How many judgments cite Liberty India v. CIT?

571 judgments on BharatTax cite Liberty India v. CIT (317 ITR 218), spanning 2009 to 2026.

Which sections of the Income Tax Act does Liberty India v. CIT come up under?

It is most often cited in judgments turning on Section 143(3), Section 14A, Section 10B, Section 80IB, Section 147, Section 80IA.

Liberty India v. CIT

317 ITR 218Supreme Court of India2009#109 most cited

What is Liberty India v. CIT authority for?

The Supreme Court clarified that for profits and gains to be eligible for deductions under sections like 10B, 80IA, or 80IB, the income must be "derived from" or have a direct nexus to the eligible business activity. Income from incidental sources like the sale of scrips/licenses or interest on employee loans is generally not considered as derived from the eligible business for such deductions.

571

judgments rely on this decision, according to BharatTax’s citation analysis of 367,154 Indian tax judgments — from 2009 to 2026.

Also referred to as

Liberty India v. CIT · 317 ITR 218 · section 10B · section 80IA · section 80IB · profits derived from · direct nexus · eligible business · export undertaking deduction · sale of scrips income · interest income deduction

Also reported as

183 Taxmann 349

Sections most often in play

Section 143(3)Section 14A Section 10B Section 80IB Section 147 Section 80IA Section 1961 Section 250

Read the full judgment

Issues it is cited on

section 75 section 80h section 80hh section 80hhc section 80ic section 80ib eligible business deduction under section 80ia section 80i section 80ia disallowance u/s 14a gross total income

Judgments citing Liberty India v. CIT

M/S Bridhi Distributors Pvt. Ltd., Agra vs. Pr.CIT-4, Kolkata

ITA 234/KOL/2020[2012-13]Status: DisposedITAT Kolkata07 Jan 2022AY 2012-13

Bench: Shri P.M. Jagtap(Kz) & Shri A. T. Varkey, Jm]

Section 143(3)Section 14ASection 263Section 68

…und satisfied. (ii) Further it was a submission on behalf of the Revenue that such large amount of share premium gives rise to suspicion on the genuineness (identity) of the shareholders i.e. they are bogus. The Apex Court in CIT vis. Lovely Exports (P) Ltd. 317 ITR 218 in the context to the pre-amended Section 68 of the Act has held that where the Revenue urges that the amount of share application money has been received from bogus shareholders then it is for the Income Tax Officer to proceed by reopening the assessment of such shareholders and assessing them to tax in accordance with law. It does not entitle t…

M/S. Interarch Building Products Pvt. Ltd., New Delhi vs. DCIT, New Delhi

In the result, the appeal of the assessee is partly allowed

ITA 1137/DEL/2013[2006-07]Status: DisposedITAT Delhi17 Nov 2021AY 2006-07

Bench: Shri O.P. Kant & Shri Kuldip Singh[Through Video Conferencing] Assessment Year: 2006-07 Interarch Building Vs. Dcit Products Pvt. Ltd., Circle -11 (1) Farm No.8 Khasra New Delhi No.56/23/2, Dera Mandi Village, Mehrauli New Delhi-110047 Pan No.Aaaci0106J (Appellant) (Respondent)

Section 143(3)Section 14ASection 80Section 80ISection 94

…IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI BENCH: ‘C’ NEW DELHI BEFORE SHRI O.P. KANT, ACCOUNTANT MEMBER AND SHRI KULDIP SINGH, JUDICIAL MEMBER [Through Video Conferencing] Assessment Year: 2006-07 Interarch Building Vs. DCIT Products Pvt. Ltd., Circle -11 (1) Farm No.8 Khasra New Delhi No.56/23/2, Dera Mandi Village, Mehrauli New Delhi-110047 PAN No.AAACI0106J (Appellant) (Respondent) Appellant by Sh. M. P. Rastogi, Advocate Respondent by Ms. Sunita Singh, CIT DR Date of hearing 30.09.2021 Date of pronouncement 17.11.2021 ORDER PER O.P. KANT, AM: This appeal by the assessee is directed against order dated…

