AMBO AGRO PRODUCTS LTD.,KOLKATA vs. THE PCIT, KOLKATA-1, KOLKATA

In the result, appeal of assessee is allowed

Bench: Shri A. T. Varkey, Jm & Dr. A. L. Saini, Am]

12. The term 'slump sale’ been defined to mean a transfer of a business undertaking or a business for a lumpsum consideration with all its assets and liabilities without values being assigned to individual assets/liabilities. The said term has no other Significance and we should not read into and understand that the word 'sale used in the term 'slump sale

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]

Transfer Pricing Officer (TPO) vide order passed under section 92CA(3) of the act without appreciating the fact that the report of TPO was not a part of the Assessment Order and the appellant has been denied the opportunity of making its objection against the said report. 12. For that in view of the finding by the TPO that there

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]

Transfer Pricing Officer (TPO) vide order passed under section 92CA(3) of the act without appreciating the fact that the report of TPO was not a part of the Assessment Order and the appellant has been denied the opportunity of making its objection against the said report. 12. For that in view of the finding by the TPO that there

EMAMI INDRASTRUCTURE LIMITED,KOLKATA vs. ITO, WD-12(1), KOLKATA, KOLKATA

In the result, the appeal of the assessee is allowed in part

12-2009 to Rs.4390 share on 11.02.2010. Accordingly, show cause 2 notice dt:18-01-2013 was issued to assessee seeking explanation why the sale price per share of Zandu Realty Ltd should not be taken at Rs.3989.80 being the average price traded at NSE as on 31-03- 2010 against sale price of Rs.2100 per share taken

TATA CONSUMER PRODUCTS LIMITED,KOLKATA vs. DCIT, CIR.-4(1), KOLKATA

In the result, the appeal for AY 2014-15 is partly allowed

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishraassessment Years: 2014-15 & Assessment Years: 2015-16

1) For the purposes of this section and sections 92, 92C, 92D and 92E, "international transaction" means a transaction between two or more associated enterprises, either or both of whom are non-residents, in the nature of purchase, sale or lease of tangible or intangible property, or provision of services, or lending or borrowing money, or any other transaction having

TATA CONSUMER PRODUCTS LIMITED,KOLKATA vs. DCIT, CIR.-4(1), KOLKATA

In the result, the appeal for AY 2014-15 is partly allowed

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishraassessment Years: 2014-15 & Assessment Years: 2015-16

1) For the purposes of this section and sections 92, 92C, 92D and 92E, "international transaction" means a transaction between two or more associated enterprises, either or both of whom are non-residents, in the nature of purchase, sale or lease of tangible or intangible property, or provision of services, or lending or borrowing money, or any other transaction having

NORMURA RESEARCH INSTITURE FINANCIAL TECHNOLOGIES INDIA PRIVATE LIMITED,KOLKATA vs. ACIT,CIRCLE-2(2), KOL, KOLKATA

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

Bench: Shri Sanjay Garg & Shri Girish Agrawalassessment Year: 2012-13

12 in ITA No. 284/Kol/2016 dated 26.10.2018. On perusal of the said order, it is noted that these issues are dealt with vide para 18, which is extracted below: “18. The Ground No. 26 raised by the assessee is with regard to the action of the ld AO in adding back the disallowance conceived

NOMURA RESEARCH INSTITUTE FINANCIAL TECHNOLOGIES INDIA PVT. LTD. (FORMERLY KNOWS AS ANSHIN SOFTWARE PVT. LTD.,),KOLKATA vs. DCIT, CIRCLE - 2(2), KOLKATA, KOLKATA

In the result, the appeal of the assessee in ITA No

Bench: Hon’Ble Shri A.T.Varkey, Jm & Hon’Ble Shri M.Balaganesh, Am ] I.T.A No. 284/Kol/2016 Assessment Year : 2011-12 Nomura Research Institute Financial Tech.(I) Pvt. Ltd. -Vs- Dcit, Circle-2(2), Kolkata (Formerly Anshin Software Pvt. Ltd.) [Pan: Aadca 8967 A] (Appellant) (Respondent) I.T.A No. 485/Kol/2016 Assessment Year : 2011-12 Dcit, Circle-2(2), Kolkata -Vs- Nomura Research Institute Financial Tech.(I) Pvt. Ltd. (Formerly Anshin Software Pvt. Ltd.) [Pan: Aadca 8967 A] (Appellant) (Respondent)

transfer pricing assessment proceedings from the said company wherein the said company had replied that it provides software development services. The ld TPO by placing reliance on the same held the said company to be a valid comparable with the assessee for computing the arm’s length margin. We also find from the profit and loss account of the said

DCIT, CIR-2(2), KOLKATA, KOLKATA vs. M/S NOMURA RESEARCH INSTITUTE & FINANCIAL TECHNOLOGIES PVT. LTD., KOLKATA

In the result, the appeal of the assessee in ITA No

Bench: Hon’Ble Shri A.T.Varkey, Jm & Hon’Ble Shri M.Balaganesh, Am ] I.T.A No. 284/Kol/2016 Assessment Year : 2011-12 Nomura Research Institute Financial Tech.(I) Pvt. Ltd. -Vs- Dcit, Circle-2(2), Kolkata (Formerly Anshin Software Pvt. Ltd.) [Pan: Aadca 8967 A] (Appellant) (Respondent) I.T.A No. 485/Kol/2016 Assessment Year : 2011-12 Dcit, Circle-2(2), Kolkata -Vs- Nomura Research Institute Financial Tech.(I) Pvt. Ltd. (Formerly Anshin Software Pvt. Ltd.) [Pan: Aadca 8967 A] (Appellant) (Respondent)

transfer pricing assessment proceedings from the said company wherein the said company had replied that it provides software development services. The ld TPO by placing reliance on the same held the said company to be a valid comparable with the assessee for computing the arm’s length margin. We also find from the profit and loss account of the said

