INDIA TODAY ONLINE PVT. LTD.,NEW DELHI vs. ITO, WARD- 12(2), NEW DELHI

In the result both the appeals of the assessee are allowed

Bench: Shri Amit Shukla & Shri L.P. Sahuita Nos. 6453 & 6454/Del/2018 Assessment Years 2013-14 & 2014-15

TDS payable 43,63,060 - 43,63,060 formula and failed to took factor of Rs. 10, and if said factor would have been taken, 8,53,059 8,75,737 8,53,059 the value of assessee’s share would have Other been Rs. 70 (even going by the method so Current applied by learned AO) Liabilities

INDIA TODAY ONLINE PVT. LTD.,NEW DELHI vs. ITO, WARD- 12(2), NEW DELHI

In the result both the appeals of the assessee are allowed

Bench: Shri Amit Shukla & Shri L.P. Sahuita Nos. 6453 & 6454/Del/2018 Assessment Years 2013-14 & 2014-15

TDS payable 43,63,060 - 43,63,060 formula and failed to took factor of Rs. 10, and if said factor would have been taken, 8,53,059 8,75,737 8,53,059 the value of assessee’s share would have Other been Rs. 70 (even going by the method so Current applied by learned AO) Liabilities

ADIT, DEHRADUN vs. M/S. HALLIBURTON OFFSHORE SERVICES INC., DEHRADUN

Bench: Shri I.C.Sudhir & Shri Prashant Maharishiadit, Halliburton Offshore Services International Taxation, Inc. , Vs. 13-A,Subhash Road, C/O. Nangia & Company, Ca, Aayakar Bhawan, 75/7, Rajpur Road, Dehradun Dehradun Pan:Aaach5154M (Appellant) (Respondent) Halliburton Offshore Services Addl. Cit, Inc. , International Taxation, Vs. C/O. Nangia & Company, Ca, Subhash Road, Suite-4A, Plaza M-6, Jasola, Dehradun New Delhi Pan:Aaach5154M (Appellant) (Respondent) Halliburton Offshore Services Inc. , Adit, C/O. Nangia & Company, Ca, International Taxation, Vs. Suite-4A, Plaza M-6, Jasola, 13-A,Subhash Road, New Delhi Aayakar Bhawan, Pan:Aaach5154M Dehradun (Appellant) (Respondent) Halliburton Offshore Services Inc. Vs Ddit (International Taxation)

2) is not merely a provision to provide information to the ITO(TDS). It is a provision requiring tax to be deducted as source to be paid to the Revenue by the payer who makes payment to a non-resident. Therefore, Section 195 has to be read in conformity with the charging provisions, ie., Sections 4, 5 and 9. This

SH. CHANDRA SHEKHAR AGGARWAL,NEW DELHI vs. ACIT,

In the result, the appeal is allowed

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

TDS is to be allowed in terms of Rule 37BA(2) of the Rules and as such the credit would be allowable on pro rata basis in the year in which the certificate is issued and also in future where balance of such income is found to be assessable as per the mandate of section 199

DDIT, NEW DELHI vs. M/S SCORPION COURAGEOUS LTD.,, NEW DELHI

In the result, the Cross Objection of the assessee is partly allowed

2) is not merely a provision to provide information to the 11 & C.O. No. 59/Del/2013 ITO(TDS). It is a provision requiring tax to be deducted as source to be paid to the Revenue by the payer who makes payment to a non-resident. Therefore, Section 195 has to be read in conformity with the charging provisions, ie., Sections

DCIT, DEHRADUN vs. M/S. EXPRO GULF LTD., MUMBAI

In the result, the appeal of the Revenue is partly allowed for statistical

Bench: : Shri H.S. Sidhu & Shri L.P. Sahu

2) is not merely a provision to provide information to the ITO(TDS). It is a provision requiring tax to be deducted as source to be paid to the Revenue by the payer who makes payment to a non-resident. Therefore, Section 195 has to be read in conformity with the charging provisions, ie., Sections 4, 5 and 9. This

