(i) Sultana Begum v. Prem Chand Jain

Beumer India P.Ltd, New Delhi vs. DCIT, Circle 1(1)(2), New Delhi

In the result, Appeal of the Assessee in ITA No

Bench: Yogesh Kumar U.S. & Shri Manish Agarwal

…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: Beumer India (P.) Ltd. Vs. DCIT “Every clause of a statute should be construed with reference to the context and other clauses of the Act, so as, as f…

Modi-Mundipharma Beauty Products Private Limited, New Delhi vs. DCIT, Circle-16(1), Dehi

In the result, appeals of the assessees are allowed

Bench: Shri Vikas Awasthy & Shri Sanjay Awasthiआअसं.725/धिल्ली/2022(नि.व. 2017-18) Modi-Mundipharma Beauty Products P. Ltd., 1400 Modi Tower, 98 Nehru Place, New Delhi 110019 ...... अपीलार्थी/Appellant Pan: Aaacm-5901-B बिाम Vs. Additional/Joint/Deputy/Assisant Commissioner Of Income Tax/ Income Tax Officer, National Faceless Assessment Centre, ..... प्रनिवादी/Respondent Delhi आअसं.672/धिल्ली/2021(नि.व. 2016-17) Le Passage Tours & Travels India P. Ltd., A-296, Basement, Conference Cabin, Shivalik, Malviya Nagar, New Delhi 110017 ...... अपीलार्थी/Appellant Pan: Aaacl-8370-K बिाम Vs. Deputy Commissioner Of Income Tax, ..... प्रनिवादी/Respondent Circle 13(1), Cr Building, New Delhi 110002 आअसं.2071/धिल्ली/2017(नि.व. 2012-13) Eberspaecher Suetrak Bus Climate Control Systems India P. Ltd., No.2/1, Soukya Road, Thirumalashettyhally, Bengaluru, Karnataka 560067 ...... अपीलार्थी/Appellant Pan: Aacce-3922-E बिाम Vs. Deputy Commissioner Of Income Tax ..... प्रनिवादी/Respondent Circle 8(1), Cr Building New Delhi

…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…

Eversub India Private Ltd. (Formely As ' Subway Systems India Private Ltd., Haryana vs. DCIT Circle 22(2), Delhi

In the result, appeals of the Assessee are allowed

Bench: Yogesh Kumar U.S. & Shri Manish Agarwal

…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…

Smart Cube India Private Limited, New Delhi vs. DCIT, Circle-22(2), New Delhi

In the result, all ITA Nos

Bench: Shrivikas Awasthy & Shrisanjay Awasthiआ.अ.सं/.I.T.A No.1939/Del/2022 िनधा"रणवष"/Assessment Year: 2018-19 बनाम Corteva Agriscience India Pvt. Ltd., Dct, 17Th Floor, Tower-C, Dlf Cyber Greens, Vs. Circle 4(2), Sector 25A, Phase-3, Gurgaon, Haryana. C.R. Building, New Delhi. Pan No.Aaace2462M अपीलाथ" Appellant ""यथ"/Respondent

…ITA No.1939/D/2022, 5939/D/2024, 525/D/2022, 5602/D/2024 + SA 650/Del/2025 & 1503/Del/2021 IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “I”NEW DELHI BEFORE SHRIVIKAS AWASTHY, JUDICIAL MEMBER AND SHRISANJAY AWASTHI, ACCOUNTANT MEMBER आ.अ.सं/.I.T.A No.1939/Del/2022 िनधा"रणवष"/Assessment Year: 2018-19 बनाम CORTEVA AGRISCIENCE INDIA PVT. LTD., DCT, 17th Floor, Tower-C, DLF Cyber Greens, Vs. Circle 4(2), Sector 25A, Phase-3, Gurgaon, Haryana. C.R. Building, New Delhi. PAN No.AAACE2462M अपीलाथ" Appellant ""यथ"/Respondent Assessee by Shri Harpreet Singh Ajmani, Advocate & Ms. Ashmita Sharma, Advocate (Virtual) Rev…

