ADIT(E), NEW DELHI vs. M/S. IILM FOUNDATION, NEW DELHI

In the result, the appeal of the assessee is partly allowed and appeals of the Revenue are dismissed

Bench: Shri G.S. Pannu & Shri Amit Shukla(Through Video Conferencing) Assessment Year: 2007-08

TDS Aarti Rai 29,750/- Dr. 6. From the above details, Assessing Officer inferred that these payments are in violation of Section 13(1)(c) read with section 13(3) and on these account the assessee is liable to lose its exemption. He further noted the name of these two persons does not appear as employee of the Banyan Tree

ADIT (E), NEW DELHI vs. IILM FOUNDATION, NEW DELHI

In the result, the appeal of the assessee is partly allowed and appeals of the Revenue are dismissed

Bench: Shri G.S. Pannu & Shri Amit Shukla(Through Video Conferencing) Assessment Year: 2007-08

TDS Aarti Rai 29,750/- Dr. 6. From the above details, Assessing Officer inferred that these payments are in violation of Section 13(1)(c) read with section 13(3) and on these account the assessee is liable to lose its exemption. He further noted the name of these two persons does not appear as employee of the Banyan Tree

IILM FOUNDAION,NEW DELHI vs. ADIT (EXEMPTION), NEW DELHI

In the result, the appeal of the assessee is partly allowed and appeals of the Revenue are dismissed

Bench: Shri G.S. Pannu & Shri Amit Shukla(Through Video Conferencing) Assessment Year: 2007-08

TDS Aarti Rai 29,750/- Dr. 6. From the above details, Assessing Officer inferred that these payments are in violation of Section 13(1)(c) read with section 13(3) and on these account the assessee is liable to lose its exemption. He further noted the name of these two persons does not appear as employee of the Banyan Tree

ADIT(E), NEW DELHI vs. M/S. IILM FOUNDATION, NEW DELHI

In the result, the appeal of the assessee is partly allowed and appeals of the Revenue are dismissed

Bench: Shri G.S. Pannu & Shri Amit Shukla(Through Video Conferencing) Assessment Year: 2007-08

TDS Aarti Rai 29,750/- Dr. 6. From the above details, Assessing Officer inferred that these payments are in violation of Section 13(1)(c) read with section 13(3) and on these account the assessee is liable to lose its exemption. He further noted the name of these two persons does not appear as employee of the Banyan Tree

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

164 to 168 of paper certain related parties (@pt 2, 3, 6 of notice) as book) stated below: “2. Please provide the copy of contract with Amazon Smart Commerce Solution Pvt Ltd (ASCSPL) for administrative support services and legal and professional services. Please explain when you yourselves are running such huge business setup in India what specialized and unique administrative

ACE MEGA STRUCTURES PRIVATE LIMITED,UTTAR PRADESH vs. DCIT/ACIT CEN CIR, NOIDA, NOIDA

In the result, appeal of the assessee is allowed

Bench: Shri Anubhav Sharma & Shri Manish Agarwalsl. Ita No(S) Asst. Appeal(S) By No Year(S) Appellant Vs. Respondent Appellant Respondent 1. 4067/Del/2025 2019-20 M/S. Ace Mega Dcit/Acit Structures Pvt. Ltd., Central Circle I-B, 7Th Floor, Ace Studio, Noida Sector-126, Noida, Sector- 37, S.O. Gautam Budh Nagar-201303 Pan-Aakca8694D M/S. Ace Mega 2. 4115/Del/2025 2019-20 Dcit, Structures Pvt. Ltd. Central Circle-1, A.R.T.O Complex, Sector-33, I-B, 7Th Floor, Ace Studio, Noida-201301. Sector-126, Noida, Sector- 37, S.O. Gautam Budh Nagar-201303 Pan-Aakca8694D Appellant By Shri Rohit Kapoor, Adv. & Shri Virsain Aggarwal, Itp Respondent By Shri Mahesh Kumar, Cit Dr Date Of Hearing 17.09.2025 Date Of Pronouncement 27.11.2025

