251 CTR 290 (Del) CIT v. Tata Communication Internet Services Ltd.

DCIT, Circle- 13(1), New Delhi vs. Jagson International Ltd., New Delhi

Bench: Sh. C. N. Prasaddr. B. R. R. Kumar

…urt, the appeal has been allowed with following remarks:- "I have considered the issue and perused the order of the Hon'ble High Court available at pages 1 to 8 of the paper book wherein the High Court considered its earlier decision in Jagson International (214 CTR 227) wherein the 'Deepsea Madrill' vessel owned or leased by the assessee was held to be ships for the purposes of section 33AC. It was noted that the vessel owned by the assessee was a qualifying ship in terms of clause(a) of section 115VD and the very nature of the activity in which the assessee engaged is to carry out operations at 17 CO No. 83/De…

DCIT, Circle- 13(1), New Delhi vs. Jagson International Ltd., New Delhi

Bench: Sh. C. N. Prasaddr. B. R. R. Kumar

…urt, the appeal has been allowed with following remarks:- "I have considered the issue and perused the order of the Hon'ble High Court available at pages 1 to 8 of the paper book wherein the High Court considered its earlier decision in Jagson International (214 CTR 227) wherein the 'Deepsea Madrill' vessel owned or leased by the assessee was held to be ships for the purposes of section 33AC. It was noted that the vessel owned by the assessee was a qualifying ship in terms of clause(a) of section 115VD and the very nature of the activity in which the assessee engaged is to carry out operations at 17 CO No. 83/De…

DCIT, New Delhi vs. M/S. Jagson International Ltd., New Delhi

In the result, ITA.No.276/Del

Bench: Shri R.K. Panda & Shri Narendra Kumar Choudhary

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCHES “D” : NEW DELHI BEFORE SHRI R.K. PANDA, ACCOUNTANT MEMBER AND SHRI NARENDRA KUMAR CHOUDHARY, JUDICIAL MEMBER ITA Nos.1001 & 1002/Del./2016 Assessment Years 2012-13 & 2013-14 The Dy. CIT, M/s. Jagson International Circle–13 (1), Ltd., 3rd Floor, Vandana Room No. 316-A, vs., Building, Tolstoy Marg, C.R. Building, New Delhi – 110 001. New Delhi. PAN AAACJ2147A (Appellant) (Respondent) ITA No.276/Del./2017 Assessment Year 2014-15 The Dy. CIT, M/s. Jagson International Circle–13 (1), Ltd., 3rd Floor, Vandana Room No. 316-A, vs., Building, Tolstoy Marg, C.R. Building,…

DCIT, New Delhi vs. M/S. Jagson International Ltd., New Delhi

In the result, ITA.No.276/Del

Bench: Shri R.K. Panda & Shri Narendra Kumar Choudhary

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCHES “D” : NEW DELHI BEFORE SHRI R.K. PANDA, ACCOUNTANT MEMBER AND SHRI NARENDRA KUMAR CHOUDHARY, JUDICIAL MEMBER ITA Nos.1001 & 1002/Del./2016 Assessment Years 2012-13 & 2013-14 The Dy. CIT, M/s. Jagson International Circle–13 (1), Ltd., 3rd Floor, Vandana Room No. 316-A, vs., Building, Tolstoy Marg, C.R. Building, New Delhi – 110 001. New Delhi. PAN AAACJ2147A (Appellant) (Respondent) ITA No.276/Del./2017 Assessment Year 2014-15 The Dy. CIT, M/s. Jagson International Circle–13 (1), Ltd., 3rd Floor, Vandana Room No. 316-A, vs., Building, Tolstoy Marg, C.R. Building,…

DCIT, New Delhi vs. M/S. Jagson International Ltd., New Delhi

In the result, ITA.No.276/Del

Bench: Shri R.K. Panda & Shri Narendra Kumar Choudhary

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCHES “D” : NEW DELHI BEFORE SHRI R.K. PANDA, ACCOUNTANT MEMBER AND SHRI NARENDRA KUMAR CHOUDHARY, JUDICIAL MEMBER ITA Nos.1001 & 1002/Del./2016 Assessment Years 2012-13 & 2013-14 The Dy. CIT, M/s. Jagson International Circle–13 (1), Ltd., 3rd Floor, Vandana Room No. 316-A, vs., Building, Tolstoy Marg, C.R. Building, New Delhi – 110 001. New Delhi. PAN AAACJ2147A (Appellant) (Respondent) ITA No.276/Del./2017 Assessment Year 2014-15 The Dy. CIT, M/s. Jagson International Circle–13 (1), Ltd., 3rd Floor, Vandana Room No. 316-A, vs., Building, Tolstoy Marg, C.R. Building,…

DCIT, Circle- 8(1), New Delhi vs. Ebix Software India Pvt. Ltd., New Delhi

Bench: Shri R.K. Panda & Ms Suchitra Kamble

…granted in the initial year, the same cannot be withdrawn. For the above proposition, he relied on the following decisions:- i) 355 ITR 14 (Del) CIT v Delhi Press Patra Prakashan Ltd. ii) 251 CTR 290 (Del) CIT v Tata Communication Internet Services Ltd. iii) 214 CTR 227 (Del) CIT vs. Jagson International Ltd. iv) 216 ITR 548 (Bom) CIT vs. Paul Brothers. v) 349 ITR 309 (Bom) CIT vs. Western Outdoor Interactive (P) Ltd. vi) 349 ITR 150 (Bom) Direct Information (P) Ltd. Vs. ITO vii) 123 ITR 669 (Guj) C.I.T. v Saurashtra Cement and Chemicals. viii) 267 ITR 774 (AP) G.B. Bros and Konda Rajagopala Chetty vs. ITO ix) 1…

The Commissioner of Income Tax vs. Regency Creations Ltd

…software. It was argued, besides, that the rule of consistency, enunciated by the Supreme Court in Radhasoami Satsang Soami Bagh, Agra v. CIT AIR 1992 SC 377 = (1992) 193 ITR 321 (SC) and followed by this Court in CIT v. Jagson International Limited 2008 214 CTR 227 (Del), estopped the Revenue from contending that the asseessee did not possess the requisite approval. It is also submitted that the Tribunal had correctly relied upon a clarification dated 31.03.2011 which put the matter beyond any shadow of doubt, i.e. that Press Notes 2 and 5 enured in favor of the assessee. They could clearly avail the…