GULF PIPING COMPANY WLL,ABU DHABI vs. DY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION), DEHRADUN

Bench: Sh. Satbeer Singh Godara & Sh. S. Rifaur Rahman

195 of the Act as the impugned payments are not chargeable to tax in India as held by the Hon’ble Apex Court in GE India Technology Centre (P) Ltd. (supra) and hence the disallowance made by the Ld. AO under section 40(a)(i) of the Act is erroneous. Accordingly, ground No. 1

M/S. JAIPRAKASH POWER VENTURES LTD.,,H.P. vs. DCIT, DEHRADUN

Bench: Shri Satbeer Singh Godara & Shri M. Balaganeshassessment Year: 2007-08 With Assessment Year: 2008-09 With Assessment Year: 2009-10 Vs. Dcit, M/S, Jaiprakash Power Ventures Ltd., Circle-2, 113, Rajpur Road, Dehradun Dehradun Pan: Aaacj5463 (Appellant) (Respondent) With Assessment Year: 2008-09 Vs. M/S, Dcit, Jaiprakash Power Circle-2, Ventures Ltd., Dehradun Juit, Complex, Waknaghat, Post Office- Dumehar Bani, Kandaghat, Distt. Solan, Himachal Pradesh Pan: Aaacj5463 (Appellant) (Respondent) Assessee By Sh. Anil K. Chopra, Ca Sh. Sanjiv Choudhary, Ca Sh. V.K. Garg, Adv. Department By Sh. Amar Pal Singh, Sr. Dr Date Of Hearing 20.03.2025 Date Of Pronouncement 23.05.2025

195 Taxman 163 (Del.) and CIT v. Nectar Life Science Ltd. 2011-TIOL-681- HC-DEL-IT. 7. That without prejudice to other grounds, otherwise too, the Ld. CIT (Appeals) has erred in not holding that the said interest income is 3 | P a g e ITA Nos.3064/Del/2013; 3925/Del/2012; 3723/Del/2013 & 3929/Del/2012 derived from the eligible business and that accordingly

DCIT, DEHRADUN vs. M/S JAI PRAKASH POWER VENTURE LTD., H.P.

Bench: Shri Satbeer Singh Godara & Shri M. Balaganeshassessment Year: 2007-08 With Assessment Year: 2008-09 With Assessment Year: 2009-10 Vs. Dcit, M/S, Jaiprakash Power Ventures Ltd., Circle-2, 113, Rajpur Road, Dehradun Dehradun Pan: Aaacj5463 (Appellant) (Respondent) With Assessment Year: 2008-09 Vs. M/S, Dcit, Jaiprakash Power Circle-2, Ventures Ltd., Dehradun Juit, Complex, Waknaghat, Post Office- Dumehar Bani, Kandaghat, Distt. Solan, Himachal Pradesh Pan: Aaacj5463 (Appellant) (Respondent) Assessee By Sh. Anil K. Chopra, Ca Sh. Sanjiv Choudhary, Ca Sh. V.K. Garg, Adv. Department By Sh. Amar Pal Singh, Sr. Dr Date Of Hearing 20.03.2025 Date Of Pronouncement 23.05.2025

195 Taxman 163 (Del.) and CIT v. Nectar Life Science Ltd. 2011-TIOL-681- HC-DEL-IT. 7. That without prejudice to other grounds, otherwise too, the Ld. CIT (Appeals) has erred in not holding that the said interest income is 3 | P a g e ITA Nos.3064/Del/2013; 3925/Del/2012; 3723/Del/2013 & 3929/Del/2012 derived from the eligible business and that accordingly

