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

PARAMINDER SINGH KALRA,NEW DELHI vs. ACIT, NEW DELHI

Bench: Sh. Amit Shukla

1)(a) of the Act. In the present case, assessment case to an end as per the assessment order on 09.03.2015. The Department is relying on clause (viii) of Explanation to Section 153B of the Act to claim extension of the period of limitation by one year without producing evidence of any reference having been made

PARAMINDER SINGH KALRA,NEW DELHI vs. ACIT, NEW DELHI

Bench: Sh. Amit Shukla

1)(a) of the Act. In the present case, assessment case to an end as per the assessment order on 09.03.2015. The Department is relying on clause (viii) of Explanation to Section 153B of the Act to claim extension of the period of limitation by one year without producing evidence of any reference having been made

ACIT, NEW DELHI vs. SH. PARMINDER SINGH KALRA, NEW DELHI

Bench: Sh. Amit Shukla

1)(a) of the Act. In the present case, assessment case to an end as per the assessment order on 09.03.2015. The Department is relying on clause (viii) of Explanation to Section 153B of the Act to claim extension of the period of limitation by one year without producing evidence of any reference having been made

ACIT, NEW DELHI vs. SH. PARMINDER SINGH KALRA, NEW DELHI

Bench: Sh. Amit Shukla

1)(a) of the Act. In the present case, assessment case to an end as per the assessment order on 09.03.2015. The Department is relying on clause (viii) of Explanation to Section 153B of the Act to claim extension of the period of limitation by one year without producing evidence of any reference having been made

ACIT, NEW DELHI vs. SH. PARMINDER SINGH KALRA, NEW DELHI

Bench: Sh. Amit Shukla

1)(a) of the Act. In the present case, assessment case to an end as per the assessment order on 09.03.2015. The Department is relying on clause (viii) of Explanation to Section 153B of the Act to claim extension of the period of limitation by one year without producing evidence of any reference having been made

PARMINDER SINGH KALRA,NEW DELHI vs. ACIT, CENTRAL CIRCLE-14, NEW DELHI

Bench: Sh. Amit Shukla

1)(a) of the Act. In the present case, assessment case to an end as per the assessment order on 09.03.2015. The Department is relying on clause (viii) of Explanation to Section 153B of the Act to claim extension of the period of limitation by one year without producing evidence of any reference having been made

PARMINDER SINGH KALRA,NEW DELHI vs. ACIT, CENTRAL CIRCLE-14, NEW DELHI

Bench: Sh. Amit Shukla

1)(a) of the Act. In the present case, assessment case to an end as per the assessment order on 09.03.2015. The Department is relying on clause (viii) of Explanation to Section 153B of the Act to claim extension of the period of limitation by one year without producing evidence of any reference having been made

ACIT, NEW DELHI vs. SH. PARMINDER SINGH KALRA, NEW DELHI

Bench: Sh. Amit Shukla

1)(a) of the Act. In the present case, assessment case to an end as per the assessment order on 09.03.2015. The Department is relying on clause (viii) of Explanation to Section 153B of the Act to claim extension of the period of limitation by one year without producing evidence of any reference having been made

M/S. MEROFORM (INDIA) PVT. LTD.,UTTAR PRADESH vs. DCIT, NEW DELHI

In the result appeals filed by the revenue are dismissed and appeal filed by the assessee is partly allowed

Bench: Shri Amit Shukla & Shri L.P. Sahu

153B and section 153C, all other provisions of this Act shall apply to the assessment made under this section.' 6.4 Thus, it is clearly implies that the nature of assessment or re- assessment to be made under this section 153A shall be governed by the normal provisions of the Act. In case it is an assessment made for the first

ACIT, NEW DELHI vs. M/S. MEROFORM INDIA PVT LTD., NOIDA

In the result appeals filed by the revenue are dismissed and appeal filed by the assessee is partly allowed

Bench: Shri Amit Shukla & Shri L.P. Sahu

153B and section 153C, all other provisions of this Act shall apply to the assessment made under this section.' 6.4 Thus, it is clearly implies that the nature of assessment or re- assessment to be made under this section 153A shall be governed by the normal provisions of the Act. In case it is an assessment made for the first

ACIT, NEW DELHI vs. M/S. MEROFORM INDIA PVT LTD., NOIDA

In the result appeals filed by the revenue are dismissed and appeal filed by the assessee is partly allowed

