(i) Sultana Begum v. Prem Chand Jain

Jubilant Pharmova Limited, Uttar Pradesh vs. DCIT/ACIT (Central), Moradabad

In the result, all two appeals of the assessee are allowed

Bench: Shrivikas Awasthy & Shrisanjay Awasthiआ.अ.सं/.I.T.A No.1970/Del/2022 िनधा"रणवष"/Assessment Year: 2018-19 बनाम Jubilant Pharmova Ltd., Acit-1, Plot-1A, Sector-16A, District G.B. Vs. Moradabad-New, Nagar, Noida,Uttar Pradesh. Uttar Pradesh. Pan No.Aabcv0200H अपीलाथ" Appellant ""यथ"/Respondent & आ.अ.सं/.I.T.A No.5713/Del/2024 िनधा"रणवष"/Assessment Year: 2021-22 बनाम Jubilant Pharmova Ltd., Dcit/Acit (Central), Bhartiagram Gajraula, Vs. Income Tax Department, Plot-1A, Sector-16A,District G.B. Moradabad, Uttar Pradesh. Nagar, Noida,Uttar Pradesh. Pan No.Aabcv0200H अपीलाथ" Appellant ""यथ"/Respondent

…, reiterates the urgency that sets the tone for the interpretation of section 144C itself.” The Division Bench affirmed aforesaid findings of the Hon’ble Single Judge and further after considering various decisions viz.Sultana Begum vs. Prem Chand Jain [1997] 1 SCC 373; CIT vs. Hindustan Bulk Carriers [2023] 126 Taxman 321/259 ITR 449; & Franklin Templeton Trustee Services (P.) Ltd. vs Amruta Garg 124 taxmann.com 326, held as under:- “23. Further, similar non-obstante clause is also used in section 144C(4) with a same limited purpose to imply, even though there might be a larger time limit under Section 153, once…

Airbnb Payments India Private Limited, Gurugram vs. The Deputy Commissioner of Income Tax, Circle 1(1), Gurugram, Haryana

Bench: Shri Vikas Awasthy & Shri Sanjay Awasthiआ.अ.सं/.I.T.A No.5517/Del/2024 िनधा"रणवष"/Assessment Year: 2021-22 बनाम Airbnb Payments India Private Limited, The Dcit Circle 1(1), Level 9, Spaze I Tech Park, A1 Tower,Sector Vs. Gurugram,Haryana. 49, Sohna Road, Gurugram, Haryana.India. Pan No. Aanca6203B अपीलाथ" Appellant ""यथ"/Respondent

…ITA Nos. 5517/D/24, 6114/D/24, 5522/D/24, 5528/D/24, 6081/D/24 & 2348/D/22 IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “I”NEW DELHI BEFORE SHRI VIKAS AWASTHY, JUDICIAL MEMBER AND SHRI SANJAY AWASTHI, ACCOUNTANT MEMBER आ.अ.सं/.I.T.A No.5517/Del/2024 िनधा"रणवष"/Assessment Year: 2021-22 बनाम AIRBNB PAYMENTS INDIA PRIVATE LIMITED, THE DCIT Circle 1(1), Level 9, Spaze I Tech Park, A1 Tower,Sector Vs. Gurugram,Haryana. 49, Sohna Road, Gurugram, Haryana.INDIA. PAN NO. AANCA6203B अपीलाथ" Appellant ""यथ"/Respondent Assessee by Ms. Taranjeet Kaur, AR &Shri Kashish Gupta, AR Revenue by Shri Dharm Veer Singh, CIT DR आ…

Pioneer India Electronics Private Limited, Gurgaon vs. DCIT, Circle 3(1), Gurgaon/ Assessment Unit/Income Tax Department, Gurgaon

