PRAMOD LAKRA, DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-11(1), KOLKATA, KOLKATA vs. BALRAMPUR CHINI MILLS LTD , KOLKATA

In the result all the four appeals of the revenue are dismissed

Bench: Shri Rajesh Kumar, Am & Shripradip Kumar Choubey, Jm

Transfer Pricing Officer adopted ₹4.96/Kwh for benchmarking these domestic transactions with the AEs thereby making an adjustment of ₹44,83,27,538/-. Accordingly, the assessment was framed by the learned ld. AO making this addition. The learned CIT (A) while passing the order, has followed the decision of the Coordinate Bench in ITA No. 1672/KOL/2019

PRAMOD LAKRA, DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-11(1), KOLKATA, KOLKATA vs. BALRAMPUR CHINI MILLS LTD , KOLKATA

In the result all the four appeals of the revenue are dismissed

Bench: Shri Rajesh Kumar, Am & Shripradip Kumar Choubey, Jm

Transfer Pricing Officer adopted ₹4.96/Kwh for benchmarking these domestic transactions with the AEs thereby making an adjustment of ₹44,83,27,538/-. Accordingly, the assessment was framed by the learned ld. AO making this addition. The learned CIT (A) while passing the order, has followed the decision of the Coordinate Bench in ITA No. 1672/KOL/2019

PRAMOD LAKRA, DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-11(1), KOLKATA, KOLKATA vs. BALRAMPUR CHINI MILLS LTD , KOLKATA

In the result all the four appeals of the revenue are dismissed

Bench: Shri Rajesh Kumar, Am & Shripradip Kumar Choubey, Jm

Transfer Pricing Officer adopted ₹4.96/Kwh for benchmarking these domestic transactions with the AEs thereby making an adjustment of ₹44,83,27,538/-. Accordingly, the assessment was framed by the learned ld. AO making this addition. The learned CIT (A) while passing the order, has followed the decision of the Coordinate Bench in ITA No. 1672/KOL/2019

M/S TATA GLOBAL BEVERAGES LIMITED,KOLKATA vs. THE DCIT, CIRCLE-4(2), KOLKATA, KOLKATA

In the result, the appeals filed by the assessee for AY 2012-

Bench: Dr. Manish Borad & Sonjoy Sarma

Transfer Pricing Officer (Ld. TPO) (in pursuance to the directions of the Learned Dispute Resolution Panel (Ld. DRP), erred in not accepting the returned income of the Appellant under normal provisions of the Income Tax Act, 1961 (‘the Act’) amounting to Rs. 2,21,33,99,386/- and enhancing the same by Rs. 5,80,32,672/- and also erred

M/S TATA GLOBAL BEVERAGES LIMITED,KOLKATA vs. THE DCIT, CIRCLE-4(2), KOLKATA, KOLKATA

In the result, the appeals filed by the assessee for AY 2012-

Bench: Dr. Manish Borad & Sonjoy Sarma

Transfer Pricing Officer (Ld. TPO) (in pursuance to the directions of the Learned Dispute Resolution Panel (Ld. DRP), erred in not accepting the returned income of the Appellant under normal provisions of the Income Tax Act, 1961 (‘the Act’) amounting to Rs. 2,21,33,99,386/- and enhancing the same by Rs. 5,80,32,672/- and also erred

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

In the result, the appeal of the assessee is allowed

Bench: Duvvuru Rl Reddy, Vp & Shri Rajesh Kumar, Am M/S Philips India Limited Dcit, Circle 11(1) 3Rd Floor, Tower-A, Dlf Park, Aaykar Bhavan, P-7, 08 Block Af, Major Arterial Chowringhee Square, Road, New Town (Rajarhat), Vs. Kolkata-700069, Kolkata-700156, West Bengal West Bengal (Appellant) (Respondent) Pan No. Aabcp9487A Assessee By : Shri Ketan Ved, Ar Revenue By : Shri A. Kundu, Cit Dr Date Of Hearing: 07.03.2025 Date Of Pronouncement : 11.03.2025

transfer pricing adjustment stands deleted. Consequently, ground nos. 6 the assessee’s appeal stand allowed. 023. The issue raised in ground no.7, is against the disallowance of expenses of ₹7,50,50,000/- u/s 14A of the Act in relation to earning of exempt income. 024. The facts in brief are that during the year under consideration, the appellant

