DCIT, NEW DELHI vs. I ENERGIZER HOLDINGS LTD., NEW DELHI

In the result, the Cross Objections of the assessees are allowed and consequently the appeals of the revenue are liable to be dismissed

Bench: Sh. Saktijit Deydr. B. R. R. Kumar

TDS. 10. It was brought to our notice that the assessee is an ‘eligible assessee’ for the purpose of Section 144C(15)(b) of the Income Tax Act, 1961. The said provision reads as under: “(15) For the purposes of this section,— (a) "Dispute Resolution Panel" means a collegium comprising of three Commissioners of Income-tax constituted by the Board

DCIT, NEW DELHI vs. I ENERGIZER HOLDINGS LTD., NEW DELHI

In the result, the Cross Objections of the assessees are allowed and consequently the appeals of the revenue are liable to be dismissed

Bench: Sh. Saktijit Deydr. B. R. R. Kumar

TDS. 10. It was brought to our notice that the assessee is an ‘eligible assessee’ for the purpose of Section 144C(15)(b) of the Income Tax Act, 1961. The said provision reads as under: “(15) For the purposes of this section,— (a) "Dispute Resolution Panel" means a collegium comprising of three Commissioners of Income-tax constituted by the Board

DCIT, NEW DELHI vs. I ENERGIZER HOLDINGS LTD., NEW DELHI

In the result, the Cross Objections of the assessees are allowed and consequently the appeals of the revenue are liable to be dismissed

Bench: Sh. Saktijit Deydr. B. R. R. Kumar

TDS. 10. It was brought to our notice that the assessee is an ‘eligible assessee’ for the purpose of Section 144C(15)(b) of the Income Tax Act, 1961. The said provision reads as under: “(15) For the purposes of this section,— (a) "Dispute Resolution Panel" means a collegium comprising of three Commissioners of Income-tax constituted by the Board

DCIT, NEW DELHI vs. I ENERGIZER HOLDINGS LTD., NEW DELHI

In the result, the Cross Objections of the assessees are allowed and consequently the appeals of the revenue are liable to be dismissed

Bench: Sh. Saktijit Deydr. B. R. R. Kumar

TDS. 10. It was brought to our notice that the assessee is an ‘eligible assessee’ for the purpose of Section 144C(15)(b) of the Income Tax Act, 1961. The said provision reads as under: “(15) For the purposes of this section,— (a) "Dispute Resolution Panel" means a collegium comprising of three Commissioners of Income-tax constituted by the Board

DCIT, NEW DELHI vs. ISERVICES INVESTMENTS LTD., NEW DELHI

In the result, the Cross Objections of the assessees are allowed and consequently the appeals of the revenue are liable to be dismissed

Bench: Sh. Saktijit Deydr. B. R. R. Kumar

TDS. 10. It was brought to our notice that the assessee is an ‘eligible assessee’ for the purpose of Section 144C(15)(b) of the Income Tax Act, 1961. The said provision reads as under: “(15) For the purposes of this section,— (a) "Dispute Resolution Panel" means a collegium comprising of three Commissioners of Income-tax constituted by the Board

DCIT, NEW DELHI vs. M/S WICKWOOD DEVELOPMENT LTD.,, NEW DELHI

In the result, the Cross Objections of the assessees are allowed and consequently the appeals of the revenue are liable to be dismissed

Bench: Sh. Saktijit Deydr. B. R. R. Kumar

TDS. 10. It was brought to our notice that the assessee is an ‘eligible assessee’ for the purpose of Section 144C(15)(b) of the Income Tax Act, 1961. The said provision reads as under: “(15) For the purposes of this section,— (a) "Dispute Resolution Panel" means a collegium comprising of three Commissioners of Income-tax constituted by the Board

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

2 and 3 that though the assessment order passed by the ld AO pursuant to the directions of the ld Dispute Resolution Panel (DRP) is barred by limitation. We deem it fit to address this preliminary ground as it goes to the root of the matter. 3. We have heard the rival submissions and perused the material available on record

DCIT, NEW DELHI vs. NEWBURY HOLDING LTD., NEW DELHI

In the result, the appeals of the Revenue in ITA Nos

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

2. The Revenue has projected the following questions of law in the present appeals: “2.1 Whether on the facts and in the circumstances of the case, the Ld. ITAT has erred in law in holding that assessment orders passed are unsustainable for not passing the draft assessment order as per the provisions of Section 144C(1) of the Act which

DCIT, NEW DELHI vs. NEWBURY HOLDING LTD., NEW DELHI

In the result, the appeals of the Revenue in ITA Nos

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

2. The Revenue has projected the following questions of law in the present appeals: “2.1 Whether on the facts and in the circumstances of the case, the Ld. ITAT has erred in law in holding that assessment orders passed are unsustainable for not passing the draft assessment order as per the provisions of Section 144C(1) of the Act which

