ACIT, CIR-3(TDS), KOLKATA, KOLKATA vs. SDV INTERNATION LOGISTICS LTD., KOLKATA

In the result, both the appeals of the revenue are dismissed while the appeal of the assessee is allowed

Bench: Shri P.M. Jagtap, Am & Shri S.S. Viswanethra Ravi, Jm]

10B, Middleton Row, 7th Floor, Kolkata – 700 071. Appearances by: Shri Soumesh Dash, Addl. CIT, Sr. DR appearing on behalf of the Revenue. Shri Anup Sinha, FCA appearing on behalf of the Assessee. Date of concluding the hearing : September 04, 2018 Date of pronouncing the order : September 12, 2018 ORDER Per P.M. Jagtap, AM Out of these three appeals

ACIT, CIR-3(TDS), KOLKATA, KOLKATA vs. SDV INTERNATION LOGISTICS LTD., KOLKATA

In the result, both the appeals of the revenue are dismissed while the appeal of the assessee is allowed

Bench: Shri P.M. Jagtap, Am & Shri S.S. Viswanethra Ravi, Jm]

10B, Middleton Row, 7th Floor, Kolkata – 700 071. Appearances by: Shri Soumesh Dash, Addl. CIT, Sr. DR appearing on behalf of the Revenue. Shri Anup Sinha, FCA appearing on behalf of the Assessee. Date of concluding the hearing : September 04, 2018 Date of pronouncing the order : September 12, 2018 ORDER Per P.M. Jagtap, AM Out of these three appeals

SDV INTERNATIONAL LOGISTICS LTD.,KOLKATA vs. ACIT, CIR-59 (TDS), KOLKATA, KOLKATA

In the result, both the appeals of the revenue are dismissed while the appeal of the assessee is allowed

Bench: Shri P.M. Jagtap, Am & Shri S.S. Viswanethra Ravi, Jm]

10B, Middleton Row, 7th Floor, Kolkata – 700 071. Appearances by: Shri Soumesh Dash, Addl. CIT, Sr. DR appearing on behalf of the Revenue. Shri Anup Sinha, FCA appearing on behalf of the Assessee. Date of concluding the hearing : September 04, 2018 Date of pronouncing the order : September 12, 2018 ORDER Per P.M. Jagtap, AM Out of these three appeals

NLC NALCO INDIA LTD.,KOLKATA vs. ACIT, CIRCLE - 11, KOLKATA, KOLKATA

In the result, the appeal of assessee in ITA No

Bench: Shri Mahavir Singh, Jm& Shri Waseem Ahmed, Am]

property 4. Particulars in respect of providing services 15,174,980.00 TNMM 5. Interest on loan received 1,603,119.00 Comparable Uncontrolled price (‘CUP’) Method 6. Reimbursement of expenses 6,893,894.00 TNMM The TPO observed in his order that in response to the notice u/s 92CA (2) of the Act, the assessee attended his office and filed details which

N L C NALCO INDIA LTD PREVIOUSLY KNOWN AS ONDEO NALCO INDIA LTD.,KOLKATA vs. ACIT, CIR - 11, KOLKATA, KOLKATA

In the result, the appeal of assessee in ITA No

Bench: Shri Mahavir Singh, Jm& Shri Waseem Ahmed, Am]

property 4. Particulars in respect of providing services 15,174,980.00 TNMM 5. Interest on loan received 1,603,119.00 Comparable Uncontrolled price (‘CUP’) Method 6. Reimbursement of expenses 6,893,894.00 TNMM The TPO observed in his order that in response to the notice u/s 92CA (2) of the Act, the assessee attended his office and filed details which

THE W.B. STATE CO-OP AGRI AND RURAL DEVELOPMENT BANK LIMITED ,KOLKATA vs. ACIT, CIR. 32, KOLKATA

Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Rakesh Mishraassessment Year: 2006-07

10B, Middleton Road, Rural Development Bank Kolkata-700071 Vs. Ltd. 25D, Shakespeare Sarani, Kolkata-700017. (PAN: AAAJT0468K) (Appellant) (Respondent) Present for: Appellant by : Shri Palash Chattapadhya, AR Respondent by : Dr. Anup Biswas, Addl. CIT Date of Hearing : 07.05.2024 Date of Pronouncement : 05.08.2024 O R D E R PER RAKESH MISHRA, ACCOUNTANT MEMBER: This appeal filed by the assessee is against