Lovely Fragrance, Mumbai vs. Pr. CIT - 24, Mumbai

In the result, appeal by the assessee stands allowed

ITA 3096/MUM/2019[2014-15]Status: DisposedITAT Mumbai20 Oct 2021AY 2014-15

Section 115JSection 143(3)Section 263Section 80Section 80I

…uestions of law are answered in the negative i.e. in favour of the appellant assessee and against the respondent Revenue.” 9. Learned Departmental Representative has opposed the above plea and point out that Hon'ble Supreme Court in the case of Liberty India 317 ITR 218 has held that words “derived from” is narrow than the connotation as compared to word “attributable to”. By issuing the expression ‘derived from’, Parliament intended to cover sources not beyond the first degree. 10. Upon careful consideration we find that aforesaid order of Hon'ble Jurisdictional High Court was delivered much later than the Hon…

Mahendra H. Shah, Mumbai vs. ITO - Ward- 4 (1)(3), Mumbai

ITA 6892/MUM/2018[2012-13]Status: DisposedITAT Mumbai27 Sept 2021AY 2012-13

Bench: Shri C.N. Prasad, Hon’Bleshri Mahendra H. Shah V. Income Tax Officer – 4(1)(3) 6Th Floor, Aayakar Bhavan C/O. The Presscopper Industries M.K. Road, Mumbai - 400020 175, Kika Street Mumbai – 400004 Pan: Aafps0929R (Appellant) (Respondent)

For Appellant: Vimal PunmiyaFor Respondent: Smita Verma

Section 132(4)Section 133(4)Section 143(1)Section 143(2)Section 68

…is whether the identity of the assessee is proved or not. In the case of share capital, if the identity is proved, no addition can be made u/s.68 of the Act. We draw support from the decision of the Hon'hle Supreme Court in the case of Lovely Exports Pvt Ltd. 317 ITR 218. We, therefore do not find any error or infirmity in the findings of the Ld CIT(A). Ground No.I is accordingly dismissed." (iv) In the case of Green Infra Ltd vs. ITO reported in 38 taxmann.com 253-ITAT) dated 23/812013, Hon'ble Mumbai ITAT decided that "During previous year ending on 31-3-2009, it had collected share premium on allotment of shar…

M/S. Thakur Infra Projects Pvt. Ltd, Raigad vs. Deputy Commissioner of Income Tax, Panvel Circle, Raigad

In the result, the appeal of the assessee is allowed

ITA 5592/MUM/2019[2013-14]Status: DisposedITAT Mumbai14 Sept 2021AY 2013-14

Bench: Shri Rajesh Kumar & Shri Pavan Kumar Gadaleassessment Year: 2013-14

For Appellant: Shri Devendra Jain, A.RFor Respondent: Shri Vijay Kumar Mehta, D.R

Section 80I

…A of the Act. The learned Departmental representative made elaborate submissions with respect to meaning of phrase "derived from". He also referred to several case law including the decision of the hon'ble apex court in the case of Liberty India v. CIT [2009] 317 ITR 218/183 Taxman 349 (SC). Referring to the ratio emanating from the aforesaid apex court's decision the learned Departmental representative submitted that the profit of the assessee from the advertising business would certainly be profits and gains of the business in terms of section 28 of the Act, the same would not amount to profits or gains derived…

Manjeera Projects, Hyderabad vs. Asst. Commissioner of Income Tax, Circle-11(1), Hyderabad

Appeals are partly allowed in above terms

ITA 15/HYD/2020[2016-17]Status: DisposedITAT Hyderabad08 Sept 2021AY 2016-17

Bench: Shri S.S. Godara & Shri Laxmi Prasad Sahu

For Appellant: Sri K.C. DevdasFor Respondent: Sri Y.V.S.T. Sai, DR

Section 143(3)Section 5Section 80I

…ITA Nos 956 and others Manjeera Projects Hyderabad. IN THE INCOME TAX APPELLATE TRIBUNAL Hyderabad ‘ B ‘ Bench, Hyderabad (Through Video Conferencing) Before Shri S.S. Godara, Judicial Member AND Shri Laxmi Prasad Sahu, Accountant Member ITA Nos. 1554, 956/Hyd/2018, 1599/Hyd/2019 & 15/Hyd/2020 Assessment Years: 2013-14 to 2016-17 Manjeera Projects Vs. Asstt. Commissioner of Hyderabad Income Tax, Circle 6(1) PAN:AAOFM0872C Hyderabad (Appellant) (Respondent) Assessee by: Sri K.C. Devdas Revenue by: Sri Y.V.S.T. Sai, DR Date of hearing: 26/08/2021 Date of pronouncement: 08/09/2021 ORDER Per S. S. Godara, J.…

