SMT. KAJARI BANERJEE,KOLKATA vs. ITO WARD-29(1), KOLKTAT

In the result, the appeal of the assessee is allowed

price of the flat and the value as\nper Stamp Valuation Authority. However, as a matter of fact the property was purchased\nin the earlier year as observed by us hereinabove in view of the payments being made\nin entirety in the earlier financial year and the details of payments have already\nextracted hereinabove. We note that the first payment

BRAJBHUMI NIRMAAN PRIVATE LIMITED,SALT LAKE vs. ITO, WARD 2(1),, KOLKATA

In the result, the appeal of the assessee is allowed

x 10,00,000 shares] by way of income\nfrom other sources u/s 56(2)(viib) of the Act.\nThe Id. CIT (A) confirmed the addition in the appellate proceedings.\nThe Id. CIT(A) is noted to have inter alia called for the details of the\nrelevant information provided by the assessee to the valuer along with\nthe financials

SHRI SANDEEP KUMAR PODDAR,KOLKATA vs. I.T.O., WARD-44(1), KOLKATA, KOLKATA

In the result, appeal of the assessee is allowed

Bench: Shri Rajpal Yadav & Shri Girish Agrawalassessment Year: 2018-19

56(1)……. (2) In particular, and without prejudice to the generality of the provisions of sub-section (1), the following incomes, shall be chargeable to income-tax under any of the head “Income from other sources”, namely- (i) ……. (ii) …… ……….. (x) where any person receives, in any previous year, from any person or persons on or after

RENU BOTHRA,KOLKATA vs. DCIT, CIRCLE 46,, KOLKATA

In the result, appeal of the assessee is allowed

Bench: SHRI GEORGE MATHAN (Judicial Member)

56(1)……. (2) In particular, and without prejudice to the generality of the provisions of sub-section (1), the following incomes, shall be chargeable to income-tax under any of the head “Income from other sources”, namely- (i) ……. (ii) …… ……….. (x) where any person receives, in any previous year, from any person or persons on or after

GOUTAM GHOSH,HOWRAH vs. P.C.I.T., KOLKATA - 13, KOLKATA

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

Bench: Sri Rajpal Yadav, Vice- & Sri Sanjay Awasthi

price (Rs. 33,70,000/-), leading to a difference of Rs. 43,17,802/-. Through the said notice it was proposed to tax this amount u/s 56(2)(x) of the Act. Thereafter, the appellant is seen to have advanced a number of reasons to canvass the point that taxability of the amount worked

DCIT, CIR-4(1), KOLKATA, KOLKATA vs. M/S MCLEOD RUSSEL INDIA LTD., KOLKATA

In the result, the appeal of the Revenue is dismissed

Bench: Shri Rajpal Yadav, Vice- & Shri Rajesh Kumar

2. I first proceed to deal with the transfer pricing adjustment of Rs,61,84,092/- in respect of the corporate guarantee issued by the appellant to its AE. From the material on record, it is noted that the assessee company had given corporate guarantees on behalf of its AE, BTHL for the loan/finance obtained by the AE from ICICI

RAGHVENDRA SINGH,HOWRAH vs. INCOME TAX OFFICER, BAMBOO VILLA, CALCUTTA

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

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) I.T.A. No. 1763/Kol/2025 Assessment Year: 2018-2019 Raghvendra Singh,……………….………...……Appellant 13, Burnt Salt Gola Lane, Howrah-711101, West Bengal [Pan:Bjhps6740J] -Vs.- Income Tax Officer,…………………………..…..Respondent Ward-62(1), Kolkata, Bamboo Villa, 169, A.J.C. Bose Road, Kolkata-700014 Appearances By: Shri Vidyut Sethi, C.A., Appeared On Behalf Of The Assessee Shri Kallol Mistry, Jcit, Sr. D.R., Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: November 13, 2025 Date Of Pronouncing The Order: December 09, 2025 O R D E R

transfer as the said value is totally unfair and inconsistent with the value prevailing in the concerned locality. Assessee has requested for the valuation of the property by the DVO of Income Tax Department. Accordingly, the valuation of the property purchased by the assessee has been referred to the DVO of the Income Tax Department. The said valuation is still

DCIT, CIRCLE - 6(1), , KOLKATA vs. M/S. BIRLA CORPORATION LTD., KOLKATA

In the result, appeals filed by the Revenue for AYs 2013-14 &

Bench: Sri Rajpal Yadav & Dr. Manish Borad

X that the arm's length price for the goods or services should be determined on the basis of methods prescribed in Section 92C of the Act. In the circumstances therefore apart from the fact that the power tariff should be shown to be fair value, it must also be demonstrated that the price adopted for determination of profits

BIRLA CORPORATION LIMITED,KOLKATA vs. DCIT CIR.-6(1), KOLKATA

In the result, appeals filed by the Revenue for AYs 2013-14 &

Bench: Sri Rajpal Yadav & Dr. Manish Borad

X that the arm's length price for the goods or services should be determined on the basis of methods prescribed in Section 92C of the Act. In the circumstances therefore apart from the fact that the power tariff should be shown to be fair value, it must also be demonstrated that the price adopted for determination of profits