M/S. JAIPRAKASH POWER VENTURES LTD.,DEHRADUN vs. DCIT, DEHRADUN

Bench: Shri Satbeer Singh Godara & Shri M. Balaganeshassessment Year: 2007-08 With Assessment Year: 2008-09 With Assessment Year: 2009-10 Vs. Dcit, M/S, Jaiprakash Power Ventures Ltd., Circle-2, 113, Rajpur Road, Dehradun Dehradun Pan: Aaacj5463 (Appellant) (Respondent) With Assessment Year: 2008-09 Vs. M/S, Dcit, Jaiprakash Power Circle-2, Ventures Ltd., Dehradun Juit, Complex, Waknaghat, Post Office- Dumehar Bani, Kandaghat, Distt. Solan, Himachal Pradesh Pan: Aaacj5463 (Appellant) (Respondent) Assessee By Sh. Anil K. Chopra, Ca Sh. Sanjiv Choudhary, Ca Sh. V.K. Garg, Adv. Department By Sh. Amar Pal Singh, Sr. Dr Date Of Hearing 20.03.2025 Date Of Pronouncement 23.05.2025

195 Taxman 163 (Del.) and CIT v. Nectar Life Science Ltd. 2011-TIOL-681- HC-DEL-IT. 7. That without prejudice to other grounds, otherwise too, the Ld. CIT (Appeals) has erred in not holding that the said interest income is 3 | P a g e ITA Nos.3064/Del/2013; 3925/Del/2012; 3723/Del/2013 & 3929/Del/2012 derived from the eligible business and that accordingly

M/S. JAIPRAKASH POWER VENTURES LTD.,DEHRADUN vs. DCIT, DEHRADUN

Bench: Shri Satbeer Singh Godara & Shri M. Balaganeshassessment Year: 2007-08 With Assessment Year: 2008-09 With Assessment Year: 2009-10 Vs. Dcit, M/S, Jaiprakash Power Ventures Ltd., Circle-2, 113, Rajpur Road, Dehradun Dehradun Pan: Aaacj5463 (Appellant) (Respondent) With Assessment Year: 2008-09 Vs. M/S, Dcit, Jaiprakash Power Circle-2, Ventures Ltd., Dehradun Juit, Complex, Waknaghat, Post Office- Dumehar Bani, Kandaghat, Distt. Solan, Himachal Pradesh Pan: Aaacj5463 (Appellant) (Respondent) Assessee By Sh. Anil K. Chopra, Ca Sh. Sanjiv Choudhary, Ca Sh. V.K. Garg, Adv. Department By Sh. Amar Pal Singh, Sr. Dr Date Of Hearing 20.03.2025 Date Of Pronouncement 23.05.2025

195 Taxman 163 (Del.) and CIT v. Nectar Life Science Ltd. 2011-TIOL-681- HC-DEL-IT. 7. That without prejudice to other grounds, otherwise too, the Ld. CIT (Appeals) has erred in not holding that the said interest income is 3 | P a g e ITA Nos.3064/Del/2013; 3925/Del/2012; 3723/Del/2013 & 3929/Del/2012 derived from the eligible business and that accordingly

KOMA SINGHAL,DEHRADUN vs. DCIT/ACIT CEN CIR, DEHRADUN

In the result, Appeal of the Assessee is allowed

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.

1 KomaSinghal IN THE INCOME TAX APPELLATE TRIBUNAL DELHI [ DELHI BENCH : “DEHRADUN” NEW DELHI] BEFORE SHRI S. RIFAUR RAHMAN, ACCOUNTANT MEMBER AND SHRI YOGESH KUMAR U.S., JUDICIAL MEMBER I.T.A. No. 59/DDN/2025 (A.Y 2021-22) Koma Singhal Vs. DCIT/ACIT 34F, Narendra Vihar Central Circle Kaulagarh Road, Dehradun Dehradun, Uttarakhand- 248001 Uttarakhand PAN: BNIPS9413P Appellant Respondent Assessee by Sh. Harshit Gupta

B R MORDEM SCHOOL SAMITI,PAURI vs. I T O, EXEMPTION WARD DEHRADUN, DEHRADUN

In the result, the appeal of the assessee is allowed

1,16,17,149/-\n(66,88,268 + 48,89,866) and since the same exceeds the maximum\nthreshold limit provided u/s 10(23C)(iiiad) of the Act for claiming\nexemption, denied the exemption to the assessee and the income was\nbrought to tax.\n5. In the instant case, AO has treated the gross receipts for the\npurpose of granting