Manjeera Projects, Hyderabad vs. Asst. Commissioner of Income Tax, Circle-6(1), Hyderabad

Appeals are partly allowed in above terms

ITA 956/HYD/2018[2014-15]Status: DisposedITAT Hyderabad08 Sept 2021AY 2014-15

Bench: Shri S.S. Godara & Shri Laxmi Prasad Sahu

For Appellant: Sri K.C. DevdasFor Respondent: Sri Y.V.S.T. Sai, DR

Section 143(3)Section 5Section 80I

Manjeera Projects, Hyderabad vs. Asst. Commissioner of Income Tax, Circle-6(1), Hyderabad

Appeals are partly allowed in above terms

ITA 1554/HYD/2018[2013-14]Status: DisposedITAT Hyderabad08 Sept 2021AY 2013-14

Bench: Shri S.S. Godara & Shri Laxmi Prasad Sahu

For Appellant: Sri K.C. DevdasFor Respondent: Sri Y.V.S.T. Sai, DR

Section 143(3)Section 5Section 80I

ACIT, Central Circle- 27, New Delhi vs. Ultimate Flexipack Ltd., New Delhi

In the result, the appeal of the Revenue in ITA No

ITA 1418/DEL/2018[2013-14]Status: DisposedITAT Delhi06 Sept 2021AY 2013-14

Bench: Shri N.K. Billaiya & Ms. Suchitra Kamble[A.Y 2013-14]

For Appellant: Shri. M. P. Rastogi, AdvFor Respondent: Ms. Nidhi Srivastava, CIT-DR

Section 80I

…1 IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI ‘B’ BENCH, NEW DELHI (THROUGH VIDEO CONFERENCING] BEFORE SHRI N.K. BILLAIYA, ACCOUNTANT MEMBER, AND MS. SUCHITRA KAMBLE, JUDICIAL MEMBER [A.Y 2013-14] The A.C.I.T Vs. Ultimate Flexipack Ltd. 305, 3rd Floor, Bhanot Corner, Central Circle 27 New Delhi Pamposh Enclave, Greater Kailash-1, New Delhi - 110048 PAN : AAACU 6565 D [Appellant] [Respondent] Date of Hearing : 06.09.2021 Date of Pronouncement : 06.09.2021 Assessee by : Shri. M. P. Rastogi, Adv. Shri Rajiv Kumar, C.A. Revenue by : Ms. Nidhi Srivastava, CIT-DR ORDER PER N.K. BILLAIYA, ACCOUNTANT ME…

Dy. Commissioner of Income Tax, Circle-16(1), Hyderabad vs. Nsl Renewable Power Private Limited, Hyderabad

In the result, the appeals of the revenue are partly allowed for statistical purposes in above terms

ITA 166/HYD/2020[2016-17]Status: DisposedITAT Hyderabad03 Sept 2021AY 2016-17

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

For Appellant: Shri Aliasgar RampurwalaFor Respondent: Shri P. Chandra Sekhar

Section 115JSection 143(3)Section 14ASection 80I

…nly profits but also losses have to be taken into consideration.” 20. Also, reliance is placed on the following judicial precedents wherein similar proposition of law was re-iterated by the Hon’ble SC (case-laws annexed): 1) Liberty India Ltd. vs CIT (2009) 317 ITR 218 (SC) 2) Synco Industries Ltd. vs AO (2008) 299 ITR 444 (SC) 3) A.M. Moosa vs CIT (2007) 163 Taxman 741 (SC) 4) CIT vs Shirke Construction Equipments Ltd. (2007) 161 Taxman 212 21. It is trite law that until unless there are similarities in the facts of the case, it is not permissible to get the benefit of the proposition of law laid down by Hon…

Dy. Commissioner of Income Tax, Circle-16(1), Hyderabad vs. Nsl Renewable Power Private Limited, Hyderabad

In the result, the appeals of the revenue are partly allowed for statistical purposes in above terms