DCIT, NEW DELHI vs. EICR (CYPRUS) LTD., NEW DELHI

In the result, the appeals of the Revenue in ITA Nos

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

2. The Revenue has projected the following questions of law in the present appeals: “2.1 Whether on the facts and in the circumstances of the case, the Ld. ITAT has erred in law in holding that assessment orders passed are unsustainable for not passing the draft assessment order as per the provisions of Section 144C(1) of the Act which

DCIT, NEW DELHI vs. GAINWAY HOLDINGS LTD., NEW DELHI

In the result, the appeal of the Revenue in ITA No

Bench: S. Rifaur Rahman & Shri Yogesh Kumar U.S.Dcit Gainway Holdings Ltd. Vs Central Circle-19, Room C/O. Sandeep Chilana, Advocate No. 362, Ara Centre, E-2, Chilana & Chilana Law Offices, Jhandewalan Extension, Advoate For The Respondent C- New Delhi 56, Lfg, Jangpura Extention, New Delhi-110014 Pan: Aafcg6056L Appellant Respondent

TDS). 3.3 Pursuant to the notice issued under Section 153C of the Act, the assessments were completed. It is the Assessee’s case that it is an “eligible assessee” and the procedure as prescribed under the Act was not followed. In as much as, the draft assessment order was not issued as required under Section 144C

DCIT, NEW DELHI vs. FOCUSOIL INC., NEW DELHI

In the result, the appeal of the Revenue in ITA No

Bench: S. Rifaur Rahman & Shri Yogesh Kumar U.S.Dcit Vs Focusoil Inc. Central Circle-19, Room C/O. Sandeep Chilana, Advocate No. 362, Ara Centre, E-2, Chilana & Chilana Law Offices, Jhandewalan Extension, Advoate For The Respondent C- New Delhi 56, Lfg, Jangpura Extention, New Delhi-110014 Pan: Aaccf3908K Appellant Respondent

TDS). 3.3 Pursuant to the notice issued under Section 153C of the Act, the assessments were completed. It is the Assessee’s case that it is an “eligible assessee” and the procedure as prescribed under the Act was not followed. In as much as, the draft assessment order was not issued as required under Section 144C

DCIT, NEW DELHI vs. GYNIA HOLDING LTD., NEW DELHI

In the result, the appeals of the Revenue in ITA Nos

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

TDS). 3.3 Pursuant to the notice issued under Section 153C of the Act, the assessments were completed. It is the Assessee’s case that it is an “eligible assessee” and the procedure as prescribed under the Act was not followed. In as much as, the draft assessment order was not issued as required under Section 144C

DCIT, NEW DELHI vs. GYNIA HOLDING LTD., NEW DELHI

In the result, the appeals of the Revenue in ITA Nos

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

TDS). 3.3 Pursuant to the notice issued under Section 153C of the Act, the assessments were completed. It is the Assessee’s case that it is an “eligible assessee” and the procedure as prescribed under the Act was not followed. In as much as, the draft assessment order was not issued as required under Section 144C

DCIT, NEW DELHI vs. GYNIA HOLDING LTD., NEW DELHI

In the result, the appeals of the Revenue in ITA Nos

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

TDS). 3.3 Pursuant to the notice issued under Section 153C of the Act, the assessments were completed. It is the Assessee’s case that it is an “eligible assessee” and the procedure as prescribed under the Act was not followed. In as much as, the draft assessment order was not issued as required under Section 144C

DCIT, NEW DELHI vs. BENNETT WILLIAMSON ENGINEERS LTD., NEW DELHI

In the result, the appeals of the Revenue in ITA Nos

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

TDS). 3.3 Pursuant to the notice issued under Section 153C of the Act, the assessments were completed. It is the Assessee’s case that it is an “eligible assessee” and the procedure as prescribed under the Act was not followed. In as much as, the draft assessment order was not issued as required under Section 144C

TRAVELPORT LP,GEORGIA USA vs. DCIT, INTERNATIONAL TAXATION CIRCLE-3(1)(1), NEW DELHI

In the result, the appeal of the assessee in ITA No

Bench: Shri N.K. Billaiya & Shri Anubhav Sharma

144C(13) r.w.s 147 r.w.s 143(3) of the Income- tax Act, 1961 [hereinafter referred to as 'The Act'] pertaining to Assessment Year 2011-12. 2. The grievances of the assessee read as under: “1. That on the facts and circumstances of the case & in law, the order dated June 21, 2019 framed under Section 1440(13) read with Sections

DCIT, NEW DELHI vs. BENNETT WILLIAMSON ENGINEERS LTD., NEW DELHI

In the result, the appeals of the Revenue in ITA Nos

2 to 6 of Revenue's appeals.\n\n14. Per contra, the Ld. AR submitted that the Assessee is a foreign\ncompany and is an “eligible assessee” within the meaning of section\n144C(15)(b) of the Act, therefore, as per section 144C(1) of the Act, it is\nmandatory for the AO to pass draft assessment orders