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“PPT”

International TaxMLIMLI293 judgments

Judgments citing PPT

Utpalkumar Devendrakumar Thakor, Vapi vs. DCIT, Vapi Circle, Vapi

In the result, the appeal of the assessee is allowed

ITA 1115/SRT/2025[2013-14]Status: HeardITAT Surat23 Jan 2026AY 2013-14

Bench: Dr. B.R.R. Kumar, Vice- & Ms. Suchitra Kamble

For Appellant: Shri Suresh K. Kabra, C.AFor Respondent: Shri Ashish Kumar, Sr. D.R
Section 69

IN THE INCOME TAX APPELLATE TRIBUNAL SURAT “SMC” BENCH, SURAT BEFORE DR. B.R.R. KUMAR, VICE-PRESIDENT AND MS. SUCHITRA KAMBLE

Kamlesh Tyagi, Delhi vs. Office of the Commissioner of Income Tax, Appeal, Delhi

The appeal of the assessee is allowed

ITA 8789/DEL/2025[2020-21]Status: DisposedITAT Delhi22 Jan 2026AY 2020-21

Bench: Sh. Satbeer Singh Godaraita No. 8789/Del/2025 : Asstt. Year: 2020-21 Kamlesh Tyagi, Vs Cit(A)/Nfac, A-601, Lake View Apptt., Paschim Income Tax Officer, Vihar, Sunder Vihar, West Delhi, Ward-67(1), New Delhi-110087 New Delhi-110002 (Appellant) (Respondent) Pan No. Aadpt4266G Assessee By: Sh. Kamlesh Tyagi (Individual) Revenue By : Sh. Manoj Kumar, Sr. Dr Date Of Hearing: 22.01.2026 Date Of Pronouncement: 22.01.2026 Order This Assessee’S Appeal For Assessment Year 2020-21 Arises Against The Addl./Jcit(A)-2, Hyderabad’S Din & Order No.Itba/Apl/S/250/2024-25/1066275720(1) Dated 30.06.2024, In Proceedings U/S 143(1) Of The Income Tax Act, 1961 (In Short “The Act”).

For Appellant: Sh. Kamlesh Tyagi (Individual)For Respondent: Sh. Manoj Kumar, Sr. DR
Section 10Section 143(1)

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘SMC’, NEW DELHI Before Sh. Satbeer Singh Godara, Judicial Member ITA No

ITO WD 3(1), Kolkata vs. Sapphire Global Finance Private Limited, Kolkata

In the result, all the three appeals of the Revenue are dismissed

ITA 1590/KOL/2025[2016-17]Status: DisposedITAT Kolkata20 Jan 2026AY 2016-17

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

For Appellant: Shri Somnath Ghosh, ARFor Respondent: Shri S.B. Chakraborthy, DR
Section 133(6)Section 143(2)Section 148Section 148ASection 68

IN THE INCOME TAX APPELLATE TRIBUNAL “D” BENCH, KOLKATA BEFORE SHRI RAJESH KUMAR, AM AND SHRI PRADIP KUMAR CHOUBEY, JM

ITO WD-3(1), Kolkata vs. Sapphire Global Finance Private Limited, Kolkata

In the result, all the three appeals of the Revenue are dismissed

ITA 1506/KOL/2025[2015-16]Status: DisposedITAT Kolkata20 Jan 2026AY 2015-16

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

For Appellant: Shri Somnath Ghosh, ARFor Respondent: Shri S.B. Chakraborthy, DR
Section 133(6)Section 143(2)Section 148Section 148ASection 68

IN THE INCOME TAX APPELLATE TRIBUNAL “D” BENCH, KOLKATA BEFORE SHRI RAJESH KUMAR, AM AND SHRI PRADIP KUMAR CHOUBEY, JM

ITO WD-3(1), Kolkata vs. Sapphire Global Finance (P) Ltd, Kolkata

In the result, all the three appeals of the Revenue are dismissed

ITA 1454/KOL/2025[2014-15]Status: DisposedITAT Kolkata20 Jan 2026AY 2014-15

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

Section 133(6)Section 143(2)Section 148Section 148ASection 68

IN THE INCOME TAX APPELLATE TRIBUNAL “D” BENCH, KOLKATA BEFORE SHRI RAJESH KUMAR, AM AND SHRI PRADIP KUMAR CHOUBEY, JM

Laxmi Kashinath Thanekar, Maharashtra vs. Commissioner of Income Tax Appeal, Thane