ITA 165/HYD/2020[2014-15]Status: DisposedITAT Hyderabad03 Sept 2021AY 2014-15

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

For Appellant: Shri Aliasgar RampurwalaFor Respondent: Shri P. Chandra Sekhar

Section 115JSection 143(3)Section 14ASection 80I

M/S. Pdp Steels Ltd., Kolkata vs. ITO, Ward - 3(3), Kolkata

In the result, the appeal of assessee is allowed for statistical purposes

ITA 1883/KOL/2019[2013-14]Status: DisposedITAT Kolkata03 Sept 2021AY 2013-14

Bench: Shri P. M. Jagtap(Kz) & Shri A. T. Varkey]

Section 80I

…M/s. PDP Steels Ltd., AY 2013-14 आयकर अपीलीय अधीकरण, "यायपीठ –“C” कोलकाता, IN THE INCOME TAX APPELLATE TRIBUNAL “C” BENCH: KOLKATA [Before Shri P. M. Jagtap, Vice President (KZ) & Shri A. T. Varkey, Judicial Member] I.T.A. No. 1883/Kol/2019 Assessment Year: 2013-14 M/s. PDP Steels Ltd. Vs Income-tax Officer, Ward-3(3), (PAN: AABCP6726C) . Kolkata. Appellant Respondent Date of Hearing (Virtual) 31.08.2021 Date of Pronouncement 03.09.2021 For the Appellant Shri S. Jhajharia, FCA For the Respondent Shri Supriyo Pal, Addl. CIT ORDER Per Shri A. T. Varkey, JM: This is an appeal preferred by the assessee against the…

DCIT Circle- 6 (3)(2), Mumbai vs. M/S Jostar Orgotech Pvt Ltd, Mumbai

ITA 103/MUM/2020[2012-13]Status: DisposedITAT Mumbai03 Sept 2021AY 2012-13

Bench: Hon’Ble Shri Pavan Kumar Gadale, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am (Hearing Through Video Conferencing Mode) आयकरअपील सं./ I.T.A. No. 103/Mum/2020 (धििाारण वर्ा / Assessment Year: 2012-13) Dcit-(6)(3)(2) M/S Jostar Orgotech Pvt. Ltd. बिाम/ Aaykar Bhavan, R. No. 576 A-501, Innova Marathon Next Gen. M.K. Road, Mumbai-400 020. Off. Ganpatrao Kadam Marg Vs. Lower Parel(W), Mumbai-400 008 स्थायीलेखासं./ जीआइआरसं./ Pan/Gir No. Aabcj-2496-H (अपीलाथी/Appellant) (प्रत्यथी / Respondent) : Revenue By : Ms. Usha Gaikwad– Ld. Sr. Dr Assessee By : Shri J. P. Bairagra– Ld. Ar सुनवाई की तारीख/ : 30/08/2021 Date Of Hearing घोषणा की तारीख / : 03/09/2021 Date Of Pronouncement आदेश / O R D E R Manoj Kumar Aggarwal () 1. Aforesaid Appeal By Revenue For Assessment Year (Ay) 2012-13 Arises Out Of The Order Of Learned Commissioner Of Income-Tax (Appeals)-12, Mumbai [Cit(A)], Dated 02/09/2019 In The Matter Of Assessment Framed By Ld. Assessing Officer U/S 143(3) On 28/03/2015. The Sole Ground By The Revenue Read As Under: - On The Facts & Circumstances Of The Case & In Law, The Ld.Cit(A) Erred In Deleting The Addition Of Rs.5,68,60,000/- Made By The Ao On Account Of Share Application Money/Share Capital & Share Premium Which Is Held As Unexplained

For Appellant: Shri J. P. Bairagra– Ld. ARFor Respondent: Ms. Usha Gaikwad– Ld. Sr. DR

Section 133(6)Section 143(3)Section 68

…f which the investments were made in the assessee company, has also been mentioned in this Annexure. 5.4 The assessee assailed the remand report on the quantum of premium and relied on the decision of Hon’ble Supreme Court in CIT v/s. Lovely Exports (P) Ltd. (317 ITR 218) as well as the decision of Hon’ble Bombay High Court in the case of CIT Vs. Gagandeep Infrastructure Private Limited [80 Taxmann.com 272]. The assessee also submitted that Ld. AO had no power to determine the quantum of premium or the method of computing the premium since it was the assessee’s own prerogative to charge premium on issue of shares…