Bench: Shri Amit Shukla & Shri L.P. Sahu

153B and section 153C, all other provisions of this Act shall apply to the assessment made under this section.' 6.4 Thus, it is clearly implies that the nature of assessment or re- assessment to be made under this section 153A shall be governed by the normal provisions of the Act. In case it is an assessment made for the first

ACIT, NEW DELHI vs. M/S. MEROFORM INDIA PVT LTD., NOIDA

In the result appeals filed by the revenue are dismissed and appeal filed by the assessee is partly allowed

Bench: Shri Amit Shukla & Shri L.P. Sahu

153B and section 153C, all other provisions of this Act shall apply to the assessment made under this section.' 6.4 Thus, it is clearly implies that the nature of assessment or re- assessment to be made under this section 153A shall be governed by the normal provisions of the Act. In case it is an assessment made for the first

ACIT, NEW DELHI vs. M/S. MEROFORM INDIA PVT LTD., NOIDA

In the result appeals filed by the revenue are dismissed and appeal filed by the assessee is partly allowed

Bench: Shri Amit Shukla & Shri L.P. Sahu

153B and section 153C, all other provisions of this Act shall apply to the assessment made under this section.' 6.4 Thus, it is clearly implies that the nature of assessment or re- assessment to be made under this section 153A shall be governed by the normal provisions of the Act. In case it is an assessment made for the first

ACIT, NEW DELHI vs. M/S. MEROFORM INDIA PVT LTD., NOIDA

In the result appeals filed by the revenue are dismissed and appeal filed by the assessee is partly allowed

Bench: Shri Amit Shukla & Shri L.P. Sahu

153B and section 153C, all other provisions of this Act shall apply to the assessment made under this section.' 6.4 Thus, it is clearly implies that the nature of assessment or re- assessment to be made under this section 153A shall be governed by the normal provisions of the Act. In case it is an assessment made for the first

ACIT, NEW DELHI vs. M/S. MEROFORM INDIA PVT LTD., NOIDA

In the result appeals filed by the revenue are dismissed and appeal filed by the assessee is partly allowed

Bench: Shri Amit Shukla & Shri L.P. Sahu

153B and section 153C, all other provisions of this Act shall apply to the assessment made under this section.' 6.4 Thus, it is clearly implies that the nature of assessment or re- assessment to be made under this section 153A shall be governed by the normal provisions of the Act. In case it is an assessment made for the first

ASHOK GUPTA,FARIDABAD vs. DCIT, FARIDABAD

The appeal of the assessee is allowed

Bench: Shri N. K. Saini & Ms Suchitra Kambleashok Gupta Vs Dcit House No. 114, Sector-15 Central Circle-1 Faridabad Faridabad Aahpg3179R (Appellant) (Respondent)

153B (1) (b) of the I.T. Act on 27/12/2010. After hearing the assessee, the income returned at Rs.59,50,860/- was accepted. During the course of search operation, the assessee made a surrendered of Rs.50,00,000/- which was incorporated by the assessee in his return of income under the head income from other sources. In the course of search

AMIT KATYAL,NEW DELHI vs. DCIT, CENTRAL CIRCLE- 1, GURGAON

In the result, the appeal of the assessee is allowed

Bench: Shri C. N. Prasad & Shri M. Balaganeshamit Katyal, Vs. Dcit, C-654, New Friends Central Circle-1, Colony, New Delhi Gurgaon (Appellant) (Respondent) Pan:Aaepk4669H Assessee By : Shri V. K. Bindal, Ca Ms. Rinki Sharma, Itp Revenue By: Shri Safarul Haque Tanweer, Cit Dr Date Of Hearing 10/01/2024 Date Of Pronouncement 08/04/2024

b) of the Income- tax Act, 1961 (hereinafter referred to as „the Act‟) dated 24.03.2014 by the Assessing Officer, DCIT, Central Circle-1, Faridabad (hereinafter referred to as „ld. AO‟). 2. The assessee has raised the following grounds of appeal:- “1. The learned CIT(A) erred in law and on facts in confirming the addition

GAUTAM CHOPRA,NEW DELHI vs. DCIT, JHANDEWALLAN EXTENSION

In the result, appeal of the assessee is allowed

B. However, and in cases where on facts it is\nfound that the material gathered is unlikely to have any impact on the\ncomputation of total income for a particular year, there would exist no\njustification to invoke the powers conferred by Section 153C.\n60. Before concluding, we also deem it imperative to briefly notice\ncertain aspects which emerge from