CHANDRA SHEKHAR AGGARWAL,NEW DELHI vs. ACIT, NEW DELHI

Appeal of the assessee is allowed

Bench: Shri N. K. Saini & Ms Suchitra Kamblechandra Shekhar Aggarwal Vs Acit R-159, Circle-61(1) New Rajinder Nagar New Delhi New Delhi Aacpa6665M (Respondent) (Appellant)

TDS strictly as per the provisions of Section 199 to be 2 read with Rule 37BA of the I.T. Rules

UBEROI SOOD & KAPOOR,NEW DELHI vs. ACIT, CIRCLE- 63(1), NEW DELHI

In the result, appeal of the Assessee is allowed

Bench: Shri R.K. Panda & Shri Narendra Kumar Choudhary

TDS is to be allowed in terms of Rule 37BA(2) of the Rules and as such the credit would be allowable on pro rata basis in the year in which the certificate is issued and also in future where balance of such income is found to be assessable as per the mandate of section 199

YAMUNA KHADAR SHIKSHA SAMITI,DELHI vs. ITO, TDS, MUZAFFARNAGAR

In the result, all the Eleven appeals filed by the Assessee stands allowed

Bench: Shri H. S. Sidhu & Before Shri A.N. Misshra

2)(k) of the Act were simultaneously introduced. He further referred to the provisions of section 200A of the Act which were introduced w.e.f. 01.04.2010 by the Finance (No.2) Act, 2009 for furnishing of TDS returns. Further, reference was made to sub-clauses under section 200A(1) of the Act, wherein clause (a) refers to the sum deducted and clause

YAMUNA KHADAR SHIKSHA SAMITI,DELHI vs. ITO, TDS, MUZAFFARNAGAR

In the result, all the Eleven appeals filed by the Assessee stands allowed

Bench: Shri H. S. Sidhu & Before Shri A.N. Misshra

2)(k) of the Act were simultaneously introduced. He further referred to the provisions of section 200A of the Act which were introduced w.e.f. 01.04.2010 by the Finance (No.2) Act, 2009 for furnishing of TDS returns. Further, reference was made to sub-clauses under section 200A(1) of the Act, wherein clause (a) refers to the sum deducted and clause

YAMUNA KHADAR SHIKSHA SAMITI,DELHI vs. ITO, TDS, MUZAFFARNAGAR

In the result, all the Eleven appeals filed by the Assessee stands allowed

Bench: Shri H. S. Sidhu & Before Shri A.N. Misshra

2)(k) of the Act were simultaneously introduced. He further referred to the provisions of section 200A of the Act which were introduced w.e.f. 01.04.2010 by the Finance (No.2) Act, 2009 for furnishing of TDS returns. Further, reference was made to sub-clauses under section 200A(1) of the Act, wherein clause (a) refers to the sum deducted and clause

SWAYAM PRABHA JAIN,NEW DELHI vs. ACIT, NEW DELHI

Bench: Shri N.S. Saini & Shri Kuldip Singh

TDS is to be allowed in terms of Rule 37BA(2) of the Rules and as such the credit would be allowable on pro rata basis in the year in which the certificate is issued and also in future where balance of such income is found to be assessable as per the mandate of section 199

DIRECTOR OF INCOME TAX INTERNATIONAL TAXATION vs. GE PACKAGED POWER INC

2) is not merely a provision to provide information to the ITO(TDS). It is a provision requiring tax to be deducted as source to be paid to the Revenue by the payer who makes payment to a non-resident. Therefore, Section 195 has to be read in conformity with the charging provisions, ie., Sections 4, 5 and 9. This

HARI SHANKAR SINGHANIA ESTATE,NEW DELHI vs. JCIT SPL. RANGE - 18, NEW DELHI

In the result, for statistical purposes the appeal of the assessee is partly allowed

Bench: Shri N.K. Billaiya & Ms. Astha Chandraasstt. Year: 2014-15 Hari Shankar Singhania Estate, Vs. Jcit, Patroit House, 3, Special Range-18 Bahadur Shah Zafar Marg, New Delhi. New Delhi – 110 002 Pan Aaaah9163Q (Appellant) (Respondent)

