ACIT v. Mitsui & Co India (P) Ltd.

155 Taxmann 19Reported decision2023#13485 most cited
7

judgments rely on this decision, according to BharatTax’s citation analysis of 348,356 Indian tax judgments — from 2024 to 2024.

Sections most often in play

Section 10AASection 195Section 234BSection 234CSection 271(1)(c)Section 37(1)Section 80IA(8)Section 90

Issues it is cited on

section 80ia(8)section 9(1)(vii)(b)section 195(2)fees for included servicessection 90(2)business connectionsection 9(1)(vii)section 10aainterest u/s 234bsection 10asection 80iafees for technical services

Judgments citing ACIT v. Mitsui & Co India (P) Ltd.

Avtec Ltd., New Delhi vs. DCIT (Ltu), Circle-1, New Delhi

In the result, the appeal of the assessee is allowed

ITA 7366/DEL/2019[2016-17]Status: DisposedITAT Delhi29 Nov 2024AY 2016-17

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

For Appellant: Shri Salil Kapoor, Sr. AdvFor Respondent: Shri Vipul Kashypa, Sr. DR
Section 10ASection 115JSection 234BSection 80I

…f accounts needs to be rejected and relied on PCIT v R.G. Buildwell Engineers Ltd. [2018] 99 Taxmann 284 (SC). He further stated that there is no Specific finding by the AO with regard to disallowance and relied on ACIT vs. Mitsui & Co India (P) Ltd [2023] 155 Taxmann 19 (Delhi- Tri). The ld AR also pointed out that the expense is to be proved as bogus expenditure - before disallowance and relied on Sheo Bhagwan Goel v ACIT [2022] 139 Taxmann 259 (Raipur-Tri). Similarly, he stated that Mere estimation of disallowance under facts and circumstances is not permissible and relied on J.J. Enterprises vs. CIT 254…

Avtec Ltd., New Delhi vs. ACIT (Ltu), Circle-1, New Delhi

In the result, the appeal of the assessee is allowed

ITA 1008/DEL/2019[2012-13]Status: DisposedITAT Delhi29 Nov 2024AY 2012-13

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

For Appellant: Shri Salil Kapoor, Sr. AdvFor Respondent: Shri Vipul Kashypa, Sr. DR
Section 10ASection 115JSection 234BSection 80I

…f accounts needs to be rejected and relied on PCIT v R.G. Buildwell Engineers Ltd. [2018] 99 Taxmann 284 (SC). He further stated that there is no Specific finding by the AO with regard to disallowance and relied on ACIT vs. Mitsui & Co India (P) Ltd [2023] 155 Taxmann 19 (Delhi- Tri). The ld AR also pointed out that the expense is to be proved as bogus expenditure - before disallowance and relied on Sheo Bhagwan Goel v ACIT [2022] 139 Taxmann 259 (Raipur-Tri). Similarly, he stated that Mere estimation of disallowance under facts and circumstances is not permissible and relied on J.J. Enterprises vs. CIT 254…

Avtec Ltd., New Delhi vs. DCIT (Ltu), Circle-1, New Delhi

In the result, the appeal of the assessee is allowed

ITA 8081/DEL/2018[2013-14]Status: DisposedITAT Delhi29 Nov 2024AY 2013-14

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

For Appellant: Shri Salil Kapoor, Sr. AdvFor Respondent: Shri Vipul Kashypa, Sr. DR
Section 10ASection 115JSection 234BSection 80I

…f accounts needs to be rejected and relied on PCIT v R.G. Buildwell Engineers Ltd. [2018] 99 Taxmann 284 (SC). He further stated that there is no Specific finding by the AO with regard to disallowance and relied on ACIT vs. Mitsui & Co India (P) Ltd [2023] 155 Taxmann 19 (Delhi- Tri). The ld AR also pointed out that the expense is to be proved as bogus expenditure - before disallowance and relied on Sheo Bhagwan Goel v ACIT [2022] 139 Taxmann 259 (Raipur-Tri). Similarly, he stated that Mere estimation of disallowance under facts and circumstances is not permissible and relied on J.J. Enterprises vs. CIT 254…

Avtec Ltd., New Delhi vs. ACIT (Ltu), Circle-1, New Delhi

In the result, the appeal of the assessee is allowed

ITA 4716/DEL/2018[2015-16]Status: DisposedITAT Delhi29 Nov 2024AY 2015-16

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

For Appellant: Shri Salil Kapoor, Sr. AdvFor Respondent: Shri Vipul Kashypa, Sr. DR
Section 10ASection 115JSection 234BSection 80I

