COMMISSIONER OF INCOME TAX v. ODEON BUILDERS P. LTD.

CMV EDUCATION SOCIETY,NEW DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX ,CENTRAL CIRCLE-6, DELHI

Appeal is allowed

Bench: SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER AND SHIR S. RIFAUR RAHMAN (Accountant Member)

…IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI BENCH: ‘B’ NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER AND SHIR S. RIFAUR RAHMAN, ACCOUNTANT MEMBER Assessment Year: 2011-12 Vs. DCIT, CMV Education Society, 2D, MIG Flats, W.E.A. Central Circle-6, 17A/56, Gulabi Bagh, Delhi New Delhi PAN: AAAAC1679A (Appellant) (Respondent) Assessee by Dr. Rakesh Gupta, Adv. Sh. Somil Aggarwal, Adv. Department by Ms. Pooja Swaroop, CIT(DR) Date of hearing 23.06.2025 Date of pronouncement 09.07.2025 ORDER PER SATBEER SINGH GODARA, JM This assessee’s appeal for assessment year 2011-12, arises against the Commissioner of I…

DCIT, NEW DELHI vs. M/S. CVENT INDIA PVT. LTD., NEW DELHI

Appeal is allowed

Bench: SHRI MAHAVIR SINGH, VICE PRESIDENT, SHRI NAVEEN CHANDRA (Accountant Member)

…IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI BENCH: ‘B’ NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER AND SHIR S. RIFAUR RAHMAN, ACCOUNTANT MEMBER Assessment Year: 2011-12 Vs. DCIT, CMV Education Society, 2D, MIG Flats, W.E.A. Central Circle-6, 17A/56, Gulabi Bagh, Delhi New Delhi PAN: AAAAC1679A (Appellant) (Respondent) Assessee by Dr. Rakesh Gupta, Adv. Sh. Somil Aggarwal, Adv. Department by Ms. Pooja Swaroop, CIT(DR) Date of hearing 23.06.2025 Date of pronouncement 09.07.2025 ORDER PER SATBEER SINGH GODARA, JM This assessee’s appeal for assessment year 2011-12, arises against the Commissioner of I…

TERAS STEELS PRIVATE LIMITED (EARLIER KNOWN AS M/S. ACCIL STEELS PVT. LTD.),NEW DELHI vs. DCIT CENTRAL CIRCLE-29, NEW DELHI

In the result, all captioned appeals/Cross-Objections etc

Bench: Shri Pradip Kumar Kedia & Shri Sudhir Kumar

…he Hon’ble Delhi High Court in the case of Surendra Kumar Jain, Virendra Kumar Jain vs Pr.CIT (Central-III), New Delhi & Anr.(2018) 406 ITR 328 (Del). The Hon’ble Delhi High took cognizance of Full Bench Judgment in the case of CIT vs Odeon Builders (P.) Ltd. 393 ITR 27 (Delhi) and that of division bench in CIT vs. Sudhir Choudhrie (2005) 278 ITR 490 (Delhi) and observed in unequivocal terms that once the order is listed for pronouncement in the Income Tax Appellate Tribunal, the department representative or the Commissioner of Income Tax (Judicial) should be taken to be aware of the order. From that point, it is…

RAJNISH J. KARKI,NEW DELHI vs. ITO WARD-32(5), NEW DELHI

The appeal of the assessee is allowed

Bench: Sh. Saktijit Dey & Sh. N. K. Billaiyaassessment Year: 2012-13 Rajnish J. Karki Ito L-1/13, Hauz Khas Enclave, Vs Ward-32(5) New Delhi New Delhi Pan No. Ajepk8684C (Appellant) (Respondent)

…der of the ITAT was also simultaneously served on the same date on the CIT (DR). The limitation period, therefore, began running from that date itself. 4. A Full Bench of this Court in CIT v. Odeon Builders (P.) Ltd. f20171 80 taxmann.com 180/247 Taxman 184/393 ITR 27categorically held that in the context of Section 260A of the Act, the limitation period for filing an appeal against an order of the ITAT would begin to run immediately upon a copy of the order being received by the CIT (Judicial).This Court rejected the contention of the Revenue that till the 'concerned jurisdictional CIT' received the order of t…

QUALCOMM INCORPORATED,USA vs. DCIT, CIRCLE- 3(1)(1), INTL. TAXATION, NEW DELHI

Bench: Shri N.K. Billaiya & Shri Sudhanshu Srivastava

…Now the question arises is as to ‘what is the meaning by received by Principal CIT or Chief Commissioner or Principal Commissioner or Commissioner?. 16. This has been answered by the Hon’ble High Court of Delhi in the case of Odeon Builders Private Limited 393 ITR 27 though this judgement is delivered in the context of section 260(2A) of the Act but, as exhibited elsewhere, provisions of section 153(2A) are similarly worded as section 260(2A) of the Act. 17. The Hon'ble High Court, thus, observed as under: “1. The central question that arises for consideration before this Bench is whether the words "the Pr…