THE UNITED PROVINCES SUGAR COMPANY LTD., ,KOLKATA vs. ITO, WARD - 12(2), KOLKATA

In the result, appeal of the assessee is allowed

Ac cited u/s 115JA of the Act cannot be applied in this case. He further relied on the order of the ld. CIT(A) and submitted that applied in this case. He further relied on the order of the ld. CIT(A) and submitted that applied in this case. He further relied on the order

DCIT, CIR-2(2), KOLKATA, KOLKATA vs. M/S NOMURA RESEARCH INSTITUTE & FINANCIAL TECHNOLOGIES PVT. LTD., KOLKATA

In the result the appeal of the assessee is partly allowed and the appeal by the revenue is dismissed

Bench: Hon’Ble Sri N.V.Vasudevan, Jm & Shri M.Balaganesh, Am]

transfer pricing order for the assessee for last year, in respect of the margins of this entity and the same is reproduced below: Revenue in Lakhs Profit in Lakhs Profit Margin

NOMURA RESEARCH INSTITUTE FINANCIAL TECHNOLOGIES INDIA PVT. LTD.,KOLKATA vs. DCIT, CIR-2(1), KOLKATA, KOLKATA

In the result the appeal of the assessee is partly allowed and the appeal by the revenue is dismissed

Bench: Hon’Ble Sri N.V.Vasudevan, Jm & Shri M.Balaganesh, Am]

transfer pricing order for the assessee for last year, in respect of the margins of this entity and the same is reproduced below: Revenue in Lakhs Profit in Lakhs Profit Margin

DCIT, CIR-7(1), KOLKATA, KOLKATA vs. M/S JET AGE SECURITIES PVT. LTD., KOLKATA

In the result, the appeal of the revenue is dismissed

Bench: Hon’Ble Shri M.Balaganesh, Am & Hon’Ble Shri S.S.Viswanethra Ravi, Jm] I.T.A No. 1359/Kol/2015 Assessment Year : 2011-12 Dcit, Circle-7(1), Kolkata -Vs- M/S Jet Age Securities Pvt. Ltd. [Pan: Aabcj 0993 R] (Appellant) (Respondent)

1,14,78,523-1,22,500) and Other STCG was Rs 45,83,787/-. Assessment was framed u/s 143(3) of the Act wherein STCG claimed u/s 111A of the Act was sought to be taxed as business income by the ld AO. 2.6.2. We find that this tribunal in assessee’s own case for the Asst Year

D.C.I.T.,CIRCLE-3(1), KOLKATA vs. SMT. SHIKHA ROY, KOLKATA

In the result, appeal of the revenue is dismissed

Ac of the Act and on various case-law for the proposition that law for the proposition that transfer of tenancy rights would tantamount to transfer of capital asset. He submitted transfer of tenancy rights would tantamount to transfer of capital asset. He submitted transfer of tenancy rights would tantamount to transfer of capital asset. He submitted that these being

SHETH COMMERCIAL CO.,KOLKATA vs. PR.CIT-14, KOLKATA

In the result, the appeal of the assessee is allowed

Bench: Shri S.S.Godara, Jm &Dr. A.L.Saini, Am आयकरअपीलसं./Ita No.1100/Kol/2019 ("नधा"रणवष" / Assessment Year: 2014-15)

1.. S.O. 1327(E). - In exercise of the powers conferred by clause (ii) in the Explanation to clause (d) of the proviso to sub-section (5) of section 43 of the Income-tax Act. 1961 (43 of 1961), read with rule 6DDB of the Income-tax Rules, 1962, the Central Government hereby notifies MCX Stock Exchange

M/S. EPCOS INDIA PRIVATE LIMITED,NADIA vs. JCIT, RANGE - 11, KOLKATA, KOLKATA

Bench: Sri S.S. Godara & Dr. A.L. Saini] I.T.A. No. 278/Kol/2016 Assessment Year: 2011-12 Assessment Year : 2012-13

12-13. 5. According to assessee, it has appointed the new law firm when the appeal was preferred before the Tribunal for A.Y 2011-12. The New Law firm after analysis of the original T. P study has advised the assessee to adopt transaction by transaction method, in place of entity level bench marking approach. According to the assessee

M/S. PRICEWATERHOUSE COOPERS PRIVATE LIMITED,KOLKATA vs. ACIT, CIRCLE - 2(2), KOLKATA, KOLKATA

In the result, appeal of the assessee is allowed partly

ac date of maturity of the forward contract is not contingent and it is a actual loss, is allowable. Thus, respectfully following the observations made by the Special Bench allowable. Thus, respectfully following the observations made by the Special Bench allowable. Thus, respectfully following the observations made by the Special Bench supra, the ground no supra, the ground

M/S SADHANA STOCKS & SECURITIES PVT. LTD.,MUMBAI vs. PCIT-4, KOLKATA, KOLKATA

In the result, the appeal of the assessee is allowed

Bench: Shri P.M. Jagtap & Shri S.S. Viswanethra Ravi

transfer of the commodity or scraps: Provided that for the purposes of this clause- (a) a contract in respect of raw materials or merchandise entered into by a person in the course of his manufacturing or merchanting business to guard against loss through future price fluctuations in respect of his contracts for actual delivery of goods manufactured