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

In the result, the appeal of the assessee is partly allowed

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

NIIT FOUNDATION,NEW DELHI vs. CIT(E), NEW DELHI

In the result, the appeal of the assessee is allowed

Bench: Shri Prashant Maharishi & Shri K.N.Charyniit Foundation, Vs. Cit(E), Plot No. 8, Balaji Estate, New Delhi Sudarshan Munjal Marg, Kalkaji, New Delhi Pan: Aacan3951E (Appellant) (Respondent)

section 263 of IX Act, 1961. 4. Date of hearing in your case has been fixed for 03.12.2018 at 11:45AM at my office. You may produce all necessary evidence in support of your explanation.," 7. Assessee responded to that by filing detailed representation explaining the reason for show cause stating that order is neither erroneous and nor prejudicial

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

19,323/-; and therefore, once there is such a huge negative value then only the face value of Rs. 10 can be taken and Rs. 20/- which is premium has to be reduced in accordance with provision of section 56(2)(viib). Accordingly, he made enhancement of Rs. 20 per share for 2,40,83,333 equity shares allotted during

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

19,323/-; and therefore, once there is such a huge negative value then only the face value of Rs. 10 can be taken and Rs. 20/- which is premium has to be reduced in accordance with provision of section 56(2)(viib). Accordingly, he made enhancement of Rs. 20 per share for 2,40,83,333 equity shares allotted during

VACHASPATI SHARMA,GURGAON vs. ITO WARD -4(1), GURGAON

In the result, the appeal of the assessee is dismissed

Bench: Sh. S. Rifaur Rahman & Sh. Sudhir Kumarassessment Year: 2019-20 Vachaspati Sharma Vs Ito Village – Hayatpur Garhi Ward-4 Harsaru, Hayatpur, Gurgaon Gurgaon Pan No.Fnqps2021R (Appellant) (Respondent) Appellants By Sh. Suraj Bhan Nain, Advocate Sh. K.L. Pahwa, Advocate Respondent By Ms. Sapna Bhatia, Cit Dr Date Of Hearing: 11/09/2024 Date Of Pronouncement: 21/11/2024 Order Sh. Sudhir Kumar, Jm :

section 194A of the I.T. Act. 11. Reliance has also placed on the following judgments :- 1. CIT, Faridabad vs. Ghanshyam (HUF) [29] 182 Taxman 368 (SC) 2. CIT, Rajkot Vs. Govindbhai Mamaiya [2014] 52 taxman.com 27 (SC) 3. Surjit Kumar Chetal Vs. CIT-XV [2017] 86 taxmann.com 121 (Delhi) 4. Movaliya Bhikhubhai Balabhai v. ITO [2016] 70 taxmann.com

YOSHIO KUBO vs. COMMISSIONER OF INCOME TAX

The appeals are disposed of accordingly

19 of 1952), to effect, an assurance on the life of the assessee or to effect a contract for an annuity." 2013:DHC:3744-DB ITA 441/2003 and connected cases Page 36 Section 7 (1) was the pre-existing provision under the Indian Income Tax Act, 1922; it read as follows: “Section 7(1)-The tax shall be payable

YOSHIO KUBO vs. COMMISSIONER OF INCOME TAX

The appeals are disposed of accordingly

19 of 1952), to effect, an assurance on the life of the assessee or to effect a contract for an annuity." 2013:DHC:3744-DB ITA 441/2003 and connected cases Page 36 Section 7 (1) was the pre-existing provision under the Indian Income Tax Act, 1922; it read as follows: “Section 7(1)-The tax shall be payable

YOSHIO KUBO vs. COMMISSIONER OF INCOME TAX

The appeals are disposed of accordingly

19 of 1952), to effect, an assurance on the life of the assessee or to effect a contract for an annuity." 2013:DHC:3744-DB ITA 441/2003 and connected cases Page 36 Section 7 (1) was the pre-existing provision under the Indian Income Tax Act, 1922; it read as follows: “Section 7(1)-The tax shall be payable

VIJAY SINGH CHAUHAN,NOIDA vs. ITO,WARD-2(5), NOIDA

The appeal of the assessee is hereby dismissed

Bench: Shri Sudhir Pareek & Shri Avdhesh Kumar Mishravijay Singh Chauhan, Income Tax Officer, House No.-193, Gali No.-3, Vs. Ward- 2(5), Noida, Village Chhalera, Sector-44, Uttar Pradesh, Noida, Uttar Pradesh India. India. Pan No: Aeipc4637E Appellant Respondent Assessee By : Sh. Naveen Kumar, Adv. Revenue By : Ms. Harpreet Kaur Hansra, Sr. Dr Date Of Hearing: 01.07.2025 Date Of Pronouncement: 26.09.2025 Order Per Sudhir Pareek, Jm: The Aforetitled Appeal Has Been Preferred Against The Order Of National Faceless Appeal Centre, Delhi [Hereinafter, In Short, ‘Cit(A)’] Dated 17.07.2023 For Ay 2015-16, By Which Appeal Of The Assessee Was Dismissed.

