M/S. A.T. KEARNEY INDIA PRIVATE LIMITED,GURGAON vs. ITO, NEW DELHI

In the result the ground No

Bench: Smt Diva Singh & Shri Prashant Maharishiat Kearney India Private Ito, Limited, Ward-1(1), Vs. 6Th Floor, Tower-D, Global New Delhi Business Park, Gurgaon Pan:Aadca1436G (Appellant) (Respondent) At Kearney India Private Ito, Limited, Ward-1(1), Vs. 6Th Floor, Tower-D, Global New Delhi Business Park, Gurgaon Pan:Aadca1436G (Appellant) (Respondent)

TDS. The return was processed under section 143(1) of the I.T. Act. 1961 on 17-05-2006, determining a Refund of Rs.30.282/- including interest. From the perusal of the I.T. Return, the following was observed: 1.1. As per annexure 5, notes to the computation, the assessee is engaged in providing IT enabled services involving research and production support

M/S. A.T. KEARNEY INDIA PRIVATE LIMITED,GURGAON vs. ITO, NEW DELHI

In the result the ground No

Bench: Smt Diva Singh & Shri Prashant Maharishiat Kearney India Private Ito, Limited, Ward-1(1), Vs. 6Th Floor, Tower-D, Global New Delhi Business Park, Gurgaon Pan:Aadca1436G (Appellant) (Respondent) At Kearney India Private Ito, Limited, Ward-1(1), Vs. 6Th Floor, Tower-D, Global New Delhi Business Park, Gurgaon Pan:Aadca1436G (Appellant) (Respondent)

TDS. The return was processed under section 143(1) of the I.T. Act. 1961 on 17-05-2006, determining a Refund of Rs.30.282/- including interest. From the perusal of the I.T. Return, the following was observed: 1.1. As per annexure 5, notes to the computation, the assessee is engaged in providing IT enabled services involving research and production support

HINDUSTAN COCA COLA BEVERAGES vs. JT.COMMISSIONER OF INCOME TAX

The appeal is allowed in the above terms, but in the circumstances, with

Bench: HON'BLE DR. JUSTICE S.MURALIDHAR,HON'BLE MR. JUSTICE NAJMI WAZIRI

10 of 17 agreement, the payments attracted TDS under Section 194-C and not Section 194-I of the Act. 24. There

MARUTI SUZUKI INDIA LTD.,NEW DELHI vs. DCIT, CIRCLE-16(1), NEW DELHI

Bench: Shri G. S. Pannu, Shri N.V.Vasudevan & Shri Vikas Awasthyआअसुं.6997/म ुं/2019(धन.व. 2016-17) Deputy Commissioner Of Income Tax Circle 11(3)(1), Mumbai ...... अपीलाथी/Appellant बनाम Vs. Total Oil India Pvt. Ltd. 3Rd Floor, The Leela Galleria, Andheri ( East), Mumbai 400 059 ..... प्रधिवादी/Respondent Pan: Aaace-2175-M C.O. No.57/Mum/2019 Total Oil India Pvt. Ltd. Mumbai – 400 059 ...... Cross Objector बनाम Vs. Deputy Commissioner Of Income Tax ...... प्रधिवादी/Respondent Circle 11(3)(1), Mumbai.

TDS liability when payment to a payee is on net of tax basis. 24. The ld. Counsel referring to the provisions of section 115-O(6) submits that sub-section (6) exempt a developer or enterprise of SEZ or the person receiving such dividend from the rigours of section 115-O(1) of the Act. The conferring of exemption

MARUTI SUZUKI INDIA LTD.,NEW DELHI vs. DCIT, CIRCLE-16(1), NEW DELHI

Bench: Shri G. S. Pannu, Shri N.V.Vasudevan & Shri Vikas Awasthyआअसुं.6997/म ुं/2019(धन.व. 2016-17) Deputy Commissioner Of Income Tax Circle 11(3)(1), Mumbai ...... अपीलाथी/Appellant बनाम Vs. Total Oil India Pvt. Ltd. 3Rd Floor, The Leela Galleria, Andheri ( East), Mumbai 400 059 ..... प्रधिवादी/Respondent Pan: Aaace-2175-M C.O. No.57/Mum/2019 Total Oil India Pvt. Ltd. Mumbai – 400 059 ...... Cross Objector बनाम Vs. Deputy Commissioner Of Income Tax ...... प्रधिवादी/Respondent Circle 11(3)(1), Mumbai.