In the result, appeals of the assessees are allowed

Bench: Shri Vikas Awasthy & Shri Sanjay Awasthiआअसं.5461/धिल्ली/2024(नि.व. 2021-22) Pioneer India Electronics P. Ltd., Unit No. 3, 10Th Floor Ambience Corporate, Tower-Ii, Nh-8 Plot No. 3 Ambience Island, Gurugram, Haryana 122002 ...... अपीलार्थी/Appellant Pan: Aaecp-8368-H बिाम Vs. Deputy Commissioner Of Income Tax, ..... प्रनिवादी/Respondent Circle 3(1), Gurgaon, Haryana 122001 आअसं.5951/धिल्ली/2024(नि.व. 2021-22) Mitsui & Co India P. Ltd., 4Th Floor, Worldmark 3, Asset 7, Aero City, Nh-8, New Delhi 110037 ...... अपीलार्थी/Appellant Pan: Aadcm-4488-J बिाम Vs. Deputy Commissioner Of Income Tax, ..... प्रनिवादी/Respondent Circle 16(1), Cr Building, Delhi 110002 आअसं.5999/धिल्ली/2024(नि.व. 2021-22) Rohde & Sehwarz India P. Ltd., A-27, First Floor, Mohan Corporate, Mathura Road, New Delhi 110044 ...... अपीलार्थी/Appellant Pan: Aaacr-3267-P बिाम Vs. Assessment Unit/Deputy Commissioner Of Income Tax, Circle 19(1), Cr Building, Ip Estate, New Delhi 110002 ..... प्रनिवादी/Respondent

…reiterates the urgency that sets the tone for the interpretation of section 144C itself.” The Division Bench affirmed aforesaid findings of the Hon’ble Single Judge and further, after considering various decisions viz. Sultana Begum vs. Prem Chand Jain [1997] 1 SCC 373; CIT vs. Hindustan Bulk Carriers [2023] 126 Taxman 321/259 ITR 449; & Franklin Templeton Trustee Services (P.) Ltd. vs Amruta Garg 124 taxmann.com 326, held as under:- “23. Further, similar non-obstante clause is also used in section 144C(4) with a same limited purpose to imply, even though there might be a larger time limit under Section 153, onc…

Fujitsu India Private Limited, Delhi vs. Assistant Commissioner of Income Tax, New Delhi

In the result, appeal of the Assessee is allowed

Bench: Yogesh Kumar U.S. & Shri Krinwant Sahay

…uch directions. The section and the sub-section have to be read as a whole with connected provisions to decipher the meaning and intentions. At this juncture it would be useful to refer to the following decisions: (i) Sultana Begum v. Prem Chand Jain, (1997) 1 SCC 373 at page 381: 21 “11. The statute has to be read as a whole to find out the real intention of the legislature. 12. In Canada Sugar Refining Co. v. R. [1898 AC 735 : 67 LJPC 126] , Lord Davy observed: “Every clause of a statute should be construed with reference to the context and other clauses of the Act, so as, as far as possible, to make a consist…

L T Foods Limited, New Delhi vs. DCIT, Circle-13(1), New Delhi

In the result, appeal of the Assessee is allowed

Bench: Yogesh Kumar U.S. & Shri Krinwant Sahayl T Foods Limited Vs Dcit Unit No. 134, Frist Floor, Circle 13(1) Rectdangle-1, Saket District Centre, New Delhi New Delhi Pan: Aaacl 0259K Appellant Respondent Assessee By Sh. Sh. Neeeraj Jain, Adv, Sh. Ramitkatiyar, Ar. Ms. Manshabhalla, Ca & Sh. Dhruv Seth, Adv Revenue By Sh. S. K. Jadhav, Cit Dr Date Of Hearing 28/01/2026 Date Of Pronouncement 29/01/2026

…uch directions. The section and the sub-section have to be read as a whole with connected provisions to decipher the meaning and intentions. At this juncture it would be useful to refer to the following decisions: (i) Sultana Begum v. Prem Chand Jain, (1997) 1 SCC 373 at page 381: 21 “11. The statute has to be read as a whole to find out the real intention of the legislature. 12. In Canada Sugar Refining Co. v. R. [1898 AC 735 : 67 LJPC 126] , Lord Davy observed: “Every clause of a statute should be construed with reference to the context and other clauses of the Act, so as, as far as possible, to make a consist…

Renew Wind Energy (Rajkot) Private Limited, Delhi vs. Deputy Commissioner of Income-Tax, Circle 19(1), Delhi