M/S TDK INDIA PRIVATE LIMITED,KOLKATA vs. DCIT CIRCLE 11(1), KOLKATA, DELHI AND KOLKATA

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

Bench: Shri Rajesh Kumar, Am & Shripradip Kumar Choubey, Jm M/S Tdk India Private Limited Dcit, Circle 11(1), Kolkata Wbidc Growth Centre, Kulia Aayakar Bhawan, P-7 Kanchrapara Road, Po Ns Chowringhee Square, Sanatorium,Kalyani, Nadia, Vs. 6Th Floor, Roomno.18, Kolkata-741251, Kolkata-700069, West Bengal West Bengal (Appellant) (Respondent) Pan No. Aaaci6950Q Assessee By : Shri Arjit Chakraborthy, Ar Revenue By : Shri S.B. Chakraborthy, Dr Date Of Hearing: 14.11.2025 Date Of Pronouncement: 05.12.2025

Transfer Pricing Officer/ Hon'ble DRP 1. 2011-12 Approach accepted by TPO - No adjustment done TNMM 2. 2012-13 Approach accepted by TPO - No adjustment done TNMM 3. 2013-14 Approach accepted by TPO - No adjustment done TNMM 4. 2014-15 Approach accepted by TPO - No adjustment done TNMM 5. 2015-16 Adjustment deleted by TPO post DRP Direction

PRAMOD LAKRA,DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 11(1), KOLKATA, KOLKATA vs. PHILLIPS CARBON BLACK LTD., KOLKATA

In the result, all the appeals of the revenue are dismissed and the appeal filed by the assessee is partly allowed for statistical purposes

Bench: Shri Pradip Kumar Choubey&Shri Sanjay Awasthi]

Price as defined in clause (4) of Section 92f of the Act, where the transfer of such goods or services is a specified domestic transaction referred to Section 92BA. The Ld. D.R has further submitted that the Ld. CIT(A) has further committed wrong in not appreciating the fact that the assessee is generating unit [CPP] account as such claim

PCBL LIMITED,KOLKATA vs. A.C.I.T., CIRCLE - 11(1),, KOLKATA

In the result, all the appeals of the revenue are dismissed and the appeal filed by the assessee is partly allowed for statistical purposes

Bench: Shri Pradip Kumar Choubey&Shri Sanjay Awasthi]

Price as defined in clause (4) of Section 92f of the Act, where the transfer of such goods or services is a specified domestic transaction referred to Section 92BA. The Ld. D.R has further submitted that the Ld. CIT(A) has further committed wrong in not appreciating the fact that the assessee is generating unit [CPP] account as such claim

PRAMOD LAKRA,DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE -11(1), KOLKATA, KOLKATA vs. PHILIPS CARBON BLACK LTD , KOLKATA

In the result, all the appeals of the revenue are dismissed and the appeal filed by the assessee is partly allowed for statistical purposes

Bench: Shri Pradip Kumar Choubey&Shri Sanjay Awasthi]

Price as defined in clause (4) of Section 92f of the Act, where the transfer of such goods or services is a specified domestic transaction referred to Section 92BA. The Ld. D.R has further submitted that the Ld. CIT(A) has further committed wrong in not appreciating the fact that the assessee is generating unit [CPP] account as such claim

PRAMOD LAKRA, DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-11(1), KOLKATA, KOLKATA vs. PHILLIPS CARBON BLACK LTD, KOLKATA