2)(i) of the Income Tax Rules, 1962 as amended by the Income Tax (Eight amendment) Rules, 2011 and observed that the essence of the provisions of the Section 199 r.w. corresponding Rules is that the tax deducted at source (TDS

INTERGLOBE TECHNOLOGY QUOTIENT PRIVATE LIMITED,NEW DELHI vs. ASSISTANT COMMISSIONER CIRCLE 10(1), NEW DELHI

Bench: Shri M. Balaganesh & Shri Anubhav Sharma[Assessment Year: 2020-21

TDS credit of Rs.3,87,50,028 was offered to tax in the year under consideration and hence the credit was allowable in terms of section 199 of the Act read with Rule 37BA of the Income Tax Rules, 1962 dehors the fact that the same was reflected in the Form 26AS for subsequent year. Re: Interest under section 234A/B/C

HERO FINCORP LIMITED,NEW DELHI vs. ACIT, CIRCLE 11(1), DELHI, C.R. BUILDING

Bench: Shri Mahavir Singh, Vice Presdient (), Shri Satbeer Singh Godara & Shri Brajesh Kumar Singhआ.अ.सं/.I.T.A No.2542/Del/2024 निर्धारणवर्ष/Assessment Year:2017-18 Hero Fincop Ltd., 34 Community Centre, Basant Lok, Vasant Vihar, New Delhi-110057 बनाम Vs. Assistant Commissioner Of Income Tax, Circle-11(1) C. R. Building, New Delhi-110002 अपीलार्थी Appellant प्रत्यर्थी/Respondent Pan:Aaach0157J Assessee By Shri Rohit Jain, Adv., Shri Deepesh Jain, Adv. & Shri Himanshu Aggarwal Adv. Revenue By Ms. Pooja Swaroop, Cit(Dr) सुनवाईकीतारीख / Date Of Hearing: 14.01.2026 उद्घोषणाकीतारीख/Pronouncement On 16.01.2026 आदेश /Order Per Brajesh Kumar Singh, Am, The Assessee Is Engaged In The Business Of ‘Hire Purchase Leasing & Finance'. This Appeal Is Filed By The Assessee Against The Order Of National Faceless Appeal Center (Nfac)/(First Appellate Authority Hereinafter Referred As “Faa”), Delhi Dated 27.03.2024 Arising Out Of Assessment Order U/S 143(3) Of The Act Dated 29.12.2019For The Assessment Year 2017-18. 2. The Assessee Has Raised Following Grounds Of Appeal: “Disallowance Of Provision For Collection Charges -Rs. 9,75,00,000/-

TDS certificates issued for FY 16-17 on sample basis, are enclosed as Enclosure-IV. Thus, our submission is that, the entire collection expenditure, including provision made for the purpose of business and services rendered by collection vendors during the year 2016-17. is allowable as business expenditure to the assessee. Therefore, the question disallowance or making any addition

ADIT, NEW DELHI vs. M/S. PARPOOL LTD., NEW DELHI

In the result, solitary ground of appeal of the revenue is dismissed

Bench: Shri H S Sidhu & Shri Prashant Maharishi

2) is not merely a provision to provide information to the ITO(TDS). It is a provision requiring tax to be deducted as source to be paid to the Revenue by the payer who makes payment to a non-resident. Therefore, Section 195 has to be read in conformity with the charging provisions, ie., Sections 4, 5 and 9. This

ROLLS ROYCE MILITARY AERO ENGINES LTD vs. DDIT INT. TAXATION CIRCLE 2 (1),

In the result all the five appeals of the assessee are partly allowed

Bench: Shri H.S.Sidhu & Shri Prashant Maharishi

2) is not merely a provision to provide information to the ITO(TDS). It is a provision requiring tax to be deducted as source to be paid to the Revenue by the payer who makes payment to a non-resident. Therefore, Section 195 has to be read in conformity with the charging provisions, ie., Sections 4, 5 and 9. This