In the result, appeals of the Assessees are allowed

Bench: Yogesh Kumar U.S. & Shri Krinwant Sahayrenew Wind Energy (Shivpur) Vs The Deputy Commissioner Of Private Limited, 138, Ansal Income Tax, Circle 19(1) Delhi Chambers, Bhikaji Cama Palace, Range Code-44, C. R. New Delhi Building, I. P. Estate, Pan: Aafcr4810H New Delhi Appellant Respondent Renew Wind Energy (Rajkot) Vs The Deputy Commissioner Of Private Limited,138, Ansal Income Tax, Circle 19(1) Delhi Chambers, Bhikajicama Palace, Range Code-44, C. R. New Delhi Building, I. P. Estate, Pan: Aafcr4553H New Delhi Appellant Respondent Assessee By Sh. Kashish Gupta, Ca Revenue By Sh. S. K. Jadhav, Cit Dr Date Of Hearing 27/01/2026 Date Of Pronouncement 29/01/2026

…uch directions. The section and the sub-section have to be read as a whole with connected provisions to decipher the meaning and intentions. At this juncture it would be useful to refer to the following decisions: (i) Sultana Begum v. Prem Chand Jain, (1997) 1 SCC 373 at page 381: 21 “11. The statute has to be read as a whole to find out the real intention of the legislature. 12. In Canada Sugar Refining Co. v. R. [1898 AC 735 : 67 LJPC 126] , Lord Davy observed: “Every clause of a statute should be construed with reference to the context and other clauses of the Act, so as, as far as possible, to make a consist…

Rohde and Schwarz India Private Limited, New Delhi vs. Assessment Unit, the Deputy Commissioner of Income Tax, Circle 19(1), New Delhi

In the result, appeal of the Assessee is allowed

Bench: Yogesh Kumar U.S. & Shri Krinwant Sahayrohde & Schwarz India Private Vs Assessment Unit, The Limited Deputy Commissioner Of A-27, First Floor Mohan Cooperative Income Tax, Circle 19(1), Industrial Estate, Mathura Road, New Delhi New Delhi-110044 Pan: Aaacr3267P Appellant Respondent Assessee By Ms. Snigdha Gautam, Adv Revenue By Sh. S. K. Jadhav, Cit Dr Date Of Hearing 27/01/2026 Date Of Pronouncement 29/01/2026

…uch directions. The section and the sub-section have to be read as a whole with connected provisions to decipher the meaning and intentions. At this juncture it would be useful to refer to the following decisions: (i) Sultana Begum v. Prem Chand Jain, (1997) 1 SCC 373 at page 381: 21 “11. The statute has to be read as a whole to find out the real intention of the legislature. 12. In Canada Sugar Refining Co. v. R. [1898 AC 735 : 67 LJPC 126] , Lord Davy observed: “Every clause of a statute should be construed with reference to the context and other clauses of the Act, so as, as far as possible, to make a consist…

Jubilant Foodworks Limited, Noida vs. Deputy Commissioner of Income Tax, Noida

In the result, all two appeals of the assessee are allowed

Bench: Shri Vikas Awasthy & Shri Sanjay Awasthiआ.अ.सं/.I.T.A No.4339/Del/2024 िनधा"रणवष"/Assessment Year: 2020-21 बनाम Jubilant Foodworks Limited, Deputy Commissioner Of Plot No.1A, Sector-16A, Noida,Gautam Vs. Income Tax, Buddha Nagar, Uttar Pradesh. Circle-5(1)(1), Noida, Pan No.Aabcd1821C Uttar Pradesh. अपीलाथ" Appellant ""यथ"/Respondent & आ.अ.सं/.I.T.A No.5712/Del/2024 िनधा"रणवष"/Assessment Year: 2021-22 बनाम Jubilant Foodworks Limited, Assistant Commissioner Of Plot No.1A, Sector-16A, Noida, Vs. Income Tax, Gautam Buddha Nagar, Uttar Pradesh. Circle 5(1)(1), Noida, Pan No.Aabcd1821C Uttar Pradesh. अपीलाथ" Appellant ""यथ"/Respondent