In the result, the appeal is allowed for statistical

ITA 4780/MUM/2025[2011-12]Status: DisposedITAT Mumbai19 Jan 2026AY 2011-12

Bench: Shri Sandeep Gosain

For Respondent: Shri Surendra Mohan, (Sr. DR)
Section 143(3)Section 148Section 234B

IN THE INCOME-TAX APPELLATE TRIBUNAL“A” BENCH, MUMBAI BEFORE SHRI SANDEEP GOSAIN, JUDICIAL MEMBER & SHRI PRABHASH SHANKAR, ACCOUNTANT MEMBER

Shri Rahul Sumerchand Dodal L/H Shri Sumerchand R Dodal, Mumbai vs. ITO, Ward 27(3)(1), Mumbai

In the result, appeal filed by the assessee stands dismissed, however with liberty as mentioned above

ITA 2328/MUM/2025[2014-15]Status: DisposedITAT Mumbai30 Dec 2025AY 2014-15

Bench: Shri Narender Kumar Choudhryassessment Year : 2014-15

For Appellant: NoneFor Respondent: Shri A.M.K. Mahadevan, Ld. Sr.DR
Section 250

IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI “SMC” BENCH : MUMBAI BEFORE SHRI NARENDER KUMAR CHOUDHRY, JUDICIAL MEMBER Assessment Year : 2014

Amish Jayeshbhai Dadawala, Vadodara vs. The ITO, Ward-1(2)(1) Previously Ward-1(1)(2), Vadodara

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

ITA 1528/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad24 Dec 2025AY 2017-18

Bench: Shri Suchitra Kamble

For Appellant: Shri Alok Shah, A.RFor Respondent: Shri Suresh Chand Meena, Sr. D.R
Section 142(1)Section 143(2)Section 143(3)Section 24BSection 250Section 69A

THE INCOME TAX APPELLATE TRIBUNAL AHMEDABAD “SMC" BENCH Before Shri Suchitra Kamble, Judicial Member ITA No. 1528/Ahd/2025 Assessment Year 2017

Sanjeev Sharma, New Delh vs. ACIT, Central Circle-16, New Delhi

The appeals of the assessee are allowed

ITA 2046/DEL/2022[2013-14]Status: DisposedITAT Delhi14 Nov 2025AY 2013-14

Bench: Shri Mahavir Singh & Shri Krinwant Sahay[Assessment Year:2013-14]

Section 132Section 153ASection 153CSection 69Section 69A

facts and circumstances, the issue of addition of Rs.31,53,600/-u/s.69 Aarising out of the printout taken from seized power point presentation (PPT) named "Kautilya Airbus Proposal" found and seized from email of Deepak Talwar, being the material seized from a 3rd party in search undertaken on said ... without prejudice, under the facts and circumstances, as the date of relevant email is 14.10.15 (A.Y.16-17), hence under no circumstance, the contents of this PPT can be taken as applicable for A. Y.13-14. Brief facts of the case:- A Search & seizure operation u/s 132 of the 4. Act was carried

Sanjeev Sharma, New Delhi vs. ACIT Central Circale-16, New Delhi

The appeals of the assessee are allowed

ITA 1979/DEL/2022[2017-18]Status: DisposedITAT Delhi14 Nov 2025AY 2017-18

Bench: Shri Mahavir Singh & Shri Krinwant Sahay[Assessment Year:2013-14]

