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“Section 209(1)”

Section References (mined)Section 209Section 209(1)91 judgments

ANEEMONI NAGA RAJU,HYDERABAD vs. ITO, WARD- 8(1), HYDERABAD

In the result, appeal filed by the assessee is allowed for statistical\npurposes in terms of our aforesaid observations

ITA 2074/HYD/2025[2020-2021]Status: DisposedITAT Hyderabad20 Mar 2026AY 2020-2021
Section 142(1)Section 147Section 249(4)(b)Section 69A

aforesaid issue would require\nadverting to Section 209 of the Act which contemplates the “computation\nof advance tax”. We find that Section 209(1) of the Act envisages the\ndetermination of the amount of advance tax payable by the assessee.\nWe find on a careful perusal of Section 209(1 ... Also, we find there has been no calculation\nmade by the assessee for the purpose of payment of advance tax as\ncontemplated in Section 209(1)(a) of the Act.\n16. Considering the aforesaid facts, i.e., there has been no calculation\nof the advance tax payable either by the assessee

REKHA KHANDELWAL,RAJGARH vs. ITO WARD RAJGARH, RAJGARH

Appeal is allowed for statistical purpose

ITA 649/IND/2025[2014-15]Status: DisposedITAT Indore19 Feb 2026AY 2014-15

Bench: Shri B.M. Biyani & Shri Paresh M. Joshiassessment Year:2014-15 Rekha Khandelwal, Income-Tax Officer, Ward No.2, Near Chote Ward Rajgarh Hanuman Mandir, बनाम/ Rajgarh Bus Stand Vs. S.O. Rajgarh, (Assessee/Appellant) (Revenue/Respondent) Pan: Eljpk1548B Assessee By Shri Milind Wadhwani, Ca Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 16.02.2026 Date Of Pronouncement 19.02.2026

Section 139Section 142(1)Section 147Section 148Section 249(4)(b)Section 253(5)Section 68

lacs would saddle the assessee with an obligation to pay "advance tax", but stood corrected a careful perusal of Section 208 and Section 209(1)(a) of the Act, which contemplates determination of the said tax liability at the behest of the assessee. 14. As in the present case

BOMBARDIER TRANSPORTATION GMMH,NEW DELHI vs. ADDLDIRECOOOTOR OF INOMCE-TAX (INTERNATIONAL TAXATION),RANGE-1,, NEW DELHI

In the result, appeal of the assessee is partly allowed

ITA 4547/DEL/2017[2009-10]Status: DisposedITAT Delhi07 Jan 2026AY 2009-10

Bench: Shri Vikas Awasthy & Shri Naveen Chandraआअसं.5732/धिल्ली/2011(नि.व. 2008-09) Bombardier Transportation Gmbh, C/O M/S. Bombardier Transportation India Ltd., 3Rd Floor, B-Wing, Somdutt Chambers-I, Bhikaji Cama Place, New Delhi ...... अपीलार्थी/Appellant Pan: Aadcb-4031-C बिाम Vs. Assistant Director Of Income Tax, ..... प्रनिवादी/Respondent Circle 1(1), New Delhi आअसं.4547/धिल्ली/2017(नि.व. 2009-10) Bombardier Transportation Gmbh, C/O M/S. Bombardier Transportation India P. Ltd., Asset No. 2, 3Rd Floor, Novotel- Pullman Commercial Tower, Aero City, Delhi International Airport, New Delhi 110037 ...... अपीलार्थी/Appellant Pan: Aadcb-4031-C बिाम Vs. Assistant Director Of Income Tax, ..... प्रनिवादी/Respondent Circle 1(1), New Delhi आअसं.4511/धिल्ली/2017(नि.व. 2009-10) Deputy Commissioner Of Income Tax, (International Taxation), R. No. 409, E-2 Block, 4Th Floor, Civic Centre, Near Minto Road, ...... अपीलार्थी/Appellant New Delhi बिाम Vs. Bombardier Transportation Gmbh, C/Co Asa & Associates, K S House 118, Shahpur Jat, New Delhi 110049 ..... प्रनिवादी/Respondent Pan: Aadcb-4031-C