…, reiterates the urgency that sets the tone for the interpretation of section 144C itself.” The Division Bench affirmed aforesaid findings of the Hon’ble Single Judge and further after considering various decisions viz.Sultana Begum vs. Prem Chand Jain [1997] 1 SCC 373; CIT vs. Hindustan Bulk Carriers [2023] 126 Taxman 321/259 ITR 449; & Franklin Templeton Trustee Services (P.) Ltd. vs Amruta Garg 124 taxmann.com 326, held as under:- “23. Further, similar non-obstante clause is also used in section 144C(4) with a same limited purpose to imply, even though there might be a larger time limit under Section 153, once…

Zimmer India Private Limited, Gurgaon, Haryana vs. The Deputy Commissioner of Income Tax, Gurgaon, Haryana

In the result, appeal of the Assessee is allowed

Bench: Yogesh Kumar U.S. & Shri Krinwant Sahayzimmer India Private Limited V The Deputy Commissioner Vanijya Nikunj, Enkay Towers, Unit S Of Income Tax, Circle 3(1) No. 6Th Floor, Udyog Vihar, Phase-V, Hsiidc Building, Udyog Gurgaon, 122016, Haryana Vihar V, Gurugram Haryana Pan: Aaecs7432H Appellant Respondent Assessee By Sh. Kashish Gupta, Ca Revenue By Sh. S. K. Jadhav, Cit Dr Date Of Hearing 27/01/2026 Date Of Pronouncement 29/01/2026

…uch directions. The section and the sub-section have to be read as a whole with connected provisions to decipher the meaning and intentions. At this juncture it would be useful to refer to the following decisions: (i) Sultana Begum v. Prem Chand Jain, (1997) 1 SCC 373 at page 381: 21 “11. The statute has to be read as a whole to find out the real intention of the legislature. 12. In Canada Sugar Refining Co. v. R. [1898 AC 735 : 67 LJPC 126] , Lord Davy observed: “Every clause of a statute should be construed with reference to the context and other clauses of the Act, so as, as far as possible, to make a consist…

Renew Wind Energy (Shivpur) Private Limited, Delhi vs. Deputy Commissioner of Income-Tax, Circle 19(1), Delhi

In the result, appeals of the Assessees are allowed

Bench: Yogesh Kumar U.S. & Shri Krinwant Sahayrenew Wind Energy (Shivpur) Vs The Deputy Commissioner Of Private Limited, 138, Ansal Income Tax, Circle 19(1) Delhi Chambers, Bhikaji Cama Palace, Range Code-44, C. R. New Delhi Building, I. P. Estate, Pan: Aafcr4810H New Delhi Appellant Respondent Renew Wind Energy (Rajkot) Vs The Deputy Commissioner Of Private Limited,138, Ansal Income Tax, Circle 19(1) Delhi Chambers, Bhikajicama Palace, Range Code-44, C. R. New Delhi Building, I. P. Estate, Pan: Aafcr4553H New Delhi Appellant Respondent Assessee By Sh. Kashish Gupta, Ca Revenue By Sh. S. K. Jadhav, Cit Dr Date Of Hearing 27/01/2026 Date Of Pronouncement 29/01/2026

…uch directions. The section and the sub-section have to be read as a whole with connected provisions to decipher the meaning and intentions. At this juncture it would be useful to refer to the following decisions: (i) Sultana Begum v. Prem Chand Jain, (1997) 1 SCC 373 at page 381: 21 “11. The statute has to be read as a whole to find out the real intention of the legislature. 12. In Canada Sugar Refining Co. v. R. [1898 AC 735 : 67 LJPC 126] , Lord Davy observed: “Every clause of a statute should be construed with reference to the context and other clauses of the Act, so as, as far as possible, to make a consist…

Fev India Private Limited, Delhi vs. Assessment Unit, National Faceless Assessment Centre

In the result, appeal of the Assessee is allowed

Bench: Yogesh Kumar U.S. & Shri Krinwant Sahayfev India Private Limited V Assessment Unit B-260, Greater Kailash-1, New S National Faceless Delhi, South East, Delhi,110048 Assessment Centre, Income Pan: Aaacf9589Q Tax Department, New Delhi Appellant Respondent Assessee By Sh. Nikhil Tiwari, Ca (Virtual) Revenue By Sh. S. K. Jadhav, Cit Dr Date Of Hearing 27/01/2026 Date Of Pronouncement 29/01/2026