Section 132Section 153ASection 153CSection 69Section 69A

facts and circumstances, the issue of addition of Rs.31,53,600/-u/s.69 Aarising out of the printout taken from seized power point presentation (PPT) named "Kautilya Airbus Proposal" found and seized from email of Deepak Talwar, being the material seized from a 3rd party in search undertaken on said ... without prejudice, under the facts and circumstances, as the date of relevant email is 14.10.15 (A.Y.16-17), hence under no circumstance, the contents of this PPT can be taken as applicable for A. Y.13-14. Brief facts of the case:- A Search & seizure operation u/s 132 of the 4. Act was carried

Sanjeev Sharma, New Delhi vs. ACIT, Central Circle-16, New Delhi

The appeals of the assessee are allowed

ITA 1978/DEL/2022[2016-17]Status: DisposedITAT Delhi14 Nov 2025AY 2016-17

Bench: Shri Mahavir Singh & Shri Krinwant Sahay[Assessment Year:2013-14]

Section 132Section 153ASection 153CSection 69Section 69A

facts and circumstances, the issue of addition of Rs.31,53,600/-u/s.69 Aarising out of the printout taken from seized power point presentation (PPT) named "Kautilya Airbus Proposal" found and seized from email of Deepak Talwar, being the material seized from a 3rd party in search undertaken on said ... without prejudice, under the facts and circumstances, as the date of relevant email is 14.10.15 (A.Y.16-17), hence under no circumstance, the contents of this PPT can be taken as applicable for A. Y.13-14. Brief facts of the case:- A Search & seizure operation u/s 132 of the 4. Act was carried

Sanjeev Sharma, New Delhi vs. ACIT Central Circle-16, New Delhi

The appeals of the assessee are allowed

ITA 1977/DEL/2022[2015-16]Status: DisposedITAT Delhi14 Nov 2025AY 2015-16

Bench: Shri Mahavir Singh & Shri Krinwant Sahay[Assessment Year:2013-14]

Section 132Section 153ASection 153CSection 69Section 69A

facts and circumstances, the issue of addition of Rs.31,53,600/-u/s.69 Aarising out of the printout taken from seized power point presentation (PPT) named "Kautilya Airbus Proposal" found and seized from email of Deepak Talwar, being the material seized from a 3rd party in search undertaken on said ... without prejudice, under the facts and circumstances, as the date of relevant email is 14.10.15 (A.Y.16-17), hence under no circumstance, the contents of this PPT can be taken as applicable for A. Y.13-14. Brief facts of the case:- A Search & seizure operation u/s 132 of the 4. Act was carried

Sanjeev Sharma, New Delhi vs. ACIT Central Circle-16, New Delhi

The appeals of the assessee are allowed

ITA 1976/DEL/2022[2014-15]Status: DisposedITAT Delhi14 Nov 2025AY 2014-15

Bench: Shri Mahavir Singh & Shri Krinwant Sahay[Assessment Year:2013-14]

Section 132Section 153ASection 153CSection 69Section 69A

facts and circumstances, the issue of addition of Rs.31,53,600/-u/s.69 Aarising out of the printout taken from seized power point presentation (PPT) named "Kautilya Airbus Proposal" found and seized from email of Deepak Talwar, being the material seized from a 3rd party in search undertaken on said ... without prejudice, under the facts and circumstances, as the date of relevant email is 14.10.15 (A.Y.16-17), hence under no circumstance, the contents of this PPT can be taken as applicable for A. Y.13-14. Brief facts of the case:- A Search & seizure operation u/s 132 of the 4. Act was carried

Pankaj Sharma, Surat vs. Income Tax Officer 19(2)(4), Mumbai

In the result, both the appeals are allowed for statistical purposes

ITA 5921/MUM/2025[2022-23]Status: DisposedITAT Mumbai13 Nov 2025AY 2022-23

Bench: Shri Vikram Singh Yadav & Shri Anikesh Banerjee

For Appellant: Shri Brijesh VyasFor Respondent: Shri Virabhadra Mahajan, Sr.DR

IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI “C” BENCH : MUMBAI BEFORE SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER AND SHRI ANIKESH

