DEPUTY COMMISSIONER OF INCOME TAX, NAGPUR vs. AVANTHA HOLDINGS LIMITED, CHANDRAPUR

In the result, appeal filed by the assessee is dismissed

transfer pricing proceedings has not been disputed either\nby the TPO or by the AO. From this credit rating it is apparent that the AE will\nnot be in a position to derive any economic benefit out of it when it comes to\ngetting the loan at a lower interest rate on the strength of higher credit rating

BAJAJ STEEL INDUSTIES LTD.,NAGPUR vs. ASSESSIG OFFICER, NATIONAL E-ASSESSMENT CENTRE, DELHI

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

Bench: Shri Satbeer Singh Godara & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita No.20/Nag/2023 िनधा"रण वष" / Assessment Year : 2018-19 Bajaj Steel Industries The Assessing Officer, Limited, Vs National E-Assessment 539/540, Imambada Road, Centre, Delhi. Maharashtra. Pan: Aaacb 5340 H Appellant / Assessee Respondent / Revenue Assessee By Shri Rajesh V. Loya – Ca Revenue By Shri Kailash Kanojiya – Sr.Dr Date Of Hearing 28/08/2023 Date Of Pronouncement 30/08/2023 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Filed By The Assessee Is Directed Against The Order Under Section 250 Of The Income Tax Act, 1961 Passed By The Ld.Cit(A)[Nfac], Delhi Dated 22.12.2022 For A.Y.2018-19 Emanating From Assessment Order Under Section 143(3) R.W.S. 144B Of The Act Dated 24.04.2021. The Assessee Has Raised Following Grounds Of Appeal : Bajaj Steel Industries Limited [A]

Transfer Pricing Report and filing of Income Tax return during that period. Hence the same could not be forwarded to the counsel. 3. The notice dated 5-12-2022 was received and the submissions were under preparation. There were 13 Grounds for adjudication on different issues. The preparation of submission alongwith enclosures took substantial time. The same could be finalized

TAJSHREE AUTOWHEELS PRIVATE LIMITED,NAGPUR vs. ACIT CIRCLE-4, NAGPUR

In the result, assessee’s appeal is allowed for statistical purposes

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

251 ITR 263 (SC); Lowry v. Consolidated African Selection Trust 8 ITR Suppl 88). However, it is only because of the deeming fiction provided in such sections i.e. section 68 or 56(2)(viib) that in certain circumstances the amount received as capital can be deemed to be income. However, section 68 and 56(2)(viib) being the deeming provisions

M/S MAHESHWARI COAL BENEFICATION & INFRASTRUCTURE P. LTD,BILASPUR vs. ACIT CENTRAL CIRCLE-1(1), NAGPUR

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant Mmber

section 153D dated 29/09/2021 is in mechanical/routine manner without application of mind by Addl.CIT, which is merely a formality, an empty ritual and as such it leads to flagrant violation of the rules of law. 45. The third contention of the learned A.R. is that while granting such mechanical approval dated 29/09/2021 under section 153D for the assessment year

M/S MAHESHWARI COAL BENEFICATION & INFRASTRUCTURE P LTD.,BILASPUR vs. ACIT CENTRAL CIRCLE 1(1), NAGPUR

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant Mmber

section 153D dated 29/09/2021 is in mechanical/routine manner without application of mind by Addl.CIT, which is merely a formality, an empty ritual and as such it leads to flagrant violation of the rules of law. 45. The third contention of the learned A.R. is that while granting such mechanical approval dated 29/09/2021 under section 153D for the assessment year

M/S MAHESHWARI COAL BENEFICATION & INFRASTRUCTURE P LTD,BILASPUR vs. ACIT CENTRAL CIRCLE 1(1), NAGPUR

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant Mmber

section 153D dated 29/09/2021 is in mechanical/routine manner without application of mind by Addl.CIT, which is merely a formality, an empty ritual and as such it leads to flagrant violation of the rules of law. 45. The third contention of the learned A.R. is that while granting such mechanical approval dated 29/09/2021 under section 153D for the assessment year

M/S MAHESHWARI COAL BENEFICATION & INFRASTRUCTURE P LTD.,BILASPUR vs. ACIT CENTRAL CIRCLE 1(1), NAGPUR

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant Mmber

section 153D dated 29/09/2021 is in mechanical/routine manner without application of mind by Addl.CIT, which is merely a formality, an empty ritual and as such it leads to flagrant violation of the rules of law. 45. The third contention of the learned A.R. is that while granting such mechanical approval dated 29/09/2021 under section 153D for the assessment year

M/S MAHESHWARI COAL BENEFICATION & INFRASTRUCTURE P LTD.,BILASPUR vs. ACIT CENTRAL CIRCLE 1(1), NAGPUR

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant Mmber

section 153D dated 29/09/2021 is in mechanical/routine manner without application of mind by Addl.CIT, which is merely a formality, an empty ritual and as such it leads to flagrant violation of the rules of law. 45. The third contention of the learned A.R. is that while granting such mechanical approval dated 29/09/2021 under section 153D for the assessment year

M/S MAHESHWARI COAL BENEFICATION & INFRASTRUCTURE P LTD.,BILASPUR vs. ACIT CENTRAL CIRCLE 1(1), NAGPUR

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant Mmber

section 153D dated 29/09/2021 is in mechanical/routine manner without application of mind by Addl.CIT, which is merely a formality, an empty ritual and as such it leads to flagrant violation of the rules of law. 45. The third contention of the learned A.R. is that while granting such mechanical approval dated 29/09/2021 under section 153D for the assessment year