Kadimi Tool Manufacturing Co. (P) Ltd. v. DCIT

87 Taxmann.com 42High Court2017#11887 most cited
9

judgments rely on this decision, according to BharatTax’s citation analysis of 366,339 Indian tax judgments — from 2018 to 2025.

Sections most often in play

Section 143(3)Section 92BSection 10DSection 115-OSection 144C(13)Section 234CSection 271(1)(c)Section 274

Issues it is cited on

section 80lsection 2(1a)section 2(1)section 10(1)captive service providerinterest on outstanding receivablesworking capital adjustmentsection 92bdividend distribution taxsection 80hhctested partycomparable companies

Judgments citing Kadimi Tool Manufacturing Co. (P) Ltd. v. DCIT

Phi Seeds Pvt. Ltd., Hyderabad vs. Addl.CIT, Special Range-7, New Delhi

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

ITA 9205/DEL/2019[2015-16]Status: DisposedITAT Delhi13 May 2026AY 2015-16

Bench: Shri Vikas Awasthy & Shri Brajesh Kumar Singh

Section 10Section 143(2)Section 143(3)Section 144C(13)Section 144C(5)Section 2Section 92C

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH, ‘I’: NEW DELHI BEFORE SHRI VIKAS AWASTHY, JUDICIAL MEMBER AND SHRI BRAJESH KUMAR SINGH, ACCOUNTANT MEMBER ITA No.1575 /DEL/2018 [Assessment Year: 2013-14] Corteva Agriscience Seeds Additional Commissioner of Income Private Limited (Formerly Tax, known as PHI Seeds Private Vs Special Range-7, Limited), V-Ascends, Atria Room No.211, C.R. Building, Block, 12th Floor, Plot No.17, Delhi-110002 Software Units Layout, Madhapur, Hyderabad Telangana, 500081 PAN-AACCP3920F Assessee Revenue [Assessment Year: 2014-15] Corteva Agriscience Seeds Additional Commissioner of I…

Phi Seeds Pvt. Ltd., Hyderabad vs. Addl.CIT, Special Range-7, New Delhi

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

ITA 1575/DEL/2018[2013-14]Status: DisposedITAT Delhi13 May 2026AY 2013-14

Bench: Shri Vikas Awasthy & Shri Brajesh Kumar Singh

Section 10Section 143(2)Section 143(3)Section 144C(13)Section 144C(5)Section 2Section 92C

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH, ‘T’: NEW DELHI BEFORE SHRI VIKAS AWASTHY, JUDICIAL MEMBER AND SHRI BRAJESH KUMAR SINGH, ACCOUNTANT MEMBER ITA No.1575/DEL/2018 [Assessment Year: 2013-14] Corteva Agriscience Seeds Additional Commissioner of Income Private Limited (Formerly Tax, known as PHI Seeds Private Vs Special Range-7, Limited), V-Ascends, Atria Room No.211, C.R. Building, Block, 12th Floor, Plot No.17, Delhi-110002 Software Units Layout, Madhapur, Hyderabad Telangana, 500081 PAN-AACCP3920F Assessee Revenue ITA No. 7375/DEL/2018 [Assessment Year: 2014-15] Corteva Agriscience Seeds Additional…

Technip India Limited, New Delhi vs. ACIT, Spl Range-9, New Delhi

In the result, Appeal No.6390/Del/2017 is partly allowed as per above terms

ITA 9852/DEL/2019[2015-16]Status: DisposedITAT Delhi17 Sept 2025AY 2015-16

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarita No. 6390/Del/2017 Assessment Year: 2013-14 Ita No. 9852/Del/2019 Assessment Year: 2015-16 Technip Energies India Vs. Additional Commissioner Of Limited, ( Formerly Known As Income Tax, Technip India Limited), Special Range-9, A-4, Sector 1, Institutional New Delhi Area, Noida – 201 301 Pan No. Aaack3349R (Appellant) (Respondent)

For Appellant: Shri Vishal Kalra, Adv., Shri Yishu GoelFor Respondent: Shri Dharm Veer Singh, CIT (DR)
Section 143(2)Section 143(3)Section 144C(13)Section 144C(5)Section 250Section 92C

…INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “I”: NEW DELHI BEFORE SHRI S RIFAUR RAHMAN, ACCOUNTANT MEMBER AND SHRI VIMAL KUMAR, JUDICIAL MEMBER ITA No. 6390/DEL/2017 Assessment Year: 2013-14 ITA No. 9852/DEL/2019 Assessment Year: 2015-16 Technip Energies India Vs. Additional Commissioner of Limited, ( formerly known as Income Tax, Technip India Limited), Special Range-9, A-4, Sector 1, Institutional New Delhi Area, Noida – 201 301 PAN No. AAACK3349R (Appellant) (Respondent) Assessee by: Shri Vishal Kalra, Adv., Shri Yishu Goel, AR & Shri Anil Kumar, Adv. Department by: Shri Dharm Veer Singh, CIT (DR) Date of H…

Technip India Ltd., Noida vs. Addl.CIT, Special Range- 9, New Delhi

In the result, Appeal No.6390/Del/2017 is partly allowed as per above terms

ITA 6390/DEL/2017[2013-14]Status: DisposedITAT Delhi17 Sept 2025AY 2013-14

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarita No. 6390/Del/2017 Assessment Year: 2013-14 Ita No. 9852/Del/2019 Assessment Year: 2015-16 Technip Energies India Vs. Additional Commissioner Of Limited, ( Formerly Known As Income Tax, Technip India Limited), Special Range-9, A-4, Sector 1, Institutional New Delhi Area, Noida – 201 301 Pan No. Aaack3349R (Appellant) (Respondent)

For Appellant: Shri Vishal Kalra, Adv., Shri Yishu GoelFor Respondent: Shri Dharm Veer Singh, CIT (DR)
Section 143(2)Section 143(3)Section 144C(13)Section 144C(5)Section 250Section 92C

…INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “I”: NEW DELHI BEFORE SHRI S RIFAUR RAHMAN, ACCOUNTANT MEMBER AND SHRI VIMAL KUMAR, JUDICIAL MEMBER ITA No. 6390/DEL/2017 Assessment Year: 2013-14 ITA No. 9852/DEL/2019 Assessment Year: 2015-16 Technip Energies India Vs. Additional Commissioner of Limited, ( formerly known as Income Tax, Technip India Limited), Special Range-9, A-4, Sector 1, Institutional New Delhi Area, Noida – 201 301 PAN No. AAACK3349R (Appellant) (Respondent) Assessee by: Shri Vishal Kalra, Adv., Shri Yishu Goel, AR & Shri Anil Kumar, Adv. Department by: Shri Dharm Veer Singh, CIT (DR) Date of H…

Fluor Daniel India P.Ltd, New Delhi vs. Addl.CIT, Special Range-3, New Delhi

In the result, the appeals of the assessee in ITA Nos

ITA 6581/DEL/2018[2014-15]Status: DisposedITAT Delhi23 Apr 2025AY 2014-15

Bench: Shri Anubhav Sharma & Shri Naveen Chandra

For Appellant: Shri Vishal Kalra, AdvFor Respondent: Shri Om Prakash, CIT-DR
Section 143(3)Section 144CSection 271Section 92C

…IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI ‘I’ BENCH, NEW DELHI BEFORE SHRI ANUBHAV SHARMA, JUDICIAL MEMBER, AND SHRI NAVEEN CHANDRA, ACCOUNTANT MEMBER ITA No. 6581/DEL/2018 [A.Y 2014-15] ITA No. 525/DEL/2021 [A.Y 2016-17] Fluor Daniel India Pvt Ltd Vs. The Addl. CIT/NFAC B-9, LGF, Green Park [Main] Special Range -3, New Delhi New Delhi PAN: AAACF 0927 G (Applicant) (Respondent) Assessee By : Shri Vishal Kalra, Adv Shri Ankit Sahani, Adv Department By : Shri Om Prakash, CIT-DR Date of Hearing : 31.01.2025 Date of Pronouncement : 23.04.2025 ORDER PER NAVEEN CHANDRA, ACCOUNTANT MEMBER:- The above t…

Lokesh Kumar Aggarwal, Delhi vs. ITO, Ward-45(5), Delhi

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

ITA 1575/DEL/2023[2012-13]Status: DisposedITAT Delhi20 Jan 2025AY 2012-13

Bench: Shri Vikas Awasthy & Shri Brajesh Kumar Singh

Section 10Section 143(2)Section 143(3)Section 144C(13)Section 144C(5)Section 2Section 92C

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH, ‘I’: NEW DELHI BEFORE SHRI VIKAS AWASTHY, JUDICIAL MEMBER AND SHRI BRAJESH KUMAR SINGH, ACCOUNTANT MEMBER ITA No.1575 /DEL/2018 [Assessment Year: 2013-14] Corteva Agriscience Seeds Additional Commissioner of Income Private Limited (Formerly Tax, known as PHI Seeds Private Vs Special Range-7, Limited), V-Ascends, Atria Room No.211, C.R. Building, Block, 12th Floor, Plot No.17, Delhi-110002 Software Units Layout, Madhapur, Hyderabad Telangana, 500081 PAN-AACCP3920F Assessee Revenue [Assessment Year: 2014-15] Corteva Agriscience Seeds Additional Commissioner of I…