In the result, all the appeals of the revenue are dismissed and the appeal filed by the assessee is partly allowed for statistical purposes

Bench: Shri Pradip Kumar Choubey&Shri Sanjay Awasthi]

Price as defined in clause (4) of Section 92f of the Act, where the transfer of such goods or services is a specified domestic transaction referred to Section 92BA. The Ld. D.R has further submitted that the Ld. CIT(A) has further committed wrong in not appreciating the fact that the assessee is generating unit [CPP] account as such claim

PRAMOD LAKRA, DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 11(1), KOLKATA, KOLKATA vs. PHILLIPS CARBON BLACK LTD, KOLKATA

In the result, all the appeals of the revenue are dismissed and the appeal filed by the assessee is partly allowed for statistical purposes

Bench: Shri Pradip Kumar Choubey&Shri Sanjay Awasthi]

Price as defined in clause (4) of Section 92f of the Act, where the transfer of such goods or services is a specified domestic transaction referred to Section 92BA. The Ld. D.R has further submitted that the Ld. CIT(A) has further committed wrong in not appreciating the fact that the assessee is generating unit [CPP] account as such claim

THE DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 3(2), GANGTOK, GANGTOK SIKKIM vs. SIKKIM STATE COOPERATIVE SUPPLY AND MARKETING FEDERATION LIMITED , GANGTOK SIKKIM

In the result, the appeal filed by the Revenue is dismissed

Bench: Shri Pradip Kumar Choubey & Shri Rakesh Mishra

80G of the Act: 6.2.2 On considering the totality of facts, I find that this cannot be a case of deliberate under reporting of income on part of the appellant. Furthermore, I also note that the appellant has been consistent in offering explanation with regard to the said claim of expenditure in the course of assessment proceedings, penalty proceedings

DCIT, CIR-5(1), , KOLKATA vs. M/S COAL INDIA LTD., KOLKATA

section 37(1) of the Income Tax Act, though claimed by the assessee\ncompany in the return of income. Further, the liability has been raised out\nof fine or penalty imposed by the forest department, and the provision out\nof the liability is also not allowable u/s. 37(1) of the Income Tax Act. In the\npresent case, the assessee

DCIT, CIRCLE - 5(1), KOLKATA, KOLKATA vs. M/S. COAL INDIA LIMITED , KOLKATA

section 37(1) of the Income Tax Act, though claimed by the assessee company in the return of income. Further, the liability has been raised out of fine or penalty imposed by the forest department, and the provision out of the liability is also not allowable u/s. 37(1) of the Income Tax Act. In the present case, the assessee

DCIT, CIRCLE - 5(1), KOLKATA, KOLKATA vs. M/S. COAL INDIA LIMITED , KOLKATA

In the result, the appeals filed by the assessee in ITA Nos

section 37(1) of the Income Tax Act, though claimed by the assessee\ncompany in the return of income. Further, the liability has been raised out\nof fine or penalty imposed by the forest department, and the provision out\nof the liability is also not allowable u/s. 37(1) of the Income Tax Act. In the\npresent case, the assessee

DCIT, CIR-5(1), , KOLKATA vs. M/S COAL INDIA LTD., KOLKATA

section 37(1) of the Income Tax Act, though claimed by the assessee\ncompany in the return of income. Further, the liability has been raised out\nof fine or penalty imposed by the forest department, and the provision out\nof the liability is also not allowable u/s. 37(1) of the Income Tax Act. In the\npresent case, the assessee

M/S COAL INDIA LTD.,KOLKATA vs. DCIT, CIR-5(1), , KOLKATA

section 115JB of the Act is a self-contained code. Explanation to\nsection 115JB of the Act provides certain adjustment to be made in the\ncomputation of book-profit. Apart from the adjustments mentioned in the\nsaid Explanation, no other adjustment can be made in the computation of\nbook-profits under section 115JB of the Act. Hence, the disallowance cannot