JONES LANG LASALLE PROPERTY CONSULTANTS (INDIA) PRIVATE LIMITED,DELHI, INDIA vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 13(1), DELHI, INDIA

In the result, the appeal of the assessee is allowed and the Stay

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarassessment Year: 2020-21 & Stay Application No.61/Del/2025 ( In Ita No. 3964/Del/2024 ) Assessment Year: 2020-21

144B of the Act is time barred having been passed beyond the time limit prescribed under section 144C(13) for completion of assessment. 4. In the alternative to ground no. 3, directions issued by Ld. DRP under section 144C(5) have been issued beyond time limit prescribed under section 144C(12). 5. Without prejudice to the above, assessment proceedings which

CBRE SOUTH ASIA PRIVATE LIMITED,DELHI vs. ADDITIONAL, JOINT, DEPUTY, ASSISTANT COMMISSIONER OF INCOME TAX, NATIONAL FACELESS ASSESSMENT CENTRE, DELHI

In the result, the appeal filed by assessee is allowed

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarassessment Year: 2019-20 Cbre South Asia Pvt. Ltd., Vs. Additional, Joint, Deputy, Assistant Pti Building, 4, Ground Floor, Commissioner Of Income Tax, Parliament Street Central Delhi, National Faceless Assessment Centre, Parliament House, New Delhi Delhi Pin: 1100 01 Pan :Aaacc9308A (Appellant) (Respondent)

144B of the Act for assessment Year 2019-20. 2 2. Brief facts of case are that assessee filed original income tax return on 30.11.2019 declaring total income of Rs.202,42,24,480/- and later on revised return under Section 139(5) of the Act, declaring income of Rs.1,99,74,55,920/- on 29.09.2020. The case was selected

RAIL VIKAS NIGAM LIMITED,NEW DELHI vs. COMMISSIONER OF INCOME TAX (APPEALS), DELHI

In the result, the appeal filed by the assessee is allowed

Bench: SHRI S.RIFAUR RAHMAN (Accountant Member), SHRI SUDHIR KUMAR (Judicial Member)

Section 144B of the IT Act mandatorily provides for the issuance of a show cause notice and draft assessment order by the National Faceless Assessment Centre before issuing a final assessment order. 9. The Appellant craves leave to add to and/or amend and/or delete and/or modify and/or alter the aforesaid grounds of appeal as and when the occasion demands

HANSRAJ ,REWARI vs. ITO WARD 1(4), GURGAON

In the result, appeal of the assessee is partly allowed

Bench: Shri Challa Nagendra Prasad & Shri Brajesh Kumar Singh, Ita No:- 4978/Del/2025 (Assessment Year- 2014-15) Hansraj, Income Tax Officer, C-75, Ground Floor, Ward-1(4), M2K County, Dharuhera Vs Gurugram, Rewari, Haryana-123106. Haryana-122001. Pan- Aazph7436E Assessee Revenue

Section 147 r.w.s. 144B of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) pertaining to Assessment Year (A.Y.) 2014- 15. 2. Brief facts of the case : In this case, the assessee had not filed his return of income required u/s 139(1) for the assessment year 2014-15. 2.1 As per the information available with the Department

MUKUL ROHATGI,NEW DELHI vs. ACIT CIRCLE 61(1), NEW DELHI

In the result, the appeal of the assessee is allowed

Bench: Shri Mahavir Singh & Shri Manish Agarwal

144B of the Act, whereby, the Assessing Officer assessed the assessee at an income of ₹133,46,92,080/- after making addition of *44,77,708/- on account of disallowance under Section 24(b) of the Act and also disallowed a sum of ₹40,10,848/- under Section 14A read with Rule 8D of the Income-tax Rules, 1962 (hereinafter

