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594 results for “TDS”+ Section 144C(6)(C)clear

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Key Topics

Section 143(3)94Double Taxation/DTAA51Section 144C30Addition to Income27Section 271(1)(c)22Penalty22Section 144C(13)21Section 9(1)(vi)21Section 144C(1)20Permanent Establishment

DCIT, NEW DELHI vs. M/S WICKWOOD DEVELOPMENT 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

ITA 3357/DEL/2015[2009-10]Status: DisposedITAT Delhi10 Jan 2024AY 2009-10
Section 153C

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. 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

ITA 3128/DEL/2015[2010-11]Status: DisposedITAT Delhi10 Jan 2024AY 2010-11
Section 153C

Showing 1–20 of 594 · Page 1 of 30

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TDS17
Section 234B14

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. 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

ITA 4652/DEL/2015[2010-11]Status: DisposedITAT Delhi11 Jan 2024AY 2010-11

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

ITA 4651/DEL/2015[2009-10]Status: DisposedITAT Delhi11 Jan 2024AY 2009-10

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

ITA 4653/DEL/2015[2011-12]Status: DisposedITAT Delhi11 Jan 2024AY 2011-12

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

ITA 4650/DEL/2015[2008-09]Status: DisposedITAT Delhi11 Jan 2024AY 2008-09

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

ITA 3356/DEL/2015[2008-09]Status: DisposedITAT Delhi10 Jan 2024AY 2008-09

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

ITA 5396/DEL/2015[2011-12]Status: DisposedITAT Delhi10 Jan 2024AY 2011-12

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. GAINWAY HOLDINGS LTD., NEW DELHI

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

ITA 4007/DEL/2015[2009-10]Status: DisposedITAT Delhi19 Sept 2025AY 2009-10

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

Section 132Section 153CSection 6(3)(ii)Section 9(1)

6 of the Revenue. 16. We have heard both the parties and perused the material available on the record. The assessee is a foreign company and the 10 ITA No. 4007 & C. O. No. 390/Del/2015 DCIT Vs. Gainway Holdings Ltd. Assessee herein is an ‘eligible assessee’ in terms of section 144C(15)(b) of the Act. As per the provisions

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

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

ITA 5335/DEL/2015[2008-09]Status: DisposedITAT Delhi19 Sept 2025AY 2008-09

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

Section 124(4)Section 132Section 144CSection 147Section 148Section 151Section 6(3)(ii)

TDS). CO Nos. 349 & 350/Del/2015 DCIT Vs. Newbury Holding Ltd. 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

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

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

ITA 5334/DEL/2015[2007-08]Status: DisposedITAT Delhi19 Sept 2025AY 2007-08

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

Section 124(4)Section 132Section 144CSection 147Section 148Section 151Section 6(3)(ii)

TDS). CO Nos. 349 & 350/Del/2015 DCIT Vs. Newbury Holding Ltd. 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

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

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

ITA 5333/DEL/2015[2011-12]Status: DisposedITAT Delhi19 Sept 2025AY 2011-12

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

Section 124(4)Section 132Section 144CSection 147Section 148Section 151Section 6(3)(ii)

TDS). CO Nos. 473 & 474/Del/2015 DCIT Vs. EICR (Cyprus) Ltd. 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

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

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

ITA 3911/DEL/2015[2009-10]Status: DisposedITAT Delhi19 Sept 2025AY 2009-10

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

Section 132Section 153CSection 6(3)(ii)Section 9(1)

6 of the Revenue. 16. We have heard both the parties and perused the material available on the record. The assessee is a foreign company and the Assessee herein is an ‘eligible assessee’ in terms of section 144C(15)(b) of the Act. As per the provisions of section 144C(1) of the Act, the Assessing Officer is mandatorily required

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

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

ITA 3916/DEL/2015[2011-12]Status: DisposedITAT Delhi19 Sept 2025AY 2011-12

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

Section 132Section 153CSection 6(3)Section 6(3)(ii)Section 9(1)

6 of the Revenue. 15. We have heard both the parties and perused the material available on the record. The assessee is a foreign company and the Assessee herein is an ‘eligible assessee’ in terms of section 144C(15)(b) of the Act. As per the provisions of section 144C(1) of the Act, the Assessing Officer is mandatorily required

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

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

ITA 3914/DEL/2015[2009-10]Status: DisposedITAT Delhi19 Sept 2025AY 2009-10

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

Section 132Section 153CSection 6(3)Section 6(3)(ii)Section 9(1)

6 of the Revenue. 15. We have heard both the parties and perused the material available on the record. The assessee is a foreign company and the Assessee herein is an ‘eligible assessee’ in terms of section 144C(15)(b) of the Act. As per the provisions of section 144C(1) of the Act, the Assessing Officer is mandatorily required

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

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

ITA 3915/DEL/2015[2010-11]Status: DisposedITAT Delhi19 Sept 2025AY 2010-11

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

Section 132Section 153CSection 6(3)Section 6(3)(ii)Section 9(1)

6 of the Revenue. 15. We have heard both the parties and perused the material available on the record. The assessee is a foreign company and the Assessee herein is an ‘eligible assessee’ in terms of section 144C(15)(b) of the Act. As per the provisions of section 144C(1) of the Act, the Assessing Officer is mandatorily required

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

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

ITA 4055/DEL/2015[2010-11]Status: DisposedITAT Delhi19 Sept 2025AY 2010-11

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

Section 132Section 153Section 153CSection 6(3)(ii)Section 9(1)

6 of the Revenue. 15. We have heard both the parties and perused the material available on the record. The assessee is a foreign company and the Assessee herein is an ‘eligible assessee’ in terms of section 144C(15)(b) of the Act. As per the provisions of section 144C(1) of the Act, the Assessing Officer is mandatorily required

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

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

ITA 4056/DEL/2015[2011-12]Status: DisposedITAT Delhi19 Sept 2025AY 2011-12
Section 132Section 153Section 153CSection 9(1)

6 of the Revenue.\n\n15. We have heard both the parties and perused the material\navailable on the record. The assessee is a foreign company and the\nAssessee herein is an ‘eligible assessee' in terms of section 144C(15)(b)\nof the Act. As per the provisions of section 144C(1) of the Act, the\nAssessing Officer is mandatorily

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

ITA 5332/DEL/2015[2010-11]Status: DisposedITAT Delhi19 Sept 2025AY 2010-11
Section 124(4)Section 132Section 144CSection 147Section 148Section 151

TDS).\n3.3 Pursuant to the notice issued under Section 153C of the Act,\nthe assessments were completed. It is the Assessee's case that it is\nan “eligible assessee” and the procedure as prescribed under the\nAct was not followed. In as much as, the draft assessment order\nwas 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

ITA 6503/DEL/2019[2011-12]Status: DisposedITAT Delhi09 Feb 2023AY 2011-12

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

For Appellant: Shri Ravi Sharma, AdvFor Respondent: Shri Jitender Kumar – CIT-DR
Section 144Section 144C(13)Section 147Section 148Section 234ASection 234C

C (Applicant) (Respondent) Assessee By : Shri Ravi Sharma, Adv Shri Rishab Malhotra, AR Department By : Shri Jitender Kumar – CIT-DR Date of Hearing : 06.02.2023 Date of Pronouncement : 09.02.2023 ORDER PER N.K. BILLAIYA, ACCOUNTANT MEMBER:- This appeal by the assessee is preferred against the order dated 21.06.2019 framed u/s 144C(13) r.w.s 147 r.w.s 143(3) of the Income