMINA PRIVATE LTD,KOLKATA vs. DCIT, CIRCLE - 8(1), KOLKATA, KOLKATA

In the result, the instant appeals filed by the assessee are partly allowed

Bench: Sri Manish Borad & Sri Sonjoy Sarma

TDS made at Rs. 5,49,950/- assessing income at Rs. 12,32,25,170/-. Against the said additions, the assessee is in appeal before this Tribunal. For AY 2015-16 also similar type of adjustments have been made against which also the assessee is in appeal before this Tribunal. 5. At the outset, ld. Counsel for the assessee requested

DCIT, CIRCLE - 11(1), KOLKATA, KOLKATA vs. M/S. EVEREADY INDUSTRIES INDIA LTD., KOLKATA

In the result, all the captioned appeals of the Revenue stand dismissed

Bench: Shri Sanjay Garg & Dr. Manish Boradi.T.A Nos.1880,1881&1882/Kol/2018 Assessment Years: 2011-12,2012-13 & 2013-14 Dcit, Circle-11(1), Kolkata.........................….................……...…..…Appellant Vs. M/S Eveready Industries India Ltd.........................................…..…..Respondent 2, Rainey Park, Kolkata-700019. [Pan: Aaace5778N] Appearances By: Shri Akkal Dudhewala, Ar, Appeared On Behalf Of The Appellant. Shri P.P. Barman, Addl. Cit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : February 09, 2023 Date Of Pronouncing The Order : March 30, 2023 आदेश / Order संजय गग", "या"यक सद"य "वारा / Per Sanjay Garg: The Captioned Appeals Have Been Preferred By The Revenue Against The Separate Orders All Dated 22.06.2018 Of The Commissioner Of Income Tax (Appeals)-22, Kolkata [Hereinafter Referred To As The ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). Since, Common Issues Are Involved In All The Appeals, Hence These Have Heard Together & Are Being Disposed Of By This Common Order. The Appeal In Ita No.1880/Kol/2018 For Assessment Year 2011-12 Is Taken As Lead Case For The Purpose Of Narration Of Facts. 2. Ita No.1880/Kol/2018 – The Revenue In This Appeal Has Taken The Following Grounds Of Appeal:

sections 92A to 92F of the Act and rules. 10A to 10E of the Rules and also maintained necessary information and documentation in support thereof. However from the SCN issued by the Ld. TPO as well as his impugned order, I find that no ground whatsoever has been set out for rejecting the TP analysis performed by the appellant. Such

DCIT, CIRCLE - 11(1), KOLKATA, KOLKATA vs. M/S. EVEREADY INDUSTRIES INDIA LTD., KOLKATA

In the result, all the captioned appeals of the Revenue stand dismissed

Bench: Shri Sanjay Garg & Dr. Manish Boradi.T.A Nos.1880,1881&1882/Kol/2018 Assessment Years: 2011-12,2012-13 & 2013-14 Dcit, Circle-11(1), Kolkata.........................….................……...…..…Appellant Vs. M/S Eveready Industries India Ltd.........................................…..…..Respondent 2, Rainey Park, Kolkata-700019. [Pan: Aaace5778N] Appearances By: Shri Akkal Dudhewala, Ar, Appeared On Behalf Of The Appellant. Shri P.P. Barman, Addl. Cit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : February 09, 2023 Date Of Pronouncing The Order : March 30, 2023 आदेश / Order संजय गग", "या"यक सद"य "वारा / Per Sanjay Garg: The Captioned Appeals Have Been Preferred By The Revenue Against The Separate Orders All Dated 22.06.2018 Of The Commissioner Of Income Tax (Appeals)-22, Kolkata [Hereinafter Referred To As The ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). Since, Common Issues Are Involved In All The Appeals, Hence These Have Heard Together & Are Being Disposed Of By This Common Order. The Appeal In Ita No.1880/Kol/2018 For Assessment Year 2011-12 Is Taken As Lead Case For The Purpose Of Narration Of Facts. 2. Ita No.1880/Kol/2018 – The Revenue In This Appeal Has Taken The Following Grounds Of Appeal:

sections 92A to 92F of the Act and rules. 10A to 10E of the Rules and also maintained necessary information and documentation in support thereof. However from the SCN issued by the Ld. TPO as well as his impugned order, I find that no ground whatsoever has been set out for rejecting the TP analysis performed by the appellant. Such