164 taxmann.com 764 (Gujarat) has held as under: Section 68 of the Income-tax Act, 1961 - Cash credit (Scope of provision) - Assessment year 2016-17 - Assessing Officer made addition of certain amount to assessee's income on account of unsecured loan treading same as unexplained cash credit under section 68 - Whether since amount of loan received by assessee was returned

DY. COMMISSIONER OF INCOME TAX, NOIDA vs. M/S ACE MEGA STRUCTURE PRIVATE LIMITED, NOIDA

In the result, appeal of the assessee is allowed

Bench: Shri Anubhav Sharma & Shri Manish Agarwalsl. Ita No(S) Asst. Appeal(S) By No Year(S) Appellant Vs. Respondent Appellant Respondent 1. 4067/Del/2025 2019-20 M/S. Ace Mega Dcit/Acit Structures Pvt. Ltd., Central Circle I-B, 7Th Floor, Ace Studio, Noida Sector-126, Noida, Sector- 37, S.O. Gautam Budh Nagar-201303 Pan-Aakca8694D M/S. Ace Mega 2. 4115/Del/2025 2019-20 Dcit, Structures Pvt. Ltd. Central Circle-1, A.R.T.O Complex, Sector-33, I-B, 7Th Floor, Ace Studio, Noida-201301. Sector-126, Noida, Sector- 37, S.O. Gautam Budh Nagar-201303 Pan-Aakca8694D Appellant By Shri Rohit Kapoor, Adv. & Shri Virsain Aggarwal, Itp Respondent By Shri Mahesh Kumar, Cit Dr Date Of Hearing 17.09.2025 Date Of Pronouncement 27.11.2025

164 taxmann.com 764 (Gujarat) has held as under: Section 68 of the Income-tax Act, 1961 - Cash credit (Scope of provision) - Assessment year 2016-17 - Assessing Officer made addition of certain amount to assessee's income on account of unsecured loan treading same as unexplained cash credit under section 68 - Whether since amount of loan received by assessee was returned

ITO, NEW DELHI vs. SHRI SANDEEP SABHARWAL, NEW DELHI

Bench: Sh. G. C. Gupta, Hon’Ble & Sh. O.P.Kant

TDS payable of Rs. 29,51,460/-. Thus, there are mutual transactions between the said company and the assessee throughout the year. 5 Therefore, in our considered opinion, this account is in the nature of a current account, and moreover, the salary payable is also credited in this account and wherever there are payments in excess of the salary

DLF LTD.,NEW DELHI vs. ADDL. CIT, NEW DELHI

Bench: Shri A.T. Varkey & Shri Prashant Maharishi

Section 41(1) the assessee should have obtained, whether in cash or in any other manner whatsoever, any amount in respect of the loss or expenditure earlier allowed as a deduction. This part of the reasoning, in the light of the amended clause (a) of sub-section (1) of Section 41 may not be relevant after substitution of the said

ACIT, NEW DELHI vs. M/S DLF LTD., NEW DELHI

Bench: Shri A.T. Varkey & Shri Prashant Maharishi

Section 41(1) the assessee should have obtained, whether in cash or in any other manner whatsoever, any amount in respect of the loss or expenditure earlier allowed as a deduction. This part of the reasoning, in the light of the amended clause (a) of sub-section (1) of Section 41 may not be relevant after substitution of the said

AMAZON SMART COMMERCE SOLUTIONS PRIVATE LIMITED,DELHI vs. PRINCIPAL COMMISSIONER OF INCOME TAX, DELHI-1, DELHI

Bench: Shri S. Rifaur Rahman & Shri Vimal Kumar

164 to 168 of paper book) The PCIT vide the said notice directed the appellant to furnish information regarding certain related parties (@pt 2, 3, 6 of notice) as stated below: “2. Please provide the copy of contract with Amazon Smart Commerce Solution Pvt Ltd (ASCSPL) for administrative support services and legal and professional services. Please explain when you yourselves

BCL SECURITIES PVT LTD,GURGAON vs. ACIT CIRCLE-4(1), NEW DELHI

In the result, the appeal of the assessee is allowed

Bench: Shri Amit Shukla & Shri Prashant Maharishi

2 lakhs left in the hands of the assessee. In this case it was held that if all that an assessee who wanted to evade tax was to have some recitals made in a document either executed by him or executed in his favour then the door would be left wide-open to evade tax. A little probing was sufficient