Msd Pharmaceuticals Pvt Ltd, Delhi vs. DCIT Circle -16(1), New Delhi

In the result, appeals of the Assessee are allowed

Bench: Yogesh Kumar U.S. & Shri Manish Agarwal

…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…

Beumer India P.Ltd, New Delhi vs. DCIT, Circle-4(2), New Delhi

Bench: Yogesh Kumar U.S. & Shri Manish Agarwal

…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…

Philip Morris Services India Sarl, New Delhi vs. DCIT, Circle-2(2)(2) International Taxation, New Delhi

In the result, appeals of the assessee are allowed

Bench: Shri Vikas Awasthy & Shri Sanjay Awasthiआअसं.1603 & 1604/धिल्ली/2022(नि.व. 2009-10 & 2010-11)

…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:- ITA Nos. 1603 & 1604/Del/2022(A.Ys 2009-10 & 2010-11) “23. Further, similar non-obstante clause is also used in section 144C(4) with a same limited purpose to imply, even though the…

Philip Morris Services India Sarl, New Delhi vs. DCIT Circle-2(2)(2), International Taxation

In the result, appeals of the assessee are allowed

Bench: Shri Vikas Awasthy & Shri Sanjay Awasthiआअसं.1603 & 1604/धिल्ली/2022(नि.व. 2009-10 & 2010-11)

…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:- ITA Nos. 1603 & 1604/Del/2022(A.Ys 2009-10 & 2010-11) “23. Further, similar non-obstante clause is also used in section 144C(4) with a same limited purpose to imply, even though the…

Vivo Mobile India Private Limited, Gurgaon vs. ACIT, Circle-25(1), Delhi

In the result, appeals of the Assessee are allowed

Bench: Yogesh Kumar U.S. & Shri Manish Agarwal

…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: “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 consistent…

Baxter (India) Pvt. Ltd., Gurgaon vs. DCIT Circle-4(2), Delhi

In the result, appeals of the Assessee are allowed

Bench: Yogesh Kumar U.S. & Shri Manish Agarwalbaxter India Pvt. Ltd. Vs Acit 2Nd Floor, Tower C, Building Circle 4 (1) No. 8, Dlf Cyber City, Dlf C. R. Building, Phase-Ii, Gurgaon New Delhi Pan: Aaacb3906F Appellant Respondent

…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…

Baxter (India) Private Ltd., Gurgaon vs. DCIT Circle-4(2), Delhi

In the result, appeals of the Assessee are allowed

Bench: Yogesh Kumar U.S. & Shri Manish Agarwalbaxter India Pvt. Ltd. Vs Acit 2Nd Floor, Tower C, Building Circle 4 (1) No. 8, Dlf Cyber City, Dlf C. R. Building, Phase-Ii, Gurgaon New Delhi Pan: Aaacb3906F Appellant Respondent

…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…

Le Passage to India Tours & Travels Pvt. Ltd., New Delhi vs. DCIT, Circle- 13(1), New Delhi

In the result, appeals of the assessees are allowed

Bench: Shri Vikas Awasthy & Shri Sanjay Awasthiआअसं.725/धिल्ली/2022(नि.व. 2017-18) Modi-Mundipharma Beauty Products P. Ltd., 1400 Modi Tower, 98 Nehru Place, New Delhi 110019 ...... अपीलार्थी/Appellant Pan: Aaacm-5901-B बिाम Vs. Additional/Joint/Deputy/Assisant Commissioner Of Income Tax/ Income Tax Officer, National Faceless Assessment Centre, ..... प्रनिवादी/Respondent Delhi आअसं.672/धिल्ली/2021(नि.व. 2016-17) Le Passage Tours & Travels India P. Ltd., A-296, Basement, Conference Cabin, Shivalik, Malviya Nagar, New Delhi 110017 ...... अपीलार्थी/Appellant Pan: Aaacl-8370-K बिाम Vs. Deputy Commissioner Of Income Tax, ..... प्रनिवादी/Respondent Circle 13(1), Cr Building, New Delhi 110002 आअसं.2071/धिल्ली/2017(नि.व. 2012-13) Eberspaecher Suetrak Bus Climate Control Systems India P. Ltd., No.2/1, Soukya Road, Thirumalashettyhally, Bengaluru, Karnataka 560067 ...... अपीलार्थी/Appellant Pan: Aacce-3922-E बिाम Vs. Deputy Commissioner Of Income Tax ..... प्रनिवादी/Respondent Circle 8(1), Cr Building New Delhi