DCIT, CIRCLE - 11(1), KOLKATA, KOLKATA vs. M/S. EVEREADY INDUSTRIES INDIA LTD., KOLKATA

In the result, all the captioned appeals of the Revenue stand dismissed

Bench: Shri Sanjay Garg & Dr. Manish Boradi.T.A Nos.1880,1881&1882/Kol/2018 Assessment Years: 2011-12,2012-13 & 2013-14 Dcit, Circle-11(1), Kolkata.........................….................……...…..…Appellant Vs. M/S Eveready Industries India Ltd.........................................…..…..Respondent 2, Rainey Park, Kolkata-700019. [Pan: Aaace5778N] Appearances By: Shri Akkal Dudhewala, Ar, Appeared On Behalf Of The Appellant. Shri P.P. Barman, Addl. Cit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : February 09, 2023 Date Of Pronouncing The Order : March 30, 2023 आदेश / Order संजय गग", "या"यक सद"य "वारा / Per Sanjay Garg: The Captioned Appeals Have Been Preferred By The Revenue Against The Separate Orders All Dated 22.06.2018 Of The Commissioner Of Income Tax (Appeals)-22, Kolkata [Hereinafter Referred To As The ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). Since, Common Issues Are Involved In All The Appeals, Hence These Have Heard Together & Are Being Disposed Of By This Common Order. The Appeal In Ita No.1880/Kol/2018 For Assessment Year 2011-12 Is Taken As Lead Case For The Purpose Of Narration Of Facts. 2. Ita No.1880/Kol/2018 – The Revenue In This Appeal Has Taken The Following Grounds Of Appeal:

sections 92A to 92F of the Act and rules. 10A to 10E of the Rules and also maintained necessary information and documentation in support thereof. However from the SCN issued by the Ld. TPO as well as his impugned order, I find that no ground whatsoever has been set out for rejecting the TP analysis performed by the appellant. Such

BBJ GAMMON JOINT VENTURE,KOLKATA vs. INCOME TAX OFFICER, WARD - 34(1), KOLKATA, KOLKATA

In the result, the appeals of the assessee as well as revenue are allowed for statistical purposes subject to directions contained hereinabove

Bench: Hon’Ble Shri S.S. Godara, Jm & Shri M.Balaganesh, Am ] I.T.A Nos. 2355,2356,2357/Kol/2013 Assessment Years : 2006-07,2007-08&2008-09 Bbj Gammon Joint Venture -Vs- Ito, Ward-34(1), Kolkata [Pan: Aaaab 4903 C] (Appellant) (Respondent)

TDS certificate issued by RVNL in the name of assessee JV was not reflected as income directly or indirectly. He observed that although substantial amount is paid to the JV for contract work by RVNL, no expenditure was shown in the expenditure side of the income and expenditure account. Accordingly he rejected the books of accounts

BBJ GAMMON JOINT VENTURE,KOLKATA vs. INCOME TAX OFFICER, WARD - 34(1), KOLKATA, KOLKATA

In the result, the appeals of the assessee as well as revenue are allowed for statistical purposes subject to directions contained hereinabove

Bench: Hon’Ble Shri S.S. Godara, Jm & Shri M.Balaganesh, Am ] I.T.A Nos. 2355,2356,2357/Kol/2013 Assessment Years : 2006-07,2007-08&2008-09 Bbj Gammon Joint Venture -Vs- Ito, Ward-34(1), Kolkata [Pan: Aaaab 4903 C] (Appellant) (Respondent)

TDS certificate issued by RVNL in the name of assessee JV was not reflected as income directly or indirectly. He observed that although substantial amount is paid to the JV for contract work by RVNL, no expenditure was shown in the expenditure side of the income and expenditure account. Accordingly he rejected the books of accounts

I.T.O, WD-34(1)/KOLKATA, KOLKATA vs. M/S B.B.J. GAMMON (JV), KOLKATA

In the result, the appeals of the assessee as well as revenue are allowed for statistical purposes subject to directions contained hereinabove

Bench: Hon’Ble Shri S.S. Godara, Jm & Shri M.Balaganesh, Am ] I.T.A Nos. 2355,2356,2357/Kol/2013 Assessment Years : 2006-07,2007-08&2008-09 Bbj Gammon Joint Venture -Vs- Ito, Ward-34(1), Kolkata [Pan: Aaaab 4903 C] (Appellant) (Respondent)

TDS certificate issued by RVNL in the name of assessee JV was not reflected as income directly or indirectly. He observed that although substantial amount is paid to the JV for contract work by RVNL, no expenditure was shown in the expenditure side of the income and expenditure account. Accordingly he rejected the books of accounts

I.T.O, WD-34(1)/KOLKATA, KOLKATA vs. M/S B.B.J. GAMMON (JV), KOLKATA

In the result, the appeals of the assessee as well as revenue are allowed for statistical purposes subject to directions contained hereinabove