BHARTIYA INTERNATIONAL LTD,NEW DELHI vs. DCIT,CIRCLE-4(2), NEW DELHI

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

Bench: Shri Saktijit Dey & Shri Pradip Kumar Kedia

144B r.w. Section 144C(13) passed in pursuance of directions issued by Dispute Resolution Panel (DRP) dated 02.06.2022 read with rectification order dated 28.06.2022 passed by DRP under Rule 13 of the Dispute Resolution Panel Rules, 2009. 2. The concise Grounds of Appeal filed by the assessee are reproduced hereunder for adjudication purposes: I.T.A. No.2109/Del/2022 2 “1. On the facts

LINKEDIN TECHNOLOGY INFORMATION PRIVATE LIMITED,DELHI vs. PRINCIPAL COMMISSIONER OF INCOME-TAX, DELHI -4 , DELHI

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

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

144B of the Act, itself is bad in law and void ab initio. Therefore, the consequent revisionary proceedings and the impugned Order passed by the Pr. CIT under section 263 of the Act to revise such a non-est reassessment order is also bad in law and without jurisdiction. The Appellant prays that the impugned Order, passed under section

VENETIAN LDF PROJECTS LLP,GURGAON vs. ACIT CIRCLE-4(1), GURGAON

In the result, grounds raised by the assessee are dismissed

Bench: Shri S. Rifaur Rahman & Shri Vimal Kumar

144B of the Act, on the alleged ground that the AO had erroneously failed to examine the following six (6) issues: (i) Related party transactions; (ii) Genuineness of platform selling expenses; (iii) Provision for doubtful advances; (iv) Provision for slow and ageing goods; (v) Various items in Balance Sheet and Audit Report; and (vi) Genuineness of advertisement expenses

INTER GLOBLE AVIATION LTD,DELHI vs. ACIT CIRCLE-10(1) ,, NEW DELHI

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

Bench: Sh. Anil Chaturvedi & Sh. Narender Kumar Choudhryinter Globle Aviation Ltd. Vs. Acit Upper Ground Floor, Circle – 10(1) Westren Wing, Thapper New Delhi House-124, Janpath, New Delhi-110001 Pan No. Aabci 2726 B (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. Ms. Soumya Jain, Adv. Revenue By Shri Anuj Garg, Sr. D.R. Date Of Hearing: 22.02.2023 Date Of Pronouncement: 22.03.2023 Order Per Anil Chaturvedi, Am: This Appeal Filed By The Assessee Is Directed Against The Order Dated 14.09.2022 Passed By The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac) - Delhi Relating To Assessment Year 2018-19. 2. Brief Facts Of The Case As Culled Out From The Material On Record Are As Under :- Inter Globle Aviation Ltd Vs Acit 2 3. Assessee Is A Company Stated To Be Engaged In The Business Of Operation Of Airlines Under The Name & Style Of Indigo. Assessee Electronically Filed Its Return Of Income For A.Y. 2018-19 On 30.11.2018 Declaring Total Income Of Rs.18,26,11,80,910/-. The Case Was Selected For Scrutiny & Thereafter Assessment Was Framed U/S 143(3) R.W.S 144B Of The Act Vide Order Dated 19.04.2021 & The Total Income Was Determined At Rs.24,31,89,53,536/-.

section 144B of the Act and also principles of natural justice. 2.3 That the CIT(A) erred in not appreciating that the assessing officer made huge additions/ disallowances without judiciously appreciating/ considering the legal and factual Inter Globle Aviation Ltd vs ACIT 4 contentions of the appellant and therefore, the assessment order is illegal and bad in law. Re: Incentive

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

BRAHAM SINGH,DELHI vs. ASSESSMENT UNIT, INCOME TAX DEPARTMENT , DELHI

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

Bench: Shri Pradip Kumar Kedia & Shri Vimal Kumarita No. 4757/Del/2024 Assessment Year: 2014-15 Ita No.4756/Del/2024 Assessment Year: 2016-17 Braham Singh, Vs Assessment Unit, House N0.57, Dhansa . Income Tax Department Raota, South West Delhi Delhi Pin: 1100 73 Delhi. Pan: Fhmps9910M (Appellant) (Respondent)