QUALCOMM INCORPORATED,USA vs. DCIT, CIRCLE- 3(1)(1), INTL. TAXATION, NEW DELHI

Bench: Shri N.K. Billaiya & Shri Sudhanshu Srivastava

…Now the question arises is as to ‘what is the meaning by received by Principal CIT or Chief Commissioner or Principal Commissioner or Commissioner?. 16. This has been answered by the Hon’ble High Court of Delhi in the case of Odeon Builders Private Limited 393 ITR 27 though this judgement is delivered in the context of section 260(2A) of the Act but, as exhibited elsewhere, provisions of section 153(2A) are similarly worded as section 260(2A) of the Act. 17. The Hon'ble High Court, thus, observed as under: “1. The central question that arises for consideration before this Bench is whether the words "the Pr…

QUALCOMM INCORPORATED,USA vs. DCIT, CIRCLE- 3(1)(1), INTL. TAXATION, NEW DELHI

Bench: Shri N.K. Billaiya & Shri Sudhanshu Srivastava

…Now the question arises is as to ‘what is the meaning by received by Principal CIT or Chief Commissioner or Principal Commissioner or Commissioner?. 16. This has been answered by the Hon’ble High Court of Delhi in the case of Odeon Builders Private Limited 393 ITR 27 though this judgement is delivered in the context of section 260(2A) of the Act but, as exhibited elsewhere, provisions of section 153(2A) are similarly worded as section 260(2A) of the Act. 17. The Hon'ble High Court, thus, observed as under: “1. The central question that arises for consideration before this Bench is whether the words "the Pr…

QUALCOMM INCORPORATED,HYDERABAD vs. DCIT, CIRCLE- 3(1)(1), INTERNATIONAL TAXATION, NEW DELHI

Bench: Shri N.K. Billaiya & Shri Sudhanshu Srivastava

…Now the question arises is as to ‘what is the meaning by received by Principal CIT or Chief Commissioner or Principal Commissioner or Commissioner?. 16. This has been answered by the Hon’ble High Court of Delhi in the case of Odeon Builders Private Limited 393 ITR 27 though this judgement is delivered in the context of section 260(2A) of the Act but, as exhibited elsewhere, provisions of section 153(2A) are similarly worded as section 260(2A) of the Act. 17. The Hon'ble High Court, thus, observed as under: “1. The central question that arises for consideration before this Bench is whether the words "the Pr…

P.K.COTTON MILLS PVT. LTD.,,MEERUT vs. PR.CIT, MEERUT

The appeal of the assessee is allowed

Bench: Shri R. K. Panda & Ms Suchitra Kamblei.T.A. No. 6039/Del/2017 (A.Y 2008-09) (Through Physical Hearing) P. K. Cotton Mills Pvt. Ltd. Vs Pr. Cit C/O. Rra Tax India, D-28, Meerut, South Extension, Part-1, New Uttar Pradesh Delhi Aadcp4270D (Appellant) (Respondent)

…1 IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH: ‘F’ NEW DELHI BEFORE SHRI R. K. PANDA ACCOUNTANT MEMBER AND MS SUCHITRA KAMBLE, JUDICIAL MEMBER I.T.A. No. 6039/DEL/2017 (A.Y 2008-09) (THROUGH PHYSICAL HEARING) P. K. Cotton Mills Pvt. Ltd. Vs Pr. CIT C/o. RRA Tax India, D-28, Meerut, South Extension, Part-1, New Uttar Pradesh Delhi AADCP4270D (APPELLANT) (RESPONDENT) Appellant by Dr. Rakesh Gupta, Adv Respondent by Sh. Mahesh Thakur, Sr. DR Date of Hearing 06.04.2021 Date of Pronouncement 20.04.2021 ORDER PER SUCHITRA KAMBLE, JM This appeal is filed by the assessee against order dated 25/07/2017 passe…

SHRI LAL MAHAL LTD.,NEW DELHI vs. DCIT, CIRCLE- 8(1), NEW DELHI

In the result appeal of the assessee is allowed

Bench: Shri Amit Shukla & Shri L.P. Sahuasstt. Year: 2010-11

…resentative, i.e., 6.3.2018; or when the order was received in the office of CIT (Judicial) on 6.4.2018 as mentioned in the penalty order. This precise issue has been dealt by the Hon’ble Delhi High Court in the case of CIT vs. Odeon Builders Pvt. Ltd. (2017) 393 ITR 27 which has been reiterated and followed in the case of Surender Kumar Jain vs. Pr.CIT by Hon’ble High Court. The relevant observations of the Hon’ble High Court in the case of Surender Kumar Jain vs. Pr. CIT (supra) reads as under :- “5. It is quite evident from the decision in Odeon Builders (P.) Ltd. (supra) that limitation begins (for any purpos…