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. 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

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. 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

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.

5) TMI 991 held as under: “10. The short ground on which the aforementioned final assessment orders and the consequent demand notices have been challenged is that there was non-compliance with the mandatory provision contained in Section 144C(1) of the Act requiring the AO to first frame draft assessment orders. 11. The question whether the final assessment order

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.

5) TMI 991 held as under: “10. The short ground on which the aforementioned final assessment orders and the consequent demand notices have been challenged is that there was non-compliance with the mandatory provision contained in Section 144C(1) of the Act requiring the AO to first frame draft assessment orders. 11. The question whether the final assessment order

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.

5) TMI 991 held as under: “10. The short ground on which the aforementioned final assessment orders and the consequent demand notices have been challenged is that there was non-compliance with the mandatory provision contained in Section 144C(1) of the Act requiring the AO to first frame draft assessment orders. 11. The question whether the final assessment order

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. 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. 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

BECHTEL LTD,LONDON vs. ACIT, CIRCLE 1(1)(2), INTERNATIONAL TAXATION, NEW DELHI

In the result, appeal of the assessee is allowed

5. That on the facts and circumstances of the case and in law, the Ld. AO has cred in proposing and the Hon'ble DRP has erred in confirming that the service receipts of the Appellant frown RII, are taxable in India as Fee for Technical Services (FIS) under Section 901(vi) of the Act. 6. That on the facts

BECHTEL LIMITED,LONDON vs. ACIT, CIRCLE INT. TAX 1(1)(2), NEW DELHI

In the result, appeal of the assessee is allowed

5. That on the facts and circumstances of the case and in law, the Ld. AO has cred in proposing and the Hon'ble DRP has erred in confirming that the service receipts of the Appellant frown RII, are taxable in India as Fee for Technical Services (FIS) under Section 901(vi) of the Act. 6. That on the facts

HAKAM FLUID POWER PVT. LTD.,NEW DELHI vs. ITO WARD 11(1), NEW DELHI

In the result, appeal of the assessee is allowed

Bench: Sh. Satbeer Singh Godara (Judicial Member)

5. That on the facts and circumstances of the case and in law, the Ld. AO has cred in proposing and the Hon'ble DRP has erred in confirming that the service receipts of the Appellant frown RII, are taxable in India as Fee for Technical Services (FIS) under Section 901(vi) of the Act. 6. That on the facts

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