M/S. Kiri Dyes and Chemicals Ltd., Ahmedabad vs. The Asstt. Commissioner of Income Tax, Circle-2(1)(2), Ahmedabad

ITA 1849/AHD/2016[2003-04]Status: DisposedITAT Ahmedabad30 Jul 2021AY 2003-04

Bench: Shri Mahavir Prasad & Shri Waseem Ahmed

For Appellant: Shri T.P. Hemani, Sr. Advocate with Shri Parimal Sinh Parmar, A.RFor Respondent: Shri Mohd Usman, C.I.T.D.R with Shri Raj Deep Singh, Sr.D.R

Section 10BSection 143(3)Section 234ASection 80I

…The learned CIT (A) further found that the other income as declared includes Excise duty refund, Interest, DEPB etc which are not the part of eligible income under section 10B as per Hon’ble supreme court decision in case of Liberty India vs. CIT reported in 317 ITR 218. Accordingly the learned CIT (A) excluded the entire other income of Rs. 6,08,75,051/- from the computation of eligible profit under section 10B of the Act. 4. Against the order of this learned CIT (A), both the assessee and the Revenue filed appeals before the ITAT in ITA Nos. 814 & 1035/AHD/2010. The ITAT vide order dated 7th March 2014 held t…

Ntt Data Global Delivery Services Limited, Bangalore vs. ACIT, Bangalore

In the result, the ground no

ITA 1487/BANG/2013[2005-06]Status: DisposedITAT Bangalore16 Jul 2021AY 2005-06

Bench: Shri B. R. Baskaran & Smt. Beena Pillai

For Appellant: Shri Chavali Narayan, A.RFor Respondent: Ms. Neera Malhotra, D.R

Section 10ASection 10A(1)Section 10A(4)

…of relief u/s 10A in respect of recruitment fees earned. The Ld. CIT(A) upheld the action of the AO in denying deduction u/s 10A in respect of recruitment fees placing reliance on the decision of the Hon’ble Supreme Court in the case of Liberty India Vs. CIT (317 ITR 218). The relevant finding of the Ld. CIT(A) is as under: “From the above mentioned precedents, it is very clear that a receipt should have direct nexus with export activity, to be eligible for a deduction u/s 10A(1) read with section 10A(4) of the Act. I have considered the facts and circumstances of the case and find that the receipts on account o…

Assistant Commissioner of Income Tax, Circle 1(1), Huballi vs. Hubli Electricity Supply Co. Ltd., Hubballi

In the result, appeal of the Revenue is treated as allowed for statistical purposes

ITA 570/BANG/2017[2012 - 13]Status: DisposedITAT Bangalore30 Jun 2021

Bench: Shri N. V. Vasudevan & Shri B. R. Baskaranassessment Year :2012-13 The Assistant Commissioner Of Vs. Hubli Electricity Supply Co. Ltd., Income Tax, Navanagar, Circle – 1(1), Hubballi – 580 025. Hubballi. Pan : Aabch3176 J Appellant Respondent Revenue By : Ms. Neera Malhotra, Cit(Dr)(Itat), Bengaluru Assessee By : Smt. Prathibha, Advocate Date Of Hearing : 24.06.2021 Date Of Pronouncement : 30.06.2021 O R D E R Per N. V. Vasudevan

For Appellant: Smt. Prathibha, AdvocateFor Respondent: Ms. Neera Malhotra, CIT(DR)(ITAT), Bengaluru

Section 80ISection 8O

…IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH : BANGALORE BEFORE SHRI N. V. VASUDEVAN, VICE PRESIDENT AND SHRI B. R. BASKARAN, ACCOUNTANT MEMBER Assessment Year :2012-13 The Assistant Commissioner of Vs. Hubli Electricity Supply Co. Ltd., Income Tax, Navanagar, Circle – 1(1), Hubballi – 580 025. Hubballi. PAN : AABCH3176 J APPELLANT RESPONDENT Revenue by : Ms. Neera Malhotra, CIT(DR)(ITAT), Bengaluru Assessee by : Smt. Prathibha, Advocate Date of hearing : 24.06.2021 Date of Pronouncement : 30.06.2021 O R D E R Per N. V. Vasudevan, Vice President This is an appeal by the Revenue against the final order dated 11…