…uch directions. The section and the sub-section have to be read as a whole with connected provisions to decipher the meaning and intentions. At this juncture it would be useful to refer to the following decisions: (i) Sultana Begum v. Prem Chand Jain, (1997) 1 SCC 373 at page 381: 21 “11. The statute has to be read as a whole to find out the real intention of the legislature. 12. In Canada Sugar Refining Co. v. R. [1898 AC 735 : 67 LJPC 126] , Lord Davy observed: “Every clause of a statute should be construed with reference to the context and other clauses of the Act, so as, as far as possible, to make a consist…

Johnson Matthey India Pvt. Ltd., New Delhi vs. ACIT Circle 13(1), New Delhi

In the result, appeals of the Assessees are allowed

Bench: Yogesh Kumar U.S. & Shri Manish Agarwaljohnson Matthey India P. Ltd. Vs The Deputy Commissioner Of C/O. Luthra & Luthra Law Income Tax, Circle 13(2) Office India, 103, Ashoka Estate, Spm Civic Centre, New Delhi Barakhamba Road, New Delhi Pan: Aaacj2919A Appellant Respondent Johnson Matthey India P. Ltd. Vs National Faceless Appeal 5Th Floor, C/O Regus Business Centre, Income Tax Center, Gurgaon, Road, South Department West Delhi Pan: Aaacj2919A Appellant Respondent Assessee By Sh. Sumit Mangal, Adv, Ms. Radhika Sharma, Adv& Ms. Soumya Pandey, Adv Revenue By Sh. S. K. Jadhav, Cit Dr Date Of Hearing 22/01/2026 Date Of Pronouncement 29/01/2026

…uch directions. The section and the sub-section have to be read as a whole with connected provisions to decipher the meaning and intentions. At this juncture it would be useful to refer to the following decisions: (i) Sultana Begum v. Prem Chand Jain, (1997) 1 SCC 373 at page 381: 21 “11. The statute has to be read as a whole to find out the real intention of the legislature. 12. In Canada Sugar Refining Co. v. R. [1898 AC 735 : 67 LJPC 126] , Lord Davy observed: “Every clause of a statute should be construed with reference to the context and other clauses of the Act, so as, as far as possible, to make a consist…

Google India Digital Services Private Limited, Delhi vs. Au, NFAC, ACIT(OSD), Range 42, Delhi

In the result, appeal of the Assessee is allowed

Bench: Yogesh Kumar U.S. & Shri Krinwant Sahaygoogle India Digital Servicdes V Assessment Unit, Private Limited. 5Th Floor, Dlf S Nfac, Acit (Osd), Range Centre Block, 124, Sansad Marg, 42, C. R. Building, H. O. Central Delhi, New Delhi New Delhi Pan: Aagcg6803L Appellant Respondent Assessee By Sh. Kanchan Kaushal, Ar Revenue By Sh. S. K. Jadhav, Cit Dr Date Of Hearing 27/01/2026 Date Of Pronouncement 29/01/2026

…uch directions. The section and the sub-section have to be read as a whole with connected provisions to decipher the meaning and intentions. At this juncture it would be useful to refer to the following decisions: (i) Sultana Begum v. Prem Chand Jain, (1997) 1 SCC 373 at page 381: 21 “11. The statute has to be read as a whole to find out the real intention of the legislature. 12. In Canada Sugar Refining Co. v. R. [1898 AC 735 : 67 LJPC 126] , Lord Davy observed: “Every clause of a statute should be construed with reference to the context and other clauses of the Act, so as, as far as 8 Google India Digital Serv…