TDS liability when payment to a payee is on net of tax basis. 24. The ld. Counsel referring to the provisions of section 115-O(6) submits that sub-section (6) exempt a developer or enterprise of SEZ or the person receiving such dividend from the rigours of section 115-O(1) of the Act. The conferring of exemption

MARUTI SUZUKI INDIA LTD,NEW DELHI vs. DCIT, CIRCLE-16(1), NEW DELHI

Bench: Shri G. S. Pannu, Shri N.V.Vasudevan & Shri Vikas Awasthyआअसुं.6997/म ुं/2019(धन.व. 2016-17) Deputy Commissioner Of Income Tax Circle 11(3)(1), Mumbai ...... अपीलाथी/Appellant बनाम Vs. Total Oil India Pvt. Ltd. 3Rd Floor, The Leela Galleria, Andheri ( East), Mumbai 400 059 ..... प्रधिवादी/Respondent Pan: Aaace-2175-M C.O. No.57/Mum/2019 Total Oil India Pvt. Ltd. Mumbai – 400 059 ...... Cross Objector बनाम Vs. Deputy Commissioner Of Income Tax ...... प्रधिवादी/Respondent Circle 11(3)(1), Mumbai.

TDS liability when payment to a payee is on net of tax basis. 24. The ld. Counsel referring to the provisions of section 115-O(6) submits that sub-section (6) exempt a developer or enterprise of SEZ or the person receiving such dividend from the rigours of section 115-O(1) of the Act. The conferring of exemption

MARUTI SUZUKI INDIA LTD,NEW DELHI vs. DCIT, CIRCLE-16(1), NEW DELHI

Bench: Shri G. S. Pannu, Shri N.V.Vasudevan & Shri Vikas Awasthyआअसुं.6997/म ुं/2019(धन.व. 2016-17) Deputy Commissioner Of Income Tax Circle 11(3)(1), Mumbai ...... अपीलाथी/Appellant बनाम Vs. Total Oil India Pvt. Ltd. 3Rd Floor, The Leela Galleria, Andheri ( East), Mumbai 400 059 ..... प्रधिवादी/Respondent Pan: Aaace-2175-M C.O. No.57/Mum/2019 Total Oil India Pvt. Ltd. Mumbai – 400 059 ...... Cross Objector बनाम Vs. Deputy Commissioner Of Income Tax ...... प्रधिवादी/Respondent Circle 11(3)(1), Mumbai.

TDS liability when payment to a payee is on net of tax basis. 24. The ld. Counsel referring to the provisions of section 115-O(6) submits that sub-section (6) exempt a developer or enterprise of SEZ or the person receiving such dividend from the rigours of section 115-O(1) of the Act. The conferring of exemption

MARUTI SUZUKI INDIA LIMITED,NEW DELHI vs. ACIT, SPL. RANGE-6, NEW DELHI

Bench: Shri G. S. Pannu, Shri N.V.Vasudevan & Shri Vikas Awasthyआअसुं.6997/म ुं/2019(धन.व. 2016-17) Deputy Commissioner Of Income Tax Circle 11(3)(1), Mumbai ...... अपीलाथी/Appellant बनाम Vs. Total Oil India Pvt. Ltd. 3Rd Floor, The Leela Galleria, Andheri ( East), Mumbai 400 059 ..... प्रधिवादी/Respondent Pan: Aaace-2175-M C.O. No.57/Mum/2019 Total Oil India Pvt. Ltd. Mumbai – 400 059 ...... Cross Objector बनाम Vs. Deputy Commissioner Of Income Tax ...... प्रधिवादी/Respondent Circle 11(3)(1), Mumbai.