Pankaj Sharma, Surat vs. Income Tax Officer 19(2)(4), Mumbai

In the result, both the appeals are allowed for statistical purposes

ITA 5920/MUM/2025[2019-20]Status: DisposedITAT Mumbai13 Nov 2025AY 2019-20

Bench: Shri Vikram Singh Yadav & Shri Anikesh Banerjee

For Appellant: Shri Brijesh VyasFor Respondent: Shri Virabhadra Mahajan, Sr.DR

IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI “C” BENCH : MUMBAI BEFORE SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER AND SHRI ANIKESH

Fullerton Financial Holdings Pte. Ltd., Singapore vs. The Assistant Commissioner of Income-Tax - (International Taxation), Circle 2(3)(1) - Mumbai, Mumbai

ITA 1137/MUM/2025[2022-23]Status: DisposedITAT Mumbai28 Oct 2025AY 2022-23

Bench: Smt. Beena Pillai () & Smt. Renu Jauhri ()

Section 143(2)Section 143(3)Section 144CSection 144C(1)Section 144C(13)Section 144C(5)Section 153

issue, therefore, that arises for consideration is whether, on the facts and circumstances of the case, the assessee satisfies the Principal Purpose Test (PPT) prescribed under Article 24A(1) and (2) of the India–Singapore DTAA for availing treaty benefit under Article 13(AA) in respect of the impugned transaction

Sai Engineering, Jamshedpur vs. I.T.O. Ward 3(1), Jamshedpur

In the result, both these appeals of the assessee are partly allowed for statistical purposes

ITA 282/RAN/2024[2021-2022]Status: DisposedITAT Ranchi09 Oct 2025AY 2021-2022

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahay

IN THE INCOME TAX APPELLATE TRIBUNAL, RANCHI BENCH, RANCHI BEFORE SHRI GEORGE MATHAN, JUDICIAL MEMBER AND SHRI RATNESH NANDAN SAHAY

Sai Engineering, Jamshedpur vs. ITO Ward 3(1), Jamshedpur

In the result, both these appeals of the assessee are partly allowed for statistical purposes

ITA 281/RAN/2024[2019-2020]Status: DisposedITAT Ranchi09 Oct 2025AY 2019-2020

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahay

IN THE INCOME TAX APPELLATE TRIBUNAL, RANCHI BENCH, RANCHI BEFORE SHRI GEORGE MATHAN, JUDICIAL MEMBER AND SHRI RATNESH NANDAN SAHAY

Sky High II Leasing Company Limited, Mumbai vs. The Assistant Commissioner of Income Tax (International Tax) Circle 4(2)(1), Mumbai

ITA 1550/MUM/2025[2022-23]Status: DisposedITAT Mumbai06 Oct 2025AY 2022-23

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

Section 143(3)Section 9(1)(vi)

assessee and held that the lease rentals are taxable in India for the reason that the assessee failed to prove the Principal Purpose Test (PPT) as per Article-6 & 7 of Multilateral Convention to implement tax treaty related measures to prevent base erosion and profit shifting (MLI). Accordingly ... accordingly. Aggrieved the assessee raised objections before the Dispute Resolution Panel (DRP). The DRP upheld the finding of the AO with regard to the PPT on the ground that (i) The onus on revenue to show that PPT is not satisfied is based only on reasonableness and not strictly evidence

Sky High Lxxx Leasing Company Limited, Mumbai vs. The Assistant Commissioner of Income Tax (International Tax) Circle 4(2)(1), Mumbai

ITA 1549/MUM/2025[2022-23]Status: DisposedITAT Mumbai06 Oct 2025AY 2022-23

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

Section 143(3)Section 9(1)(vi)

assessee and held that the lease rentals are taxable in India for the reason that the assessee failed to prove the Principal Purpose Test (PPT) as per Article-6 & 7 of Multilateral Convention to implement tax treaty related measures to prevent base erosion and profit shifting (MLI). Accordingly ... accordingly. Aggrieved the assessee raised objections before the Dispute Resolution Panel (DRP). The DRP upheld the finding of the AO with regard to the PPT on the ground that (i) The onus on revenue to show that PPT is not satisfied is based only on reasonableness and not strictly evidence