General Motors India Private Limited, Haryana vs. Circle-1(1), Gurgaon

Bench: Yogesh Kumar U.S. & Shri Krinwant Sahay

…such directions. The section and the sub-section have to be read as a whole with connected provisions to decipher the meaning and intentions. At this juncture it would be useful to refer to the following decisions: (i) Sultana Begum v. Prem Chand Jain, (1997) 1 SCC 373 at page 381: 21 “11. The statute has to be read as a whole to find out the real intention of the legislature. 12. In Canada Sugar Refining Co. v. R. [1898 AC 735 : 67 LJPC 126], Lord Davy observed: “Every clause of a statute should be construed with reference to the context and other clauses of the Act, so as, as far as possible, to make a consiste…

Groupe Seb India Pvt Ltd, Gurugram vs. ACIT, (OSD), New Delhi

In the result, appeal of the Assessee is allowed

Bench: Yogesh Kumar U.S. & Shri Krinwant Sahaygroupe Seb India Pvt. Ltd. Vs Acit (Osd) Vipul Plaza, 215-220, Golf Course Range-10, C. R. Building, Road Suncity, Sector-54, Gurgaon, New Delhi Haryana Pan: Aagcm6857L Appellant Respondent Assessee By Ms. Shruti Khimta, Adv Revenue By Sh. S. K. Jadhav, Cit Dr Date Of Hearing 28/01/2026 Date Of Pronouncement 29/01/2026

…uch directions. The section and the sub-section have to be read as a whole with connected provisions to decipher the meaning and intentions. At this juncture it would be useful to refer to the following decisions: (i) Sultana Begum v. Prem Chand Jain, (1997) 1 SCC 373 at page 381: 21 “11. The statute has to be read as a whole to find out the real intention of the legislature. 12. In Canada Sugar Refining Co. v. R. [1898 AC 735 : 67 LJPC 126] , Lord Davy observed: “Every clause of a statute should be construed with reference to the context and other clauses of the Act, so as, as far as possible, to make a consist…

Ball Beverage Packaging(India) Pvt Ltd, Bangalore vs. DCIT, Circle-4 (2), Delhi

In the result, appeal of the Assessee is allowed

Bench: Yogesh Kumar U.S. & Shri Krinwant Sahayball Beverage Packaging (India) Pvt. V Dcit, Circle-4(2) Ltd. B-302, 3Rd Floor B Wing Brigade S New Delhi-110002 Magnum, Amruthali, Nh-7, International Airport Road, Bangaluru, Not Listed, 560092 Pan: Aabch77101B Appellant Respondent Assessee By Ms. Snigdha Gautam, Adv Revenue By Sh. S. K. Jadhav, Cit Dr Date Of Hearing 22/01/2026 Date Of Pronouncement 29/01/2026

…uch directions. The section and the sub-section have to be read as a whole with connected provisions to decipher the meaning and intentions. At this juncture it would be useful to refer to the following decisions: (i) Sultana Begum v. Prem Chand Jain, (1997) 1 SCC 373 at page 381: 21 “11. The statute has to be read as a whole to find out the real intention of the legislature. 12. In Canada Sugar Refining Co. v. R. [1898 AC 735 : 67 LJPC 126] , Lord Davy observed: “Every clause of a statute should be construed with reference to the context and other clauses of the Act, so as, as far as possible, to make a consist…

Haskoningdhv Consulting Pvt Ltd, Delhi vs. ACIT, Circle-10(1), Delhi

Bench: Shri Vikas Awasthy & Shri Sanjay Awasthiआ.अ.सं/.I.T.A No.5517/Del/2024 िनधा"रणवष"/Assessment Year: 2021-22 बनाम Airbnb Payments India Private Limited, The Dcit Circle 1(1), Level 9, Spaze I Tech Park, A1 Tower,Sector Vs. Gurugram,Haryana. 49, Sohna Road, Gurugram, Haryana.India. Pan No. Aanca6203B अपीलाथ" Appellant ""यथ"/Respondent