For Appellant: S/Shri Deepak Chopra, Anmol Anand &For Respondent: Ms. Ekta Jain CIT-DR &
Section 143(3)Section 234BSection 271(1)(c)

that the Hon’ble Supreme Court of India in the case of DIT vs. Mistibushi Corporation (supra) has held that the proviso to section 209(1) of 22 ITA Nos.4547 & 4511/Del/2017 (AY 2009-10) the Act inserted by Finance Act, 2012 would operate prospectively after AY 2012-13. Hence

DCIT, CIRCLE- 1(1)(2), INTL. TAXATION, NEW DELHI vs. BOMBARDIER TRANSPORTATION GMBH, NEW DELHI

In the result, appeal of the assessee is partly allowed

ITA 4511/DEL/2017[2009-10]Status: DisposedITAT Delhi07 Jan 2026AY 2009-10

Bench: Shri Vikas Awasthy & Shri Naveen Chandraआअसं.5732/धिल्ली/2011(नि.व. 2008-09) Bombardier Transportation Gmbh, C/O M/S. Bombardier Transportation India Ltd., 3Rd Floor, B-Wing, Somdutt Chambers-I, Bhikaji Cama Place, New Delhi ...... अपीलार्थी/Appellant Pan: Aadcb-4031-C बिाम Vs. Assistant Director Of Income Tax, ..... प्रनिवादी/Respondent Circle 1(1), New Delhi आअसं.4547/धिल्ली/2017(नि.व. 2009-10) Bombardier Transportation Gmbh, C/O M/S. Bombardier Transportation India P. Ltd., Asset No. 2, 3Rd Floor, Novotel- Pullman Commercial Tower, Aero City, Delhi International Airport, New Delhi 110037 ...... अपीलार्थी/Appellant Pan: Aadcb-4031-C बिाम Vs. Assistant Director Of Income Tax, ..... प्रनिवादी/Respondent Circle 1(1), New Delhi आअसं.4511/धिल्ली/2017(नि.व. 2009-10) Deputy Commissioner Of Income Tax, (International Taxation), R. No. 409, E-2 Block, 4Th Floor, Civic Centre, Near Minto Road, ...... अपीलार्थी/Appellant New Delhi बिाम Vs. Bombardier Transportation Gmbh, C/Co Asa & Associates, K S House 118, Shahpur Jat, New Delhi 110049 ..... प्रनिवादी/Respondent Pan: Aadcb-4031-C

For Appellant: S/Shri Deepak Chopra, Anmol Anand &For Respondent: Ms. Ekta Jain CIT-DR &
Section 143(3)Section 234BSection 271(1)(c)

that the Hon’ble Supreme Court of India in the case of DIT vs. Mistibushi Corporation (supra) has held that the proviso to section 209(1) of 22 ITA Nos.4547 & 4511/Del/2017 (AY 2009-10) the Act inserted by Finance Act, 2012 would operate prospectively after AY 2012-13. Hence

BOMBARDIER TRANSPORTATION GMBH,NEW DELHI vs. ADIT, NEW DELHI

ITA 5732/DEL/2011[2008-09]Status: DisposedITAT Delhi07 Jan 2026AY 2008-09
Section 143(3)Section 234BSection 271(1)(c)

that the Hon'ble Supreme Court of India in the case of\nDIT vs. Mistibushi Corporation (supra) has held that the proviso to section 209(1) of\n21\nITA No 5732/Del/2011 (AY 2008-09)\nITA Nos.4547 & 4511/Del/2017 (AY 2009-10)\nthe Act inserted by Finance Act, 2012 would operate prospectively

LAKHMI CHAND KHUSHIRAMANI,GWALIOR vs. INCOME TAX OFFICER, WARD 1(1), GWALIOR, GWALIOR

In the result, appeal of the assessee is allowed for statistical purposes in terms of the aforesaid observations

ITA 284/AGR/2025[2017-18]Status: DisposedITAT Agra15 Sept 2025AY 2017-18
Section 139Section 142(1)Section 144Section 249(4)Section 249(4)(b)Section 294(4)(b)Section 69A

passed by the Ld. Assessing Officer. Hence, this clause is not applicable.\n• That, in view of the above, as per provision of section 209(1)(a), the advance tax payable by the assessee was NIL.\n• Therefore, in view of above, provision of section ... advance tax payable by the assessee as mentioned in provision of section 249(4)(b) was NIL as computed as per provision of section 209(1)(a) of the Act. Accordingly, the conditions of liability to pay advance tax as per provision of section 208 of the Act, the appellant