DCIT,C-11(1), NEW DELHI vs. HERO MOTOCORP LTD.,, NEW DELHI

Appeal of the Revenue is dismissed

Bench: Shri Narendra Kumar Billaiya & Shri Kul Bharat

TDS) v. OCM India Ltd. - [2018] 408 ITR 369 (P&H) - Hindustan Coca Cola Beverages (P.) Ltd. v. CIT: [2018] 402 ITR 539 (Raj. HC) Without prejudice to the above, it is submitted that the assessing officer erred in disallowing 100% of the impugned expenditure incurred, instead of restricting the disallowance to 30% of the said total expenditure, in terms

NEETU YADAV,GURGAON vs. INCOME TAX OFFICER, GURGAON

Bench: Sh. Satbeer Singh Godara & Sh. Manish Agarwalita No. 4095/Del/2024 : Asstt. Year : 2013-14 Ita No. 4229/Del/2024 : Asstt. Year : 2019-20 Ita No. 845/Del/2025 : Asstt. Year : 2014-15 Neetu Yadav, Vs Income Tax Officer, 164-P, Sector-15, Part-1, Ward-3(1), Gurgaon, Haryana-122001 Gurgaon, Haryana (Appellant) (Respondent) Pan No. Abfpy2785C Assessee By : Sh. Anand Kumar Pandey, Adv. & Sh. Archit Pandey, Adv. Revenue By : Sh. Om Prakash, Sr. Dr Date Of Hearing: 29.09.2025 Date Of Pronouncement: 29.09.2025 Order Per Satbeer Singh Godara: These Assessee’S Three Appeals In Ita Nos. 4095 & 4229/Del/2024 & Ita No. 845/Del/2025 For Assessment Years 2013-14, 2014-15 & 2019-20, Arise Against The Cit(A)/Nfac, Delhi’S Din & Order No. Itba/Nfac/S/250/2024- 25/1066728710(1) & 1067097100(1) & 1066774096(1) Dated 15.07.2024, 16.07.2024 & 29.07.2024 In Proceedings U/S 143(3) Of The Income Tax Act, 1961 (In Short “The Act”), Respectively.

164-P, Sector-15, Part-1, Ward-3(1), Gurgaon, Haryana-122001 Gurgaon, Haryana (APPELLANT) (RESPONDENT) PAN No. ABFPY2785C Assessee by : Sh. Anand Kumar Pandey, Adv. & Sh. Archit Pandey, Adv. Revenue by : Sh. Om Prakash, Sr. DR Date of Hearing: 29.09.2025 Date of Pronouncement: 29.09.2025 ORDER Per Satbeer Singh Godara, Judicial Member: These assessee’s three appeals

NEETU YADAV,GURGAON vs. INCOME TAX OFFICER, GURGAON

Bench: Sh. Satbeer Singh Godara & Sh. Manish Agarwalita No. 4095/Del/2024 : Asstt. Year : 2013-14 Ita No. 4229/Del/2024 : Asstt. Year : 2019-20 Ita No. 845/Del/2025 : Asstt. Year : 2014-15 Neetu Yadav, Vs Income Tax Officer, 164-P, Sector-15, Part-1, Ward-3(1), Gurgaon, Haryana-122001 Gurgaon, Haryana (Appellant) (Respondent) Pan No. Abfpy2785C Assessee By : Sh. Anand Kumar Pandey, Adv. & Sh. Archit Pandey, Adv. Revenue By : Sh. Om Prakash, Sr. Dr Date Of Hearing: 29.09.2025 Date Of Pronouncement: 29.09.2025 Order Per Satbeer Singh Godara: These Assessee’S Three Appeals In Ita Nos. 4095 & 4229/Del/2024 & Ita No. 845/Del/2025 For Assessment Years 2013-14, 2014-15 & 2019-20, Arise Against The Cit(A)/Nfac, Delhi’S Din & Order No. Itba/Nfac/S/250/2024- 25/1066728710(1) & 1067097100(1) & 1066774096(1) Dated 15.07.2024, 16.07.2024 & 29.07.2024 In Proceedings U/S 143(3) Of The Income Tax Act, 1961 (In Short “The Act”), Respectively.