…ITA Nos. 5517/D/24, 6114/D/24, 5522/D/24, 5528/D/24, 6081/D/24 & 2348/D/22 IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “I”NEW DELHI BEFORE SHRI VIKAS AWASTHY, JUDICIAL MEMBER AND SHRI SANJAY AWASTHI, ACCOUNTANT MEMBER आ.अ.सं/.I.T.A No.5517/Del/2024 िनधा"रणवष"/Assessment Year: 2021-22 बनाम AIRBNB PAYMENTS INDIA PRIVATE LIMITED, THE DCIT Circle 1(1), Level 9, Spaze I Tech Park, A1 Tower,Sector Vs. Gurugram,Haryana. 49, Sohna Road, Gurugram, Haryana.INDIA. PAN NO. AANCA6203B अपीलाथ" Appellant ""यथ"/Respondent Assessee by Ms. Taranjeet Kaur, AR &Shri Kashish Gupta, AR Revenue by Shri Dharm Veer Singh, CIT DR आ…

Jubilant Pharmova Ltd, Noida vs. ACIT-1Moradabad New, Utter Pradesh

In the result, all two appeals of the assessee are allowed

Bench: Shrivikas Awasthy & Shrisanjay Awasthiआ.अ.सं/.I.T.A No.1970/Del/2022 िनधा"रणवष"/Assessment Year: 2018-19 बनाम Jubilant Pharmova Ltd., Acit-1, Plot-1A, Sector-16A, District G.B. Vs. Moradabad-New, Nagar, Noida,Uttar Pradesh. Uttar Pradesh. Pan No.Aabcv0200H अपीलाथ" Appellant ""यथ"/Respondent & आ.अ.सं/.I.T.A No.5713/Del/2024 िनधा"रणवष"/Assessment Year: 2021-22 बनाम Jubilant Pharmova Ltd., Dcit/Acit (Central), Bhartiagram Gajraula, Vs. Income Tax Department, Plot-1A, Sector-16A,District G.B. Moradabad, Uttar Pradesh. Nagar, Noida,Uttar Pradesh. Pan No.Aabcv0200H अपीलाथ" Appellant ""यथ"/Respondent

…, reiterates the urgency that sets the tone for the interpretation of section 144C itself.” The Division Bench affirmed aforesaid findings of the Hon’ble Single Judge and further after considering various decisions viz.Sultana Begum vs. Prem Chand Jain [1997] 1 SCC 373; CIT vs. Hindustan Bulk Carriers [2023] 126 Taxman 321/259 ITR 449; & Franklin Templeton Trustee Services (P.) Ltd. vs Amruta Garg 124 taxmann.com 326, held as under:- “23. Further, similar non-obstante clause is also used in section 144C(4) with a same limited purpose to imply, even though there might be a larger time limit under Section 153, once…

Vatika Seven Elements Pvt. Ltd., New Delhi vs. ACIT Circle 25(1), New Delhi

In the result, appeal of the Assessee is allowed

Bench: Shri Yogesh Kumar U.S. & Shri Krinwant Sahay, Accountnat Member [Assessment Year: 2018-19]

…uch directions. The section and the sub-section have to be read as a whole with connected provisions to decipher the meaning and intentions. At this juncture it would be useful to refer to the following decisions: (i) Sultana Begum v. Prem Chand Jain, (1997) 1 SCC 373 at page 381: 21 “11. The statute has to be read as a whole to find out the real intention of the legislature. 12. In Canada Sugar Refining Co. v. R. [1898 AC 735 : 67 LJPC 126] , Lord Davy observed: “Every clause of a statute should be construed with reference to the context and other clauses of the Act, so as, as far as possible, to make a consist…

Denso Subros Thermal Engineering Centre P.Ltd, New Delhi vs. ACIT, Circle-7(1), New Delhi

In the result, appeals of the Assessees are allowed

Bench: Shri Yogesh Kumar U.S. & Shri Krinwant Sahay, Accountnat Member

…uch directions. The section and the sub-section have to be read as a whole with connected provisions to decipher the meaning and intentions. At this juncture it would be useful to refer to the following decisions: (i) Sultana Begum v. Prem Chand Jain, (1997) 1 SCC 373 at page 381: 21 “11. The statute has to be read as a whole to find out the real intention of the legislature. 12. In Canada Sugar Refining Co. v. R. [1898 AC 735 : 67 LJPC 126] , Lord Davy observed: “Every clause of a statute should be construed with reference to the context and other clauses of the Act, so as, as far as possible, to make a consist…