Omniglobe Information Technologies (India) Pvt. Ltd., New Delhi vs. ACIT, Special Range-7, New Delhi

In the result, the appeal is allowed, as indicated above

ITA 6548/DEL/2018[2014-15]Status: DisposedITAT Delhi19 Oct 2022AY 2014-15

Bench: Shri Saktijit Dey & Dr. B.R.R. Kumarassessment Year: 2014-15

Section 143(1)

…IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI BENCH: ‘I’ NEW DELHI BEFORE SHRI SAKTIJIT DEY, JUDICIAL MEMBER AND DR. B.R.R. KUMAR, ACCOUNTANT MEMBER Assessment Year: 2014-15 M/s. Omniglobe Information Vs. ACIT, Technologies (India) Pvt. Ltd., Special Range-7, [Now, known as M/s. New Delhi Sequential Technology International (India) Pvt. Ltd.], 31, Todar Mal Lane, Bengali Market, New Delhi PAN :AAACO6606M (Appellant) (Respondent) Appellant by Sh. Neeraj Jain, Advocate Sh. Abhishek Aggarwal, CA Respondent by Sh. Mahesh Shah, CIT (DR) Date of hearing 21.07.2022 Date of pronouncement 19.10.2022 ORDER PER SAKTIJIT…

M/S. Barco Electronic Systems (P) Ltd., New Delhi vs. DCIT, New Delhi

In the result, the appeal of the assessee is allowed

ITA 1530/DEL/2016[2010-11]Status: DisposedITAT Delhi28 Jun 2019AY 2010-11

Bench: Shri Amit Shukla & Shri O.P. Kantassessment Year: 2010-11 M/S. Barco Electronic Vs. Deputy Commissioner Of Systems (P.) Ltd., Income Tax, E-20, 1St & 2Nd Floor, Hauz Circle-4(1), New Delhi Khas, New Delhi Pan : Aaacb5865F (Appellant) (Respondent) Appellant By S/Shri Gautam Jain & Piyush Kamal; & Ms. Monika, Ca Respondent By Shri Sandeep Kr. Mishra, Sr.Dr

Section 143(2)

…n the supplier credit that it is availing from domestic as well as from AEs. • Appellant is a debt free company and is not paying interest on any funds utilized by it in its business activities. • Reliance is placed on the following judicial pronouncements: - 87 Taxmann.com 42 (Del) Kadimi Tool Manufacturing Co (P) Ltd vs. Deputy Commissioner of Income Tax - 99 taxmann.com 167 (Del) Inductis (India) (P) Ltd vs. ITO - ITA No 87/D/2017 Teradata India (P) Ltd vs. ACIT - ITA No. 7653/MUM/2011 in Evonik Degussa India (P) Ltd - ITANo.3120/Ahd/2010 MASTER Ltd. vs. Addl. CIT - ITA No. 1053 of 2012 (Bom) CIT vs. Indo Amer…

Inductis India Pvt. Ltd., New Delhi vs. ACIT, New Delhi

In the result, the appeal of the assessee stands allowed in

ITA 1203/DEL/2017[2012-13]Status: DisposedITAT Delhi20 Aug 2018AY 2012-13

Bench: Shri Pramod Kumar & Shri Sudhanshu Srivastavaasstt. Year: 2012-13

For Appellant: Shri Vishal Kalra, AdvFor Respondent: Ms Paramita M. Biswas, CIT DR
Section 14ASection 92D

…sessment year 2010-11 wherein in ITA No. 2075/Del/2015, vide order dated 6.3.2018, the Coordinate Bench of the Tribunal has, relying on the order of the Coordinate Bench of the Tribunal in Kadimi Tool Manufacturing Co. Pvt. Ltd. vs. DCIT reported in (2017) 87 Taxmann.com 42 (Delhi Tribunal), which was confirmed by the Hon’ble Delhi High Court as well the Hon’ble Apex Court, has held that adjustment made by the TPO/Ld. DRP on account of interest on receivables was not sustainable in the eyes of law in the case of the assessee as, undisputedly, the taxpayer is a debt free company. During the course of proceedi…

Kadimi Tool Manufacturing Co. (P) Ltd. v. DCIT (87 Taxmann.com 42) — Cited in 9 Judgments | BharatTax