TDS form 26QB, section 194IA) amounting to Rs.4,98,66,600/- which was not disclosed in ITR as ITR for the assessment year 2014-15 was not filed. The case was reopened vide order under Section 148A sub-section (d) of section 148A of the Act dated 22.07.2022. Notice under Section 148 was served upon the assessee

BRAHAM SINGH,DELHI vs. ASSESSMENT UNIT, INCOME TAX DEPARTMENT, DELHI

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

Bench: Shri Pradip Kumar Kedia & Shri Vimal Kumarita No. 4757/Del/2024 Assessment Year: 2014-15 Ita No.4756/Del/2024 Assessment Year: 2016-17 Braham Singh, Vs Assessment Unit, House N0.57, Dhansa . Income Tax Department Raota, South West Delhi Delhi Pin: 1100 73 Delhi. Pan: Fhmps9910M (Appellant) (Respondent)

TDS form 26QB, section 194IA) amounting to Rs.4,98,66,600/- which was not disclosed in ITR as ITR for the assessment year 2014-15 was not filed. The case was reopened vide order under Section 148A sub-section (d) of section 148A of the Act dated 22.07.2022. Notice under Section 148 was served upon the assessee

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

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

144B of the Income Tax Act, 1961 (the Act) passed on 30th April, 2021. The assessee has raised the following grounds of appeal:- “1. That the assessing officer erred on facts and in law in completing assessment under section 143(3) read with section 144C of the Income-tax Act, 1961 ('the Act'), vide order dated 30.04.2021, at an income

SUMITOMO CORPORATION INDIA PVT LTD,DELHI vs. DCIT,CIRCLE-22(2), DELHI

In the result, the appeals of the assessee are partly allowed as indicated above and the stay application is dismissed as infructuous

Bench: Shri C.N. Prasad & Shri M. Balaganesh, Accontant Member Assessment Year 2020-21 Sumitomo Corporation India Vs. Dcit Pvt. Ltd. Circle -22 (2) 501 & 502, 5Th Floor West Wing, World Mark 1, Asset No.11, Hospitality District Aerocity, New Delhi-110037 Pan No.Aabcs1887M Appellant Respondent It(Tp) Appeal No.14/Del/2025 Assessment Year 2021-22 Sumitomo Corporation India Vs. Dcit Pvt. Ltd. Circle -22 (2) 501 & 502, 5Th Floor Delhi West Wing, World Mark 1, Asset No.11, Hospitality District Aerocity, New Delhi-110037 Pan No.Aabcs1887M Appellant Respondent

144B of the Act as against the income of INR 25,27,45,360/-per the modified return of income filed by the Appellant. In doing so, the Ld. AO has erred in making an adjustment of INR 2,21,26,058/- which comprises of the Transactional Net Margin Method ('TNMM') based adjustment amounting

MAHASHIAN DI HATTI (P) LTD,NEW DELHI vs. PCIT-4, NEW DELHI

Bench: Shri M. Balaganesh & Sh. Yogesh Kumar U.S.

144B of the Act at assessed income of Rs. 6,20,42,83,460/-. 3. On perusal of your balance sheet of column 5A & 5B, it has been observed that there have been sharp increase of Rs.14,49,91,615/- under the sub-head "Advance for properties" and Rs.42,85,51,442/- under sub-head "Advance to suppliers". During

INTERGLOBE TECHNOLOGY QUOTIENT PRIVATE LIMITED,NEW DELHI vs. ASSISTANT COMMISSIONER CIRCLE 10(1), NEW DELHI

Bench: Shri M. Balaganesh & Shri Anubhav Sharma[Assessment Year: 2020-21

144B, assessing income of the appellant at Rs.24,91,76,860, after making two disallowances. 2.1 The first disallowance was with regard denial of deduction claimed under section 80G of the Act 2.2 The second disallowance related to not allowing credit of TDS