…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…

Fena Pvt. Ltd., New Delhi vs. Addl. CIT National Faceless Centre, New Delhi

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

…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…

Evalueserve.Com Pvt. Ltd., Gurgain vs. ACIT Circle-9(2), New Delhi

In the result, all ITA Nos

Bench: Shrivikas Awasthy & Shrisanjay Awasthiआ.अ.सं/.I.T.A No.5982/Del/2024 िनधा"रणवष"/Assessment Year: 2021-22 बनाम Mmtc-Pamp India Private Limited, Dcit, 221, Ground Floor, Okhla Industrial Estate, Vs. Circle-16(1),C.R. Building, Phase-Iii, New Delhi. Indraprastha Marg, Pan No.Aafcm3576K I.P. Estate, New Delhi. अपीलाथ" Appellant ""यथ"/Respondent

…ITA Nos. 5982/D/2024, 1994/D/2022, 5991/D/2024, 5992/D/2024, 6034/D/2024, 1186/D/2022, 422/D/2021 & 1813/D/2022 IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “I”NEW DELHI BEFORE SHRIVIKAS AWASTHY, JUDICIAL MEMBER AND SHRISANJAY AWASTHI, ACCOUNTANT MEMBER आ.अ.सं/.I.T.A No.5982/Del/2024 िनधा"रणवष"/Assessment Year: 2021-22 बनाम MMTC-PAMP INDIA PRIVATE LIMITED, DCIT, 221, Ground Floor, Okhla Industrial Estate, Vs. Circle-16(1),C.R. Building, Phase-III, New Delhi. Indraprastha Marg, PAN No.AAFCM3576K I.P. Estate, New Delhi. अपीलाथ" Appellant ""यथ"/Respondent Assessee by Ms. Sherry Goyal, Adv., & Ms. Viyushti Raw…

Inductis (India) Pvt. Ltd., New Delhi vs. ACIT, Circle- 12(1), New Delhi

In the result, appeal of the Assessee is allowed

Bench: Yogesh K Umar, U.S. & Shri Manish Agarwal

…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…

Baxter India Pvt. Ltd., Gurgaon vs. ACIT, Circle- 4(1), New Delhi

In the result, appeals of the Assessee are allowed

Bench: Yogesh Kumar U.S. & Shri Manish Agarwalbaxter India Pvt. Ltd. Vs Acit 2Nd Floor, Tower C, Building Circle 4 (1) No. 8, Dlf Cyber City, Dlf C. R. Building, Phase-Ii, Gurgaon New Delhi Pan: Aaacb3906F Appellant Respondent

…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…

Eberspaecher Suetrak Bus Climate Control Systems India Pvt. Ltd., Bengalore vs. DCIT, New Delhi

In the result, appeals of the assessees are allowed

Bench: Shri Vikas Awasthy & Shri Sanjay Awasthiआअसं.725/धिल्ली/2022(नि.व. 2017-18) Modi-Mundipharma Beauty Products P. Ltd., 1400 Modi Tower, 98 Nehru Place, New Delhi 110019 ...... अपीलार्थी/Appellant Pan: Aaacm-5901-B बिाम Vs. Additional/Joint/Deputy/Assisant Commissioner Of Income Tax/ Income Tax Officer, National Faceless Assessment Centre, ..... प्रनिवादी/Respondent Delhi आअसं.672/धिल्ली/2021(नि.व. 2016-17) Le Passage Tours & Travels India P. Ltd., A-296, Basement, Conference Cabin, Shivalik, Malviya Nagar, New Delhi 110017 ...... अपीलार्थी/Appellant Pan: Aaacl-8370-K बिाम Vs. Deputy Commissioner Of Income Tax, ..... प्रनिवादी/Respondent Circle 13(1), Cr Building, New Delhi 110002 आअसं.2071/धिल्ली/2017(नि.व. 2012-13) Eberspaecher Suetrak Bus Climate Control Systems India P. Ltd., No.2/1, Soukya Road, Thirumalashettyhally, Bengaluru, Karnataka 560067 ...... अपीलार्थी/Appellant Pan: Aacce-3922-E बिाम Vs. Deputy Commissioner Of Income Tax ..... प्रनिवादी/Respondent Circle 8(1), Cr Building New Delhi