Hero Motocrop Ltd., New Delhi vs. ACIT, Circle- 11(1), New Delhi

The appeal of the assessee is partly allowed

ITA 9187/DEL/2019[2015-16]Status: DisposedITAT Delhi13 Apr 2021AY 2015-16

Bench: Shri Sudhanshu Srivastava & Shri O.P. Kantassessment Year: 2015-16

Section 115JSection 143(3)Section 144CSection 145ASection 80ISection 92C

…“158) We have heard the rival contentions. Our findings on the various issues raised by the assessing officer are given in seriatim hereunder: 1. Interest on loan given at subsidized rates to employees The Supreme Court in the case of Liberty India vs. CIT: 317 ITR 218, has held that source of income beyond the first degree nexus with the manufacturing operation cannot be considered as derived from such business/activity. Following the aforesaid decision, the Courts / Tribunal in certain cases have held that interest income earned from fixed deposits made by the eligible unit is not eligible for deduction under…

DCIT, New Delhi vs. M/S Malana Power Co. Ltd., New Delhi

In the result, appeal filed by the learned assessing officer in ITA number 3713/del/2017 for assessment year 2012 – 13 is dismissed

ITA 3713/DEL/2017[2012-13]Status: DisposedITAT Delhi23 Mar 2021AY 2012-13

Bench: Shri Amit Shuklaa N D Shri Prashant Maharishi(Through Video Conferencing) Dcit, Vs. Malana Power Co. Ltd, Bhilwara Bhawan, Circle-16(1)M 40-41, Community Centre, New Friends Colony, New Delhi New Delhi Pan: Aabcm1108R (Appellant) (Respondent) Malana Power Co. Ltd, Vs. Addl. Dcit, Bhilwara Bhawan, 40-41, Community Centre, New Range-6, Friends Colony, New Delhi New Delhi Pan: Aabcm1108R (Appellant) (Respondent)

For Appellant: Shri P. K. Jain, CAFor Respondent: Shri Sohil Malik, Sr. DR

Section 115JSection 14Section 14ASection 2(14)Section 80I

…where in the interest was received from trade debtors and Overdue payment from debtors. That is not the fact here. In our opinion the issue is squarely covered in favour of revenue by decision of Honorable Supreme court in case of Liberty India v. CIT [2009] 317 ITR 218 (SC) with respect to interest on FDR as it is not derived from the industrial undertaking. Thus, Ground no 2 of appeal is dismissed. 15. Thus, appeal of the assessee I partly allowed. 16. Coming to the appeal of the ld AO , ground number 1/4 are with respect to the disallowance u/s 14 A of the income tax act. The brief facts of that the learned a…

Malana Power Co. Ltd., New Delhi vs. Addl. CIT, New Delhi

In the result, appeal filed by the learned assessing officer in ITA number 3713/del/2017 for assessment year 2012 – 13 is dismissed

ITA 2464/DEL/2017[2012-13]Status: DisposedITAT Delhi23 Mar 2021AY 2012-13

For Appellant: Shri P. K. Jain, CAFor Respondent: Shri Sohil Malik, Sr. DR

Section 115JSection 14Section 14ASection 2(14)Section 80I

Kasper Information Technology Pvt. Ltd., New Delhi vs. ITO Ward-14(2), New Delhi

ITA 9357/DEL/2019[2012-13]Status: DisposedITAT Delhi18 Mar 2021AY 2012-13

Bench: Shri Amit Shukla & Shri Prashant Maharishi

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “C” NEW DELHI BEFORE SHRI AMIT SHUKLA, JUDICIAL MEMBER & SHRI PRASHANT MAHARISHI, ACCOUNTANT MEMBER I.T.A. No.4691/DEL/2016 Assessment Year 2012-13 Income Tax Officer, v. M/s. Angel Cement Pvt. Ltd., Ward-2(4), 58, 1st Floor, Jaipuria New Delhi. Enclave, Kaushambi, Ghaziabad. TAN/PAN: AAHCA6602J (Appellant) (Respondent) I.T.As. No.5974/DEL/2017 & 6401/DEL/2017 Assessment Years 2012-13 & 2014-15 Income Tax Officer, v. M/s. Delight Resorts Pvt. Ward-7(1), Ltd., New Delhi. F-1-200/13, Sector-3A, Vaishali, Ghaziabad. TAN/PAN: AAACE0061C (Appellant) (Respondent) I…