MAMTA ANCHALIA,KOLKATA vs. DCIT, CIRCLE-32, KOLKATA, KOLKATA

In the result, the appeal of the assessee is treated as allowed for statistical purposes

house property on the date of sale of silver utensils. It was contended that the assessee thus was entitled for exemption under section 54F and the A.O. was not justified in disallowing the said exemption. The Ld. CIT(A) did not find merit in this contention raised on behalf of the assessee and proceeded to confirm the disallowance made

MADHU JAYANTI INTERNATIONAL LIMITED,KOLKATA vs. DCIT, CIRCLE - 4(1), KOLKATA, KOLKATA

In the result, the appeal of the assessee is allowed for statistical purposes

Bench: Hon’Ble Shri Aby. T. Varkey, Jm & Shri M.Balaganesh, Am ] I.T.A No. 214/Kol/2016 Assessment Year : 2011-12 Madhu Jayanti International Ltd. -Vs- Dcit, Cc-4(1), Kolkata [Pan: Aabcm 7502 R] (Appellant) (Respondent)

section 144C(5) of the Act dated 15.10.2015 for the Asst Year 2011-12. 2. Though the assessee had raised several grounds of appeal before us with regard to the transfer pricing addition, the only effective issue to be decided in this appeal is with regard to the determination of the Most Appropriate Method (MAM) in the instant case

ACIT, LTU - 2, KOLKATA , KOLKATA vs. M/S. UCO BANK, KOLKATA

In the result, appeal of the Revenue is dismissed

Bench: Shri S. S. Godara, Jm & Dr. A.L. Saini, Am Vs. M/S Uco Bank Acit, Ltu-2, Kolkata 10, Btm, Sarani, Kolkata – 700001. "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaacu3561B .. (अपीलाथ" /Appellant) (""यथ" / Respondent)

House property in Singapore is not taxable in India under DTAA while as per Article 25 of DTAA, it is taxable in India. 3 M/s UCO Bank 10. That the appellant craves for leave to add, delete and/or modify any of the grounds of appeal before or at the time of hearing. 3. Ground Nos.1 & 2 relates to addition

AT&S INDIA PRIVATE LIMITED vs. D.C.I.T., CIRCLE-11(1), KOLKATA, KOLKATA

In the result, appeal filed by the assessee, is allowed

Bench: Shri A. T. Varkey, Jm &Dr. A.L.Saini, Am आयकरअपीलसं./Ita No.77/Kol/2017 ("नधा"रणवष" / Assessment Year: 2012-13) At & S India (P) Ltd. Vs. D.C.I.T, Circle-11(1), Kolkata

property or services transferred in a comparable uncontrolled transaction in comparable circumstances. " 11.1 We also find support from the decision of the Hon'ble Mumbai Tribunal in the matter of DCIT vs. Isagro (Asia) Agrochemicals (P.) Ltd reported in [2013] 31 taxmann.com 388 (Mumbai - Trib.), wherein the Hon'ble Tribunal interalia held that : "various benches of the Tribunal including Asstt

MOHAMMED AZHAR,KOLKATA vs. ACIT, CIR-33, KOLKATA, KOLKATA

In the result, all the appeals of the assessee are allowed for statistical purposes

Bench: : Shri Partha Sarathi Chaudhury & Shri Dr. Arjun Lal Saini

section 24(b), deduction of Rs.1,50,000/- is admissible, if the house property is acquired or completed with capital borrowed within 3 years from the end of the financial year in which the capital was borrowed for the purpose of acquisition/construction of house property. Though the assessee claimed that the loan was taken from HDFC Bank, but no supporting

ORIENTAL CHARITABLE FOUNDATION,KOLKATA vs. CIT(EXEMPTIONS), KOLKATA

In the result, the appeal of the assessee is partly allowed

Bench: Shri Rajpal Yadav & Shri Rakesh Mishraassessment Year: 2017-18

10B on 26.10.2017 and claimed exemption u/s. 11 of the Act. The Ld. CIT(E) observed that a perusal of the Income & Expenditure Account for the F. Y. 2016-17 revealed that Rs.9,37,84,046/- was claimed as application of income against income of Rs. 68,41,927/-. From the Balance Sheet, it was found that there

SIKA INDIA PVT. LTD.,KOLKATA vs. DCIT, CIR-11, KOLKATA, KOLKATA

In the result, appeal of the assessee is allowed in part and in appeal of the revenue is dismissed