TDS liability when payment to a payee is on net of tax basis. 24. The ld. Counsel referring to the provisions of section 115-O(6) submits that sub-section (6) exempt a developer or enterprise of SEZ or the person receiving such dividend from the rigours of section 115-O(1) of the Act. The conferring of exemption

CHRONICLE PUBLICATION PVT LTD,NEW DELHI vs. ACIT (CPC)-TDS, NEW DELHI

In the result, all appeals of different assesses are allowed

Bench: Ms. Sushma Chowla, Vp & Dr. B.R.R. Kumar, Am

10. We have heard the rival contention and perused the record. The issue which is arising in the present set of appeals is against the chargeability of late filing fee in terms of section 234E of the Act. The issue which is raised by different assessee before us is whether where the return for the TDS

CHRONICLE PUBLICATION PVT LTD,NEW DELHI vs. ACIT (CPC)-TDS, NEW DELHI

In the result, all appeals of different assesses are allowed

Bench: Ms. Sushma Chowla, Vp & Dr. B.R.R. Kumar, Am

10. We have heard the rival contention and perused the record. The issue which is arising in the present set of appeals is against the chargeability of late filing fee in terms of section 234E of the Act. The issue which is raised by different assessee before us is whether where the return for the TDS

CHRONICLE PUBLICATION PVT LTD,NEW DELHI vs. ACIT (CPC)-TDS, NEW DELHI

In the result, all appeals of different assesses are allowed

Bench: Ms. Sushma Chowla, Vp & Dr. B.R.R. Kumar, Am

10. We have heard the rival contention and perused the record. The issue which is arising in the present set of appeals is against the chargeability of late filing fee in terms of section 234E of the Act. The issue which is raised by different assessee before us is whether where the return for the TDS

CHRONICLE PUBLICATION PVT LTD,NEW DELHI vs. ACIT (CPC)-TDS, NEW DELHI

In the result, all appeals of different assesses are allowed

Bench: Ms. Sushma Chowla, Vp & Dr. B.R.R. Kumar, Am

10. We have heard the rival contention and perused the record. The issue which is arising in the present set of appeals is against the chargeability of late filing fee in terms of section 234E of the Act. The issue which is raised by different assessee before us is whether where the return for the TDS

CHRONICLE PUBLICATION PVT LTD,NEW DELHI vs. ACIT (CPC)-TDS, NEW DELHI

In the result, all appeals of different assesses are allowed

Bench: Ms. Sushma Chowla, Vp & Dr. B.R.R. Kumar, Am

10. We have heard the rival contention and perused the record. The issue which is arising in the present set of appeals is against the chargeability of late filing fee in terms of section 234E of the Act. The issue which is raised by different assessee before us is whether where the return for the TDS

CHRONICLE PUBLICATION PVT LTD,NEW DELHI vs. ACIT (CPC)-TDS, NEW DELHI

In the result, all appeals of different assesses are allowed

Bench: Ms. Sushma Chowla, Vp & Dr. B.R.R. Kumar, Am

10. We have heard the rival contention and perused the record. The issue which is arising in the present set of appeals is against the chargeability of late filing fee in terms of section 234E of the Act. The issue which is raised by different assessee before us is whether where the return for the TDS

CHRONICLE PUBLICATION PVT LTD,NEW DELHI vs. ACIT (CPC)-TDS, NEW DELHI

In the result, all appeals of different assesses are allowed

Bench: Ms. Sushma Chowla, Vp & Dr. B.R.R. Kumar, Am

10. We have heard the rival contention and perused the record. The issue which is arising in the present set of appeals is against the chargeability of late filing fee in terms of section 234E of the Act. The issue which is raised by different assessee before us is whether where the return for the TDS

CHRONICLE PUBLICATION PVT LTD,NEW DELHI vs. ACIT (CPC)-TDS, NEW DELHI

In the result, all appeals of different assesses are allowed

Bench: Ms. Sushma Chowla, Vp & Dr. B.R.R. Kumar, Am

10. We have heard the rival contention and perused the record. The issue which is arising in the present set of appeals is against the chargeability of late filing fee in terms of section 234E of the Act. The issue which is raised by different assessee before us is whether where the return for the TDS

CHRONICLE PUBLICATION PVT LTD,NEW DELHI vs. ACIT (CPC)-TDS, NEW DELHI

In the result, all appeals of different assesses are allowed

Bench: Ms. Sushma Chowla, Vp & Dr. B.R.R. Kumar, Am

10. We have heard the rival contention and perused the record. The issue which is arising in the present set of appeals is against the chargeability of late filing fee in terms of section 234E of the Act. The issue which is raised by different assessee before us is whether where the return for the TDS