…f accounts needs to be rejected and relied on PCIT v R.G. Buildwell Engineers Ltd. [2018] 99 Taxmann 284 (SC). He further stated that there is no Specific finding by the AO with regard to disallowance and relied on ACIT vs. Mitsui & Co India (P) Ltd [2023] 155 Taxmann 19 (Delhi- Tri). The ld AR also pointed out that the expense is to be proved as bogus expenditure - before disallowance and relied on Sheo Bhagwan Goel v ACIT [2022] 139 Taxmann 259 (Raipur-Tri). Similarly, he stated that Mere estimation of disallowance under facts and circumstances is not permissible and relied on J.J. Enterprises vs. CIT 254…

Avtec Ltd., New Delhi vs. ACIT (Ltu), Circle-1, New Delhi

In the result, the appeal of the assessee is allowed

ITA 2893/DEL/2018[2014-15]Status: DisposedITAT Delhi29 Nov 2024AY 2014-15

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

For Appellant: Shri Salil Kapoor, Sr. AdvFor Respondent: Shri Vipul Kashypa, Sr. DR
Section 10ASection 115JSection 234BSection 80I

…f accounts needs to be rejected and relied on PCIT v R.G. Buildwell Engineers Ltd. [2018] 99 Taxmann 284 (SC). He further stated that there is no Specific finding by the AO with regard to disallowance and relied on ACIT vs. Mitsui & Co India (P) Ltd [2023] 155 Taxmann 19 (Delhi- Tri). The ld AR also pointed out that the expense is to be proved as bogus expenditure - before disallowance and relied on Sheo Bhagwan Goel v ACIT [2022] 139 Taxmann 259 (Raipur-Tri). Similarly, he stated that Mere estimation of disallowance under facts and circumstances is not permissible and relied on J.J. Enterprises vs. CIT 254…

Avtec Ltd., New Delhi vs. DCIT (Ltu), New Delhi

In the result, the appeal of the assessee is allowed

ITA 6332/DEL/2016[2012-13]Status: DisposedITAT Delhi29 Nov 2024AY 2012-13

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

For Appellant: Shri Salil Kapoor, Sr. AdvFor Respondent: Shri Vipul Kashypa, Sr. DR
Section 10ASection 115JSection 234BSection 80I

…f accounts needs to be rejected and relied on PCIT v R.G. Buildwell Engineers Ltd. [2018] 99 Taxmann 284 (SC). He further stated that there is no Specific finding by the AO with regard to disallowance and relied on ACIT vs. Mitsui & Co India (P) Ltd [2023] 155 Taxmann 19 (Delhi- Tri). The ld AR also pointed out that the expense is to be proved as bogus expenditure - before disallowance and relied on Sheo Bhagwan Goel v ACIT [2022] 139 Taxmann 259 (Raipur-Tri). Similarly, he stated that Mere estimation of disallowance under facts and circumstances is not permissible and relied on J.J. Enterprises vs. CIT 254…

M/S. Avtec Ltd., New Delhi vs. DCIT (Ltu), New Delhi

In the result, the appeal of the assessee is allowed

ITA 1009/DEL/2015[2011-12]Status: DisposedITAT Delhi29 Nov 2024AY 2011-12

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

For Appellant: Shri Salil Kapoor, Sr. AdvFor Respondent: Shri Vipul Kashypa, Sr. DR
Section 10ASection 115JSection 234BSection 80I

…f accounts needs to be rejected and relied on PCIT v R.G. Buildwell Engineers Ltd. [2018] 99 Taxmann 284 (SC). He further stated that there is no Specific finding by the AO with regard to disallowance and relied on ACIT vs. Mitsui & Co India (P) Ltd [2023] 155 Taxmann 19 (Delhi- Tri). The ld AR also pointed out that the expense is to be proved as bogus expenditure - before disallowance and relied on Sheo Bhagwan Goel v ACIT [2022] 139 Taxmann 259 (Raipur-Tri). Similarly, he stated that Mere estimation of disallowance under facts and circumstances is not permissible and relied on J.J. Enterprises vs. CIT 254…

ACIT v. Mitsui & Co India (P) Ltd. (155 Taxmann 19) — Cited in 7 Judgments | BharatTax