…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…

Oracle India Pvt. Ltd., New Delhi vs. DCIT, New Delhi

In the result, appeals of the Assessee in ITA No

Bench: Yogesh Kumar U.S. & Shri Manish Agarwaloracle India Private Limited Vs Addl. Cit F-01/02, 1St Floor, Salcon Range-13 Rasvilas, D-1, District Centre, New Delhi Saket, New Delhi Pan: Aaaco0158L Appellant Respondent Oracle India Private Limited Vs Dcit F-01/02, 1St Floor, Circle-19(1) Salconrasvilas, D-1, District New Delhi Centre, Saket, New Delhi Pan: Aaaco0158L Appellant Respondent Dcit Vs Oracle India Private Limited Circle-19(1) F-01/02, 1St Floor, Salcon New Delhi Rasvilas, D-1, District Centre, Saket, New Delhi Pan: Aaaco0158L Appellant Respondent Assessee By Sh. Naveen Dhamija, Ca, Sh. Vishal Aggarwal, Ca& Sh. Rinku Gupta, Ca Revenue By Sh. S. K. Jadhav, Cit Dr Date Of Hearing 22/01/2026 Date Of Pronouncement 28/01/2026

…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 Oracal India Vs. Addl. CIT “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…

Veetee Fine Foods Ltd., New Delhi vs. DCIT, New Delhi

In the result, appeals of the assessee pertaining to assessment

Bench: Shrivikas Awasthy & Shrisanjay Awasthiआ.अ.सं/.I.T.A No.853/Del/2016 िनधा"रणवष"/Assessment Year: 2011-12 बनाम Veetee Fine Foods Ltd. Dcit, 551, 5Th Floor, Tower-B, Vs. Circle-26(1), Aggarwal Cyber Plaza, Netaji Subhash Place, New Delhi. New Delhi. Pan No.Aaacp0658C अपीलाथ" Appellant ""यथ"/Respondent आ.अ.सं/.I.T.A No.959/Del/2016 िनधा"रणवष"/Assessment Year: 2011-12 बनाम Dcit, Veetee Fine Foods Ltd. 551, 5Th Floor, Tower-B, Circle-26(1), Vs. New Delhi. Aggarwal Cyber Plaza, Netaji Subhash Place, New Delhi. Pan No.Aaacp0658C अपीलाथ" Appellant ""यथ"/Respondent आ.अ.सं/.I.T.A No.2572/Del/2017 िनधा"रणवष"/Assessment Year: 2012-13 बनाम Veetee Fine Foods Ltd. Addl. Cit 551, 5Th Floor, Tower-B, Vs. Special Range-9, Aggarwal Cyber Plaza, Netaji Subhash Place, New Delhi. New Delhi. Pan No.Aaacp0658C अपीलाथ" Appellant ""यथ"/Respondent आ.अ.सं/.I.T.A No.7371/Del/2019 िनधा"रणवष"/Assessment Year: 2013-14 बनाम Veetee Fine Foods Ltd. Addl. Cit 551, 5Th Floor, Tower-B, Vs. Special Range-9, Aggarwal Cyber Plaza, Netaji Subhash Place, New Delhi. New Delhi. Pan No.Aaacp0658C 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…

Consulting Engineering Services (India) Pvt. Ltd., Gurgaon vs. ACIT, New Delhi

In the result, appeals of the assessee are allowed

Bench: Shri Vikas Awasthy & Shri Sanjay Awasthiआअसं. 1767/धिल्ली/2016 (नि.व. 2011-12)

…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:- 13 ITA No. 1767 /Del/2016 (A.Y 2011-12) “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…