DCIT, CIRCLE - 6(1), , KOLKATA vs. M/S. BIRLA CORPORATION LTD., KOLKATA

In the result, appeals filed by the Revenue for AYs 2013-14 &

Bench: Sri Rajpal Yadav & Dr. Manish Borad

X that the arm's length price for the goods or services should be determined on the basis of methods prescribed in Section 92C of the Act. In the circumstances therefore apart from the fact that the power tariff should be shown to be fair value, it must also be demonstrated that the price adopted for determination of profits

BIRLA CORPORATION LIMITED,KOLKATA vs. DCIT, CIR.-6(1), KOLKATA

In the result, appeals filed by the Revenue for AYs 2013-14 &

Bench: Sri Rajpal Yadav & Dr. Manish Borad

X that the arm's length price for the goods or services should be determined on the basis of methods prescribed in Section 92C of the Act. In the circumstances therefore apart from the fact that the power tariff should be shown to be fair value, it must also be demonstrated that the price adopted for determination of profits

RECKITT BENCKISER (INDIA) PVT LTD.,KOLKATA vs. DCIT, CIRCLE-12(1), KOLKATA, KOLKATA

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

Bench: Shri Rajpal Yadav & Shri Girish Agrawalassessment Year: 2012-13

2) (a) under which certain types of expenditure incurred by way of payment to related parties is not deductible where the AO "is of the opinion that such expenditure is excessive or unreasonable having regard to the fair market value of the goods." In such event, "so much of the expenditure as is so considered by him to be excessive

SANJAY KUMAR SINGH,KOLKATA vs. ACIT, E-ASSESSMENT CENTRE, DELHI

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

Bench: Shri Rajpal Yadav & Shri Rakesh Mishraassessment Year: 2020-21

section 56(2)(x)(b) of The Income Tax Act, 1961 as information gathered from system of Income Tax Portal and also submission of the Appellant which has not applied to the facts as the Appellant is a developer for constructing House Building as the Income under Business and Profession of the Appellant which has been also disclosed before

RECKITT BENCKISER (INDIA) PVT LTD.,KOLKATA vs. DCIT, CIRCLE-12(1), KOLKATA, KOLKATA

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

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarmaita Nos.78/Kol/2018 Assessment Year: 2013-14 &

X are applicable to the transfer pricing adjustment exercise” 27. Our view is also fortified by the decision of the Coordinate Bench of ITAT Kolkata in the case of M/s Philips India Ltd ,ITA No.2489/Kol/2017, order dated 04.04.2018 wherein it was held as follows: “11. We have heard the rival submissions. At the outset, we find that

RECKITT BENCKISER (INDIA) PVT. LTD.,GURGAON vs. D.C.I.T., CIRCLE - 11(1),, KOLKATA

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

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarmaita Nos.78/Kol/2018 Assessment Year: 2013-14 &

X are applicable to the transfer pricing adjustment exercise” 27. Our view is also fortified by the decision of the Coordinate Bench of ITAT Kolkata in the case of M/s Philips India Ltd ,ITA No.2489/Kol/2017, order dated 04.04.2018 wherein it was held as follows: “11. We have heard the rival submissions. At the outset, we find that

RECKITT BENCKISER (INDIA) PVT LTD.,KOLKATA vs. DCIT, CIRCLE-12(1), KOLKATA, KOLKATA

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

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarmaita Nos.78/Kol/2018 Assessment Year: 2013-14 &

X are applicable to the transfer pricing adjustment exercise” 27. Our view is also fortified by the decision of the Coordinate Bench of ITAT Kolkata in the case of M/s Philips India Ltd ,ITA No.2489/Kol/2017, order dated 04.04.2018 wherein it was held as follows: “11. We have heard the rival submissions. At the outset, we find that

PARTHA PRATIM CHAKRABARTY,BANKURA vs. I.T.O., WARD - 3(1), BANKURA, BANKURA

In the result, the appeal of the assessee is allowed

Bench: Shri Rajpal Yadav, Vice-(Kz) & Dr. Manish Boradi.T.A. No. 1520/Kol/2024 Assessment Year: 2020-2021 Partha Pratim Chakrabarty,……..……….……Appellant Katjuridanga, P.O. Kenduadihi, Dist. Bankura-722102, West Bengal [Pan:Acepc4256E] -Vs.- Income Tax Officer,………………………….……Respondent Ward-3(1), Bankura, Income Tax Office, Kenduadihi, P.O. Kenduadihi, Dist. Bankura-722102 Appearances By: Shri D.K. Sen, Advocate, Appeared On Behalf Of The Assessee Shri Bonnine Debbarma, Addl. Cit (Dr), Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: September 25, 2024 Date Of Pronouncing The Order: October 09, 2024 O R D E R

x) of the Income Tax Act. It emerges out that the assessee has submitted that this flat was purchased by his mother Sabita Chakrabarty, who has paid Rs.71,00,000/- and deducted TDS at Rs.71,000/-. The balance amount of Rs.9,89,290/- was paid by him through account payee cheque and TDS of Rs.10,710/- was deducted

RECKITT BENCKISER INDIA PRIVATE LIMITED,GURGAON, HARYANA vs. D.C.I.T., CIRCLE 11.1, KOLKATA, KOLKATA

X are applicable to the transfer pricing adjustment exercise\"\n27. Our view is also fortified by the decision of the Coordinate Bench of ITAT Kolkata\nin the case of M/s Philips India Ltd,ITA No.2489/Kol/2017, order dated 04.04.2018\nwherein it was held as follows:\n\n“11. We have heard the rival submissions. At the outset, we find that