KUNSHAN Q TECH MICROELECTRONICS (INDIA) PVT. LTD.,UTTAR PRADESH vs. DCIT, CENTRAL CIRCLE-30, DELHI

2) of the I.T. Act, and A.O. have been vested with the jurisdiction over the case of the assessee. In that event, if there is any dispute of the jurisdiction of the A.O, such question will be determined in accordance with the provisions of Section 124 of the Income Tax Act. However, in the present case, the Addl. CIT, Range

JSP PROJECTS (P) LTD,DELHI vs. DCIT CENTRAL CIRCLE - 13, DELHI

In the result appeal of the assessee in ITA number 3646/Del/2025 and

Bench: Shri Yogesh Kumar U.S. & Shri Amitabh Shukla, Accountnat Member

127(2) of the Income-tax Act, 1961, which was carried out by an incompetent authority, rendering the assessment without proper jurisdiction. Non-compliance with Section 65B of Indian Evidence Act 1872/section 63 of BSA 2023 7. That on the facts and in the circumstances of the case, the Ld. CIT(A) erred on fact and in law in sustaining

JSP PROJECTS (P) LTD,DELHI vs. DCIT CENTRAL CIRCLE - 13, DELHI

In the result appeal of the assessee in ITA number 3646/Del/2025 and

Bench: Shri Yogesh Kumar U.S. & Shri Amitabh Shukla, Accountnat Member

127(2) of the Income-tax Act, 1961, which was carried out by an incompetent authority, rendering the assessment without proper jurisdiction. Non-compliance with Section 65B of Indian Evidence Act 1872/section 63 of BSA 2023 7. That on the facts and in the circumstances of the case, the Ld. CIT(A) erred on fact and in law in sustaining

JSP PROJECTS (P) LTD,DELHI vs. DCIT CENTRAL CIRCLE - 13, DELHI

In the result appeal of the assessee in ITA number 3646/Del/2025 and

Bench: Shri Yogesh Kumar U.S. & Shri Amitabh Shukla, Accountnat Member

127(2) of the Income-tax Act, 1961, which was carried out by an incompetent authority, rendering the assessment without proper jurisdiction. Non-compliance with Section 65B of Indian Evidence Act 1872/section 63 of BSA 2023 7. That on the facts and in the circumstances of the case, the Ld. CIT(A) erred on fact and in law in sustaining

JSP PROJECTS (P) LTD,DELHI vs. DCIT CENTRAL CIRCLE - 13, DELHI

In the result appeal of the assessee in ITA number 3646/Del/2025 and

Bench: Shri Yogesh Kumar U.S. & Shri Amitabh Shukla, Accountnat Member

127(2) of the Income-tax Act, 1961, which was carried out by an incompetent authority, rendering the assessment without proper jurisdiction. Non-compliance with Section 65B of Indian Evidence Act 1872/section 63 of BSA 2023 7. That on the facts and in the circumstances of the case, the Ld. CIT(A) erred on fact and in law in sustaining

JSP PROJECTS (P) LTD,DELHI vs. DCIT CENTRAL CIRCLE -13, DELHI

In the result appeal of the assessee in ITA number 3646/Del/2025 and

Bench: Shri Yogesh Kumar U.S. & Shri Amitabh Shukla, Accountnat Member

127(2) of the Income-tax Act, 1961, which was carried out by an incompetent authority, rendering the assessment without proper jurisdiction. Non-compliance with Section 65B of Indian Evidence Act 1872/section 63 of BSA 2023 7. That on the facts and in the circumstances of the case, the Ld. CIT(A) erred on fact and in law in sustaining

HERO MOTOCORP LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result appeal No. 2424/Del/ 2015 filed by the revenue in assessment year 2010-11 is partly allowed

Bench: Shri R. K. Panda & Ms Suchitra Kamble

section 194C was amended by the Finance (2) Act, 2009 w.e.f. 1.10.2009, whereby the definition of “work” was enlarged to include contract for manufacturing or supplying a product according to the requirement or specification of a customer by using material purchased from such customer. The said amendment also provided that contract for carrying out work shall not include contract

REETA SINGHAL,MEERUT vs. ITO, WARD- 2(2), MEERUT

In the result, appeal of the Assessee allowed

Bench: Shri Bhavnesh Saini & Shri N.K. Billaiya

TDS statement [26AS]. In the absence of explanation of assessee, addition of Rs.55,700/- was made. The A.O. also noted that in the return assessee claimed deduction of Rs.1,10,714/- under section 80 of the I.T. Act, 1961. In the absence of documentary evidences, A.O. made addition of Rs.1,10,714/- and completed the assessment under section

HERO MOTOCORP LTD.,,NEW DELHI vs. ADDL.CIT, RANGE-11, NEW DELHI

In the result ground No

Bench: Shri R. K. Panda & Ms Suchitra Kamblei.T.A. No. 6990/Del/2017 (A.Y 2013-14)

2 - Grant of License and Exclusivity ii) ARTICLE 3-No sublicense iii) ARTICLE 9 - Use and Disclosure of Technical Information iv) ARTICLE 13 - Terms of agreement (upto 30.06.2007) v) ARTICLE 21/22 Termination/Effect of Expiry and Termination vi) ARTICLE 25/26 Certain Prohibitions/Maintenance of Secrecy To the same effect are the following clauses placing restrictions on use of knowhow by the assessee