Bench: Sri J. Sudhakar Reddy & Sri S.S. Viswanethra Ravi]

property (Knowhow etc.), duration and degree of protection, segment of industry and anticipated benefits are same or similar and the economic environment and geographical area of the licensor and licensee in case of comparable is also same or similar; 3. Whether on the basis of facts and in law, Ld. DRP, Kolkata have erred in holding that the determination

DCIT, CIR-11, KOLKATA, KOLKATA vs. M/S SIKA INDIA PVT. LTD., KOLKATA

In the result, appeal of the assessee is allowed in part and in appeal of the revenue is dismissed

Bench: Sri J. Sudhakar Reddy & Sri S.S. Viswanethra Ravi]

property (Knowhow etc.), duration and degree of protection, segment of industry and anticipated benefits are same or similar and the economic environment and geographical area of the licensor and licensee in case of comparable is also same or similar; 3. Whether on the basis of facts and in law, Ld. DRP, Kolkata have erred in holding that the determination

ACIT, CIR-31, KOLKATA, KOLKATA vs. WEST BENGAL HOUSING BOARD, KOLKATA

In the result, the appeal of the revenue is dismissed

section 56 of the Act. Where a person has only one source of income, which is business, there could hardly be any other inference. In the case of Snam Progetti S.P.A. vs. Add!. CIT [1981J 132 ITR 70 the Delhi High Court took a broad view and considered interest as incidental to business income, because it cannot be presumed that

M/S. TEGA INDUSTRIES LIMITED,KOLKATA vs. D.C.I.T., CIRCLE - 11(1), KOLKATA

In the result, the appeal filed by the assessee is partly allowed

Bench: Shri George Mathan & Shri Rakesh Mishra

10B(1)(a) of the Income Tax Rules, 1962. It was also submitted that the Ld. TPO/AO/DRP erred in making adjustment of INR 9,88,849/- on account of corporate guarantee on behalf of Tega Industries Chile SpA (‘Tega Chile’) by applying CUP method. 6.1 A perusal of the assessment order shows that in respect of the corporate guarantee

JASPAL SINGH BINDRA,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX, CPC, BANGALORE

The appeal are allowed and the Ld

Bench: Shri Sanjay Garg & Shri Rakesh Mishraassessment Year: 2022-23

house property and profit in share. The assessee filed his return of income u/s 139(1) on 31.10.2022 declaring total income of ₹6,76,96,410/-. The assessee is an Individual and a Resident of India and regularly assessed to tax. During the year under consideration, he earned Pension from Standard Chartered Pension (SCD) Overseas, UK of Rs.1

ARUS PROPERTIES LLP,,KOLKATA vs. D.C.I.T., EXEMPT - 1, CIRCLE - 1(1),, KOLKATA

In the result, the appeal filed by the assessee is allowed

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) & Shri Rajesh Kumari.T.A. No. 533/Kol/2025 Assessment Year: 2023-2024 Arus Properties Llp,………………………..….…Appellant 7B, Pretoria Street, ‘Alom House’, Kolkata-700071 [Pan:Abcfa4787H] -Vs.- Deputy Commissioner Of Income Tax,..…….Respondent Exempt-1, Circle-1(1), Kolkata, 10B, Middleton Row, Kolkata-700071 Appearances By: Shri P.J. Bhide, Fca, Appeared On Behalf Of The Assessee Ms. Archana Gupta, Addl. Cit, Sr. D.R., Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: August 06, 2025 Date Of Pronouncing The Order: October 31, 2025 O R D E R

section 71 & 72 of the Act. Accordingly, the grounds raised by the assessee are allowed. 8. In the result, the appeal filed by the assessee is allowed. Order pronounced in the open Court on 31/10/2025. (Rajesh Kumar) (Duvvuru RL Reddy) Accountant Member Vice-President Kolkata, the 31st day of October, 2025 4 Arus Properties LLP Copies to :(1) Arus Properties

DCIT, CIRCLE - 10, KOLKATA, KOLKATA vs. M/S. DIC INDIA LTD., KOLKATA

In the result, both appeals of Revenue stand dismissed

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

house Coopers as part of the documents and information kept and maintained by it. Rule 10D(e) casts a responsibility on the assessee to keep and maintain information and documents regarding description of functions performed by the assessee and its AEs involved in the international transactions. In this context, reference is made to Part-IV of the Report submitted