MILLENNIUM CONTRADE PVT. LTD.,KOLKATA vs. DCIT, CIRCLE- 11(1), KOLKATA

In the result, the appeal filed by the assessee is partly allowed for\nstatistical purposes

ITA 424/KOL/2025[2014-15]Status: DisposedITAT Kolkata11 Sept 2025AY 2014-15
Section 143(3)Section 147Section 148Section 149(1)(b)Section 68Section 69C

this regard is ₹10,000/- or more.\nFurther, Section 209 of the Act r.w.s.210 specifies the manner of\ncomputation of advance tax; section 209(1) of which is reproduced as\nunder:\n“209. (1) The amount of advance tax payable by an assessee in the financial\nyear shall, subject

VARUN TRADE LINK PRIVATE LIMITED,KOLKATA vs. CIT(APPEALS), NFAC, , DELHI

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

ITA 401/KOL/2025[2014-15]Status: DisposedITAT Kolkata25 Aug 2025AY 2014-15

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 147Section 148Section 249(4)(b)Section 250Section 68

regard is Rs. 10,000/- or more. Further, Section 209 of the Act r.w.s. 210 specifies the manner of computation of advance tax; section 209(1) of which is reproduced as under: “209. (1) The amount of advance tax payable by an assessee in the financial year shall, subject

KAMLESH KUMAR,PATNA vs. ITO WARD- 6 (4), PATNA

In the result, the appeal filed by the assessee is allowed for\nstatistical purposes

ITA 147/PAT/2025[2015-16]Status: DisposedITAT Patna07 Aug 2025AY 2015-16
Section 144Section 250

Assessment Year: 2015-16\nKamlesh Kumar.\nFurther, Section 209 of the Act r.w.s. 210 specifies the manner of\ncomputation of advance tax; section 209(1) of which is reproduced as\nunder:\n“209. (1) The amount of advance tax payable by an assessee in the financial\nyear shall, subject

SURESH PATEL,DEWAS vs. CIT(A),NFAC, DELHI

Appeal is dismissed

ITA 131/IND/2025[2009-10]Status: DisposedITAT Indore31 Jul 2025AY 2009-10

Bench: Shri B.M. Biyani & Shri Paresh M. Joshi

Section 144Section 249(4)(b)Section 253(5)Section 271(1)(c)

lacs would saddle the assessee with an obligation to pay "advance tax", but stood corrected a careful perusal of Section 208 and Section 209(1)(a) of the Act, which contemplates determination of the said tax liability at the behest of the assessee. 14. As in the present case

SURESH PATEL,DEWAS vs. CIT(A) ,NFAC, DELHI

Appeal is dismissed

ITA 130/IND/2025[2009-10]Status: DisposedITAT Indore31 Jul 2025AY 2009-10

Bench: Shri B.M. Biyani & Shri Paresh M. Joshi

Section 144Section 249(4)(b)Section 253(5)Section 271(1)(c)

lacs would saddle the assessee with an obligation to pay "advance tax", but stood corrected a careful perusal of Section 208 and Section 209(1)(a) of the Act, which contemplates determination of the said tax liability at the behest of the assessee. 14. As in the present case

AMADEUS IT GROUP SA,DELHI vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIVIC CENTER

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

ITA 1494/DEL/2025[2022-23]Status: DisposedITAT Delhi04 Jul 2025AY 2022-23

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

For Appellant: Shri Neeraj Jain, AdvFor Respondent: Ms. Anjula Jain, CIT- DR
Section 143(2)Section 143(3)Section 44DSection 9(1)(vi)

income of the taxpayer held liable to tax in India, the levy of interest u/s 234B is not warranted. 34. Provisions contained below section 209(1)(d) of the Act introduced by Finance Act, 2012 wef 01.04.2012 would apply only in a situation where persons responsible for tax has paid

DEPUTY COMMISSIONER OF INCOME TAX, NOIDA vs. FORMULA ONE MARKETING II LIMITED, UNITED KINGDOM

ITA 5092/DEL/2024[2012-13]Status: DisposedITAT Delhi30 May 2025AY 2012-13

Bench: Shri Shamim Yahya & Shri Sudhir Pareek

For Appellant: Shri Hiten Thakkar, AdvFor Respondent: Shri Surender Pal Singh, CIT(DR)
Section 148Section 154Section 195Section 209Section 234ASection 234B