164-P, Sector-15, Part-1, Ward-3(1), Gurgaon, Haryana-122001 Gurgaon, Haryana (APPELLANT) (RESPONDENT) PAN No. ABFPY2785C Assessee by : Sh. Anand Kumar Pandey, Adv. & Sh. Archit Pandey, Adv. Revenue by : Sh. Om Prakash, Sr. DR Date of Hearing: 29.09.2025 Date of Pronouncement: 29.09.2025 ORDER Per Satbeer Singh Godara, Judicial Member: These assessee’s three appeals

NEETU YADAV,GURGAON, HARYANA vs. INCOME TAX OFFICER, INCOME TAX OFFICE, GURGAON

Bench: Sh. Satbeer Singh Godara & Sh. Manish Agarwalita No. 4095/Del/2024 : Asstt. Year : 2013-14 Ita No. 4229/Del/2024 : Asstt. Year : 2019-20 Ita No. 845/Del/2025 : Asstt. Year : 2014-15 Neetu Yadav, Vs Income Tax Officer, 164-P, Sector-15, Part-1, Ward-3(1), Gurgaon, Haryana-122001 Gurgaon, Haryana (Appellant) (Respondent) Pan No. Abfpy2785C Assessee By : Sh. Anand Kumar Pandey, Adv. & Sh. Archit Pandey, Adv. Revenue By : Sh. Om Prakash, Sr. Dr Date Of Hearing: 29.09.2025 Date Of Pronouncement: 29.09.2025 Order Per Satbeer Singh Godara: These Assessee’S Three Appeals In Ita Nos. 4095 & 4229/Del/2024 & Ita No. 845/Del/2025 For Assessment Years 2013-14, 2014-15 & 2019-20, Arise Against The Cit(A)/Nfac, Delhi’S Din & Order No. Itba/Nfac/S/250/2024- 25/1066728710(1) & 1067097100(1) & 1066774096(1) Dated 15.07.2024, 16.07.2024 & 29.07.2024 In Proceedings U/S 143(3) Of The Income Tax Act, 1961 (In Short “The Act”), Respectively.

164-P, Sector-15, Part-1, Ward-3(1), Gurgaon, Haryana-122001 Gurgaon, Haryana (APPELLANT) (RESPONDENT) PAN No. ABFPY2785C Assessee by : Sh. Anand Kumar Pandey, Adv. & Sh. Archit Pandey, Adv. Revenue by : Sh. Om Prakash, Sr. DR Date of Hearing: 29.09.2025 Date of Pronouncement: 29.09.2025 ORDER Per Satbeer Singh Godara, Judicial Member: These assessee’s three appeals

ACIT, CIRCLE-8(2), NEW DELHI vs. EXPENDITORS INTERNATIONAL (INDIA) PVT. LTD., NEW DELHI

In the result, all the appeals of the assessee are allowed and all the appeals of the revenue are dismissed

Bench: Sh. Amit Shukladr. B. R. R. Kumar

164/- made on account of Arm’s Length Price. 2. The ld. CIT (A) erred in law and on the facts of the case in deleting the addition of Rs.3,84,88,293/- made on account of non-deduction of TDS in respect of payment made towards Global Account Management Charges. 3. The ld. CIT (A) erred

EXPEDITORS INTERNATIONAL (INDIA) PRIVATE LIMITED,NEW DELHI vs. ACIT CIRCLE-7(1), NEW DELHI

In the result, all the appeals of the assessee are allowed and all the appeals of the revenue are dismissed

Bench: Sh. Amit Shukladr. B. R. R. Kumar

164/- made on account of Arm’s Length Price. 2. The ld. CIT (A) erred in law and on the facts of the case in deleting the addition of Rs.3,84,88,293/- made on account of non-deduction of TDS in respect of payment made towards Global Account Management Charges. 3. The ld. CIT (A) erred