MICROSOFT CORPORATION (INDIA) PRIVATE LIMITED,NEW DELHI vs. DCIT, CIRCLE-16(1), NEW DELHI

In the result, the appeal of the assessee is allowed

Bench: Shri M. Balaganesh & Shri Yogesh Kumar Usmicrosoft Corporation (India) Vs. Dcit, Pvt. Ltd, Circle-16(1), 807, New Delhi House, New Delhi Barakhamba Road, New Delhi (Appellant) (Respondent) Pan: Aaacm5586C Assessee By : Shri Nageswar Rao & Parth, Adv Revenue By: Shri Rajesh Kumar, Cit(Dr) Date Of Hearing 22/02/2024 Date Of Pronouncement 28/02/2024

TDS. The case of the assessee was referred by the ld AO to ld TPO for benchmarking the international transaction of the assessee. The ld TPO passed order u/s 92CA(3) of the Act on 30.07.2021 proposing an arm‟s length price (ALP) of Rs. 5,25,89,297/- in respect of provision of marketing support services by the assessee

KAUSHAL INFRAPROJECT INDUSTRIES INDIA LTD.,NEW DELHI vs. DCIT, NEW DELHI

Bench: : Shri Bhavnesh Saini & Dr. B.R.R. Kumar

TDS have been deducted and income have been offered for tax by the Director. Therefore, considering the nature of business of assessee and contribution of Director and following order for A.Y. 2010-2011 in which we have dismissed the departmental appeal, we do not find any justification to interfere with the Order of the Ld. CIT(A) in deleting

DCIT, NEW DELHI vs. M/S. KUSHAL INFRAPROJECT INDUSTRIES INDIA LTD., NEW DELHI

Bench: : Shri Bhavnesh Saini & Dr. B.R.R. Kumar

TDS have been deducted and income have been offered for tax by the Director. Therefore, considering the nature of business of assessee and contribution of Director and following order for A.Y. 2010-2011 in which we have dismissed the departmental appeal, we do not find any justification to interfere with the Order of the Ld. CIT(A) in deleting

DCIT, NEW DELHI vs. M/S. KUSHAL INFRAPROJECT INDUSTRIES INDIA LTD., NEW DELHI

Bench: : Shri Bhavnesh Saini & Dr. B.R.R. Kumar

TDS have been deducted and income have been offered for tax by the Director. Therefore, considering the nature of business of assessee and contribution of Director and following order for A.Y. 2010-2011 in which we have dismissed the departmental appeal, we do not find any justification to interfere with the Order of the Ld. CIT(A) in deleting

KAUSHAL INFRAPROJECT INDUSTRIES INDIA LTD.,NEW DELHI vs. DCIT, NEW DELHI

Bench: : Shri Bhavnesh Saini & Dr. B.R.R. Kumar

TDS have been deducted and income have been offered for tax by the Director. Therefore, considering the nature of business of assessee and contribution of Director and following order for A.Y. 2010-2011 in which we have dismissed the departmental appeal, we do not find any justification to interfere with the Order of the Ld. CIT(A) in deleting

DCIT, LUCKNOW vs. SAHARA INDIA FINANCIAL CORP. LTD.,, LUCKNOW

In the result both the appeals filed by the revenue are dismissed and COs of the assessee are allowed

Bench: Shri H.S.Sidhu & Shri Prashant Maharishi

section 127 of the income tax act by the Commissioner of income tax Lucknow, it is apparent that jurisdiction over TDS has not been transferred to the other specified officers other than ITO (TDS), Lucknow. Further in case of sister concerns also the ITO TDS Ward – 2

DCIT, LUCKNOW vs. SAHARA INDIA FINANCIAL CORP. LTD.,, LUCKNOW

In the result both the appeals filed by the revenue are dismissed and COs of the assessee are allowed

Bench: Shri H.S.Sidhu & Shri Prashant Maharishi

section 127 of the income tax act by the Commissioner of income tax Lucknow, it is apparent that jurisdiction over TDS has not been transferred to the other specified officers other than ITO (TDS), Lucknow. Further in case of sister concerns also the ITO TDS Ward – 2

DCIT, NEW DELHI vs. M/S. NEWBURY HOLDING TWO LTD., NEW DELHI

In the result, the Cross Objections of the assessees are\nallowed and consequently the appeals of the revenue are liable\nto be dismissed

TDS.\n10. It was brought to our notice that the assessee is an\n`eligible assessee' for the purpose of Section 144C(15)(b) of the\nIncome Tax Act, 1961. The said provision reads as under:\n“(15) For the purposes of this section, —\n(a) \"Dispute Resolution Panel\" means a collegium comprising of three\nCommissioners of Income-tax constituted

HERO MOTO CORP LTD.,NEW DELHI vs. NEAC, DELHI

Bench: Shri Kul Bharat & Shri Prashant Maharishi(Through Video Conferencing)

TDS) v. OCM India Ltd. – [2018] 408 ITR 369 (P&H) v. Hindustan Coca Cola Beverages (P.) Ltd. v. CIT: [2018] 402 ITR 539 (Raj. HC) 34. Without prejudice, it is submitted that the appellant was under the bonafide belief that no tax was required to be deducted there from. Reliance in this regard is also placed on the decision