5092/Del/2024 Formula One Marke"ng II Limited "13. The main point argued on behalf of the Revenue relates to the interpretation of section 209(1)(d) of the Act, with stress on the words "deductible or collectible at source". The contention of the Revenue is based on the fact that ... amount of tax which would be deductible at source under the provisions of the Act during the said financial year. The provision of Section 209(1) of the Act, is reproduced as under: "209. The amount of advance tax payable by an assessee in the financial year shall, subject

RITIKA JAIN,THANE vs. ITO(IT TP), BHOPAL, AAYKAR BHAVAN

Appeal of the assessee is allowed for statistical purpose

ITA 632/IND/2024[2015-16]Status: DisposedITAT Indore29 Apr 2025AY 2015-16

Bench: Smt. Annapurna Gupta & Shri Paresh M Joshiritika Jain, Cit (Appeals), बना A-504, Laxmi Residency Chs Nfac, म/ Ltd, Delhi Vs. Opposite Datta Mandir Check Naka, Wagle Estate, Thane

Section 142(1)Section 144CSection 148Section 148ASection 250Section 253

lacs would saddle the assessee with an obligation to pay "advance tax", but stood corrected a careful perusal of Section 208 and Section 209(1)(a) of the Act, which contemplates determination of the said tax liability at the behest of the assessee. 14. As in the present case

SMS MEER GMBH,NEW DELHI vs. ACIT (INTERNATIONAL TAXATION), CIRCLE-3(1)(2), NEW DELHI

ITA 375/DEL/2020[2016-17]Status: DisposedITAT Delhi09 Apr 2025AY 2016-17
Section 144C

Mitsubishi Corporation has\nalready settled the instant issue in assessee's favour and against\nthe department, thereby holding that section 209(1) proviso\ninserted in the Act vide Finance Act, 2012, carries prospective effect\nonly. We reiterate that the assessment year before us is AY 2008-\n09. That being

SMS MEVAC UK LTD.,NEW DELHI vs. ACIT (INTERNATIONAL TAXATION), CIRCLE-3(1)(2), NEW DELHI

ITA 9738/DEL/2019[2016-17]Status: DisposedITAT Delhi09 Apr 2025AY 2016-17

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahmanassessment Year: 2008-09 With Assessment Year: 2007-08 With Assessment Year: 2007-08 With Assessment Year: 2009-10 With Assessment Year: 2010-11 With Assessment Year: 2011-12 Vs. Addl. Dit/Ddit, M/S. Sms Siemag Ag (Formerly Sms Demag Ag) Circle-2(2), Intl. Taxation, C/O- Mohinder Puri & Co., New Delhi Ca, 1A-D, Vandhna, 11 Tolstoy Marg, New Delhi Pan: Aadcs1173J (Appellant) (Respondent) With Assessment Year: 2012-13 With Assessment Year: 2013-14 With Assessment Year: 2014-15

Section 143(3)Section 144CSection 144C(1)Section 263(1)

Mitsubishi Corporation has already settled the instant issue in assessee’s favour and against the department, thereby holding that section 209(1) proviso inserted in the Act vide Finance Act, 2012, carries prospective effect only. We reiterate that the assessment year before us is AY 2008- 09. That being ... clear before parting that so far as the assessee’s section 234B interest liability is concerned, explanatory memorandum to Finance Act, 2012; regarding section 209(1) amendment (supra), has made it clear that the same applies from FY 2012-13 onwards only. We reiterate that we are dealing with

SMS GROUP GMBH,NEW DELHI vs. ACIT, CIRCLE-3(1)(2) (INT. TAX.), NEW DELHI

ITA 4044/DEL/2019[2016-17]Status: DisposedITAT Delhi09 Apr 2025AY 2016-17

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahmanassessment Year: 2008-09 With Assessment Year: 2007-08 With Assessment Year: 2007-08 With Assessment Year: 2009-10 With Assessment Year: 2010-11 With Assessment Year: 2011-12 Vs. Addl. Dit/Ddit, M/S. Sms Siemag Ag (Formerly Sms Demag Ag) Circle-2(2), Intl. Taxation, C/O- Mohinder Puri & Co., New Delhi Ca, 1A-D, Vandhna, 11 Tolstoy Marg, New Delhi Pan: Aadcs1173J (Appellant) (Respondent) With Assessment Year: 2012-13 With Assessment Year: 2013-14 With Assessment Year: 2014-15