TDS-1, Surat [2016] 70 taxmann.com 45 (Gujrat). 8. Per Contra, the Learned DR relying upon the orders passed by the both authorities below, submitted that the Legislature introduced the provisions of section 56(2)(viii) vide an amendment, by the Finance Act, 2009, w.e.f. 01/04/2010, and inserted “income by way of interest received on compensation or on enhanced compensation

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) read with Section 44BB(1). The service tax is not an amount paid or payable, or received or deemed to be received by the Assessee for the services rendered by it. The Assessee is only collecting the service tax for passing it on to the government. 18. The Court further notes that the position has been made explicit

HINDUSTAN COCA COLA BEVERAGES vs. JT.COMMISSIONER OF INCOME TAX

The appeal is allowed in the above terms, but in the circumstances, with

Bench: HON'BLE DR. JUSTICE S.MURALIDHAR,HON'BLE MR. JUSTICE NAJMI WAZIRI

TDS under Section 194-C of the Act. 11. The above order of the ITAT dated 12th July 2002 was affirmed by this Court by order dated 21st May 2004 in ITA No. 282 of 2002. The Court was of the view that no substantial question of law arose from the impugned order dated 12th July 2002 of the ITAT

HERO MOTOCORP LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result appeal No. 2424/Del/ 2015 filed by the revenue in assessment year 2010-11 is partly allowed

Bench: Shri R. K. Panda & Ms Suchitra Kamble

section 194C was amended by the Finance (2) Act, 2009 w.e.f. 1.10.2009, whereby the definition of “work” was enlarged to include contract for manufacturing or supplying a product according to the requirement or specification of a customer by using material purchased from such customer. The said amendment also provided that contract for carrying out work shall not include contract

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

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

TDS) under Section 195(2) or 195(3) either by the non-resident or by the resident payer is to avoid any future hassles for both resident as well as non resident. In our view, Sections 195(2) and 195(3) are safeguards. The said provisions are of practical importance. This reasoning of ours is based on the decision

HERO MOTOCORP LTD.,,NEW DELHI vs. ADDL.CIT, RANGE-11, NEW DELHI

In the result ground No

Bench: Shri R. K. Panda & Ms Suchitra Kamblei.T.A. No. 6990/Del/2017 (A.Y 2013-14)

19. The Ld. AR submitted that the aforesaid issue is covered by the order passed by the Tribunal in the assessee's own case for Assessment Year 2008- 09, wherein, the Tribunal had taken into consideration the finding of the DRP deciding the issue in favor of the assessee and remanded the matter to the file of the Assessing Officer

KAUSHAL INFRAPROJECT INDUSTRIES INDIA LTD.,NEW DELHI vs. DCIT, NEW DELHI

Bench: : Shri Bhavnesh Saini & Dr. B.R.R. Kumar

TDS have been deducted and income have been offered for tax by the Director. Therefore, considering the nature of business of assessee and contribution of Director and following order for A.Y. 2010-2011 in which we have dismissed the departmental appeal, we do not find any justification to interfere with the Order of the Ld. CIT(A) in deleting

DCIT, NEW DELHI vs. M/S. KUSHAL INFRAPROJECT INDUSTRIES INDIA LTD., NEW DELHI

Bench: : Shri Bhavnesh Saini & Dr. B.R.R. Kumar

TDS have been deducted and income have been offered for tax by the Director. Therefore, considering the nature of business of assessee and contribution of Director and following order for A.Y. 2010-2011 in which we have dismissed the departmental appeal, we do not find any justification to interfere with the Order of the Ld. CIT(A) in deleting

DCIT, NEW DELHI vs. M/S. KUSHAL INFRAPROJECT INDUSTRIES INDIA LTD., NEW DELHI

Bench: : Shri Bhavnesh Saini & Dr. B.R.R. Kumar

TDS have been deducted and income have been offered for tax by the Director. Therefore, considering the nature of business of assessee and contribution of Director and following order for A.Y. 2010-2011 in which we have dismissed the departmental appeal, we do not find any justification to interfere with the Order of the Ld. CIT(A) in deleting

KAUSHAL INFRAPROJECT INDUSTRIES INDIA LTD.,NEW DELHI vs. DCIT, NEW DELHI

Bench: : Shri Bhavnesh Saini & Dr. B.R.R. Kumar

TDS have been deducted and income have been offered for tax by the Director. Therefore, considering the nature of business of assessee and contribution of Director and following order for A.Y. 2010-2011 in which we have dismissed the departmental appeal, we do not find any justification to interfere with the Order of the Ld. CIT(A) in deleting