DEPUTY COMMISSIONER OF INCOME TAX, NEW DELHI vs. ODIA SAMAJ, NEW DELHI

In the result Cross objections raised by assessee is allowed

Bench: Ms. Madhumita Roy & Shri Naveen Chandra

144B of the Income-Tax Act, 1961 (hereinafter referred to as "the Act") passed by the Assessment Unit, Income Tax Department, for AY – 2020-21. Both the appeals are heard analogously and are being disposed of by this common order. 2 The cross objections filed by assessee is time barred by 27 days. The learned AR during the course

INCOME TAX OFFICER, GURGAON vs. DISCOVERI MEDIA GROUP, GURGAON

In the result, appeal of the Revenue is dismissed whereas the appeal of the assessee is partly allowed

Bench: Shri Pradip Kumar Kedia & Shri Yogesh Kumar Us[Assessment Year : 2014-15] Ito, Vs Discoveri Media Group, Gurgaon. 97B, Udyog Vihar, Phase-V, Gurgaon-122002. Pan-Aaifd8766G Appellant Respondent [Assessment Year : 2014-15] Discoveri Media Group Vs Ito, C/O-S.L.Poddar & Co., Ward-1(4), Gokul Apartment, E-3A, Kantichandra Gurugram. Road, Bani Park, Jaipur, Rajasthan-302016. Pan-Aaifd8766G Appellant Respondent [Assessment Year : 2015-16] Ito, Vs Discoveri Media Group, Gurgaon. 97B, Udyog Vihar, Phase-V, Gurgaon-122002. Pan-Aaifd8766G Appellant Respondent [Assessment Year : 2015-16] Discoveri Media Group, Vs Ito, 97B, Udyog Vihar, Phase-V, Ward-1(4), Gurgaon-122002. Gurugram. Pan-Aaifd8766G Appellant Respondent

144B of the Act. Based on TDS deductions and other information received and in the absence of any cogent explanation offered on behalf of the assessee, gross receipts in the hands of the assessee under the various heads were adopted as taxable income and assessed accordingly. 5. Aggrieved, the assessee preferred appeal before Ld.CIT(A). It was contended before Ld.CIT

INCOME TAX OFFICER, GURGAON vs. DISCOVERI MEDIA GROUP, GURGAON

In the result, appeal of the Revenue is dismissed whereas the appeal of the assessee is partly allowed

Bench: Shri Pradip Kumar Kedia & Shri Yogesh Kumar Us[Assessment Year : 2014-15] Ito, Vs Discoveri Media Group, Gurgaon. 97B, Udyog Vihar, Phase-V, Gurgaon-122002. Pan-Aaifd8766G Appellant Respondent [Assessment Year : 2014-15] Discoveri Media Group Vs Ito, C/O-S.L.Poddar & Co., Ward-1(4), Gokul Apartment, E-3A, Kantichandra Gurugram. Road, Bani Park, Jaipur, Rajasthan-302016. Pan-Aaifd8766G Appellant Respondent [Assessment Year : 2015-16] Ito, Vs Discoveri Media Group, Gurgaon. 97B, Udyog Vihar, Phase-V, Gurgaon-122002. Pan-Aaifd8766G Appellant Respondent [Assessment Year : 2015-16] Discoveri Media Group, Vs Ito, 97B, Udyog Vihar, Phase-V, Ward-1(4), Gurgaon-122002. Gurugram. Pan-Aaifd8766G Appellant Respondent

144B of the Act. Based on TDS deductions and other information received and in the absence of any cogent explanation offered on behalf of the assessee, gross receipts in the hands of the assessee under the various heads were adopted as taxable income and assessed accordingly. 5. Aggrieved, the assessee preferred appeal before Ld.CIT(A). It was contended before Ld.CIT