Section 143(3)Section 144CSection 144C(1)Section 263(1)

Mitsubishi Corporation has already settled the instant issue in assessee’s favour and against the department, thereby holding that section 209(1) proviso inserted in the Act vide Finance Act, 2012, carries prospective effect only. We reiterate that the assessment year before us is AY 2008- 09. That being ... clear before parting that so far as the assessee’s section 234B interest liability is concerned, explanatory memorandum to Finance Act, 2012; regarding section 209(1) amendment (supra), has made it clear that the same applies from FY 2012-13 onwards only. We reiterate that we are dealing with

SMS MEVAC UK LTD.,NEW DELHI vs. ACIT (INTERNATIONAL TAXATION), CIRCLE-3(1)(2), NEW DELHI

ITA 3070/DEL/2019[2015-16]Status: DisposedITAT Delhi09 Apr 2025AY 2015-16

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahmanassessment Year: 2008-09 With Assessment Year: 2007-08 With Assessment Year: 2007-08 With Assessment Year: 2009-10 With Assessment Year: 2010-11 With Assessment Year: 2011-12 Vs. Addl. Dit/Ddit, M/S. Sms Siemag Ag (Formerly Sms Demag Ag) Circle-2(2), Intl. Taxation, C/O- Mohinder Puri & Co., New Delhi Ca, 1A-D, Vandhna, 11 Tolstoy Marg, New Delhi Pan: Aadcs1173J (Appellant) (Respondent) With Assessment Year: 2012-13 With Assessment Year: 2013-14 With Assessment Year: 2014-15

Section 143(3)Section 144CSection 144C(1)Section 263(1)

Mitsubishi Corporation has already settled the instant issue in assessee’s favour and against the department, thereby holding that section 209(1) proviso inserted in the Act vide Finance Act, 2012, carries prospective effect only. We reiterate that the assessment year before us is AY 2008- 09. That being ... clear before parting that so far as the assessee’s section 234B interest liability is concerned, explanatory memorandum to Finance Act, 2012; regarding section 209(1) amendment (supra), has made it clear that the same applies from FY 2012-13 onwards only. We reiterate that we are dealing with

SMS GROUP GMBH,NEW DELHI vs. JCIT (INTERNATIONAL TAXATION), CIRCLE-3(1)(2), NEW DELHI

ITA 5521/DEL/2018[2015-16]Status: DisposedITAT Delhi09 Apr 2025AY 2015-16
Section 144C

Mitsubishi Corporation has\nalready settled the instant issue in assessee's favour and against\nthe department, thereby holding that section 209(1) proviso\ninserted in the Act vide Finance Act, 2012, carries prospective effect\nonly. We reiterate that the assessment year before us is AY 2008-\n09. That being

SMS GROUP GMBH,NEW DELHI vs. ACIT (INTERNATIONAL TAXATION), CIRCLE-3(1)(2), NEW DELHI

ITA 7570/DEL/2017[2014-15]Status: DisposedITAT Delhi09 Apr 2025AY 2014-15

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahmanassessment Year: 2008-09 With Assessment Year: 2007-08 With Assessment Year: 2007-08 With Assessment Year: 2009-10 With Assessment Year: 2010-11 With Assessment Year: 2011-12 Vs. Addl. Dit/Ddit, M/S. Sms Siemag Ag (Formerly Sms Demag Ag) Circle-2(2), Intl. Taxation, C/O- Mohinder Puri & Co., New Delhi Ca, 1A-D, Vandhna, 11 Tolstoy Marg, New Delhi Pan: Aadcs1173J (Appellant) (Respondent) With Assessment Year: 2012-13 With Assessment Year: 2013-14 With Assessment Year: 2014-15

Section 143(3)Section 144CSection 144C(1)Section 263(1)

Mitsubishi Corporation has already settled the instant issue in assessee’s favour and against the department, thereby holding that section 209(1) proviso inserted in the Act vide Finance Act, 2012, carries prospective effect only. We reiterate that the assessment year before us is AY 2008- 09. That being ... clear before parting that so far as the assessee’s section 234B interest liability is concerned, explanatory memorandum to Finance Act, 2012; regarding section 209(1) amendment (supra), has made it clear that the same applies from FY 2012-13 onwards only. We reiterate that we are dealing with

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