Bench: Hon’Ble Shri S.S. Godara, Jm & Shri M.Balaganesh, Am ] I.T.A Nos. 2355,2356,2357/Kol/2013 Assessment Years : 2006-07,2007-08&2008-09 Bbj Gammon Joint Venture -Vs- Ito, Ward-34(1), Kolkata [Pan: Aaaab 4903 C] (Appellant) (Respondent)

TDS certificate issued by RVNL in the name of assessee JV was not reflected as income directly or indirectly. He observed that although substantial amount is paid to the JV for contract work by RVNL, no expenditure was shown in the expenditure side of the income and expenditure account. Accordingly he rejected the books of accounts

BBJ GAMMON JOINT VENTURE,KOLKATA vs. INCOME TAX OFFICER, WARD - 34(1), KOLKATA, KOLKATA

In the result, the appeals of the assessee as well as revenue are allowed for statistical purposes subject to directions contained hereinabove

Bench: Hon’Ble Shri S.S. Godara, Jm & Shri M.Balaganesh, Am ] I.T.A Nos. 2355,2356,2357/Kol/2013 Assessment Years : 2006-07,2007-08&2008-09 Bbj Gammon Joint Venture -Vs- Ito, Ward-34(1), Kolkata [Pan: Aaaab 4903 C] (Appellant) (Respondent)

TDS certificate issued by RVNL in the name of assessee JV was not reflected as income directly or indirectly. He observed that although substantial amount is paid to the JV for contract work by RVNL, no expenditure was shown in the expenditure side of the income and expenditure account. Accordingly he rejected the books of accounts

ITO, WD-34(1), KOLKATA, KOLKATA vs. M/S B. B. J GAMMON, KOLKATA

In the result, the appeals of the assessee as well as revenue are allowed for statistical purposes subject to directions contained hereinabove

Bench: Hon’Ble Shri S.S. Godara, Jm & Shri M.Balaganesh, Am ] I.T.A Nos. 2355,2356,2357/Kol/2013 Assessment Years : 2006-07,2007-08&2008-09 Bbj Gammon Joint Venture -Vs- Ito, Ward-34(1), Kolkata [Pan: Aaaab 4903 C] (Appellant) (Respondent)

TDS certificate issued by RVNL in the name of assessee JV was not reflected as income directly or indirectly. He observed that although substantial amount is paid to the JV for contract work by RVNL, no expenditure was shown in the expenditure side of the income and expenditure account. Accordingly he rejected the books of accounts

I.T.O, WD-34(1)/KOLKATA, KOLKATA vs. M/S B.B.J. GAMMON (JV), KOLKATA

In the result, the appeals of the assessee as well as revenue are allowed for statistical purposes subject to directions contained hereinabove

Bench: Hon’Ble Shri S.S. Godara, Jm & Shri M.Balaganesh, Am ] I.T.A Nos. 2355,2356,2357/Kol/2013 Assessment Years : 2006-07,2007-08&2008-09 Bbj Gammon Joint Venture -Vs- Ito, Ward-34(1), Kolkata [Pan: Aaaab 4903 C] (Appellant) (Respondent)

TDS certificate issued by RVNL in the name of assessee JV was not reflected as income directly or indirectly. He observed that although substantial amount is paid to the JV for contract work by RVNL, no expenditure was shown in the expenditure side of the income and expenditure account. Accordingly he rejected the books of accounts

DCIT, CIR-12(2), KOLKATA, KOLKATA vs. M/S PHILIPS INDIA LTD., KOLKATA

Bench: Shri N.V.Vasudevan & Shri Waseem Ahmed

section 92A(2) of the Act. The assessee is engaged in 4 business segments as detailed below: 1. Consumer lifestyle 2. Healthcare 3. Lighting 4. Software Development Consumer Lifestyle consists of Domestic Appliances & Personal Care and Consumer Electronics divisions. It consists of Television, Shaving & Beauty, Audio & Video Multimedia, Domestic Appliances, Health & Wellness, and Peripherals & Accessories etc. A benchmarking study

M/S PHILIPS INDIA LTD.,KOLKATA vs. DCIT, CIR-12(2), KOLKATA, KOLKATA

Bench: Shri N.V.Vasudevan & Shri Waseem Ahmed

section 92A(2) of the Act. The assessee is engaged in 4 business segments as detailed below: 1. Consumer lifestyle 2. Healthcare 3. Lighting 4. Software Development Consumer Lifestyle consists of Domestic Appliances & Personal Care and Consumer Electronics divisions. It consists of Television, Shaving & Beauty, Audio & Video Multimedia, Domestic Appliances, Health & Wellness, and Peripherals & Accessories etc. A benchmarking study