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

35,00,000/-; secondly, in financial year 2011-12, i.e., in the assessment year 2012-13 for sum of Rs. 50,90,00,00/-, aggregating to Rs. 72,25,00,000/-; and lastly, further received share application money in financial year 2012-13 for sum of Rs. 16,96,01,580/-. All the share application money was received from

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

35,00,000/-; secondly, in financial year 2011-12, i.e., in the assessment year 2012-13 for sum of Rs. 50,90,00,00/-, aggregating to Rs. 72,25,00,000/-; and lastly, further received share application money in financial year 2012-13 for sum of Rs. 16,96,01,580/-. All the share application money was received from

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 :

35 Section 45(5) read as a whole (including clause (c)) not only deals with reworking as urged on behalf of the assessee but also with the change in the full value of the consideration (computation) and since the enhanced compensation/ consideration (including interest under Section 28 of the 1894 Act) becomes payable/ paid under the 1894 Act at different

YOSHIO KUBO vs. COMMISSIONER OF INCOME TAX

The appeals are disposed of accordingly

35. In the case of Yoshio Kubo, one of the appeals in the present batch, the assessee employee was a Japanese national, and an official of M/s Sony Corporation of Japan. He was deputed to work in M/s Sony India Ltd. The welfare pension scheme in that case contained the following elements: (a) The contribution was covered by the welfare

YOSHIO KUBO vs. COMMISSIONER OF INCOME TAX

The appeals are disposed of accordingly

35. In the case of Yoshio Kubo, one of the appeals in the present batch, the assessee employee was a Japanese national, and an official of M/s Sony Corporation of Japan. He was deputed to work in M/s Sony India Ltd. The welfare pension scheme in that case contained the following elements: (a) The contribution was covered by the welfare

YOSHIO KUBO vs. COMMISSIONER OF INCOME TAX

The appeals are disposed of accordingly

35. In the case of Yoshio Kubo, one of the appeals in the present batch, the assessee employee was a Japanese national, and an official of M/s Sony Corporation of Japan. He was deputed to work in M/s Sony India Ltd. The welfare pension scheme in that case contained the following elements: (a) The contribution was covered by the welfare

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) @ 10 per cent only on amount of Rs.13,43,02,195/- which is the interest portion and the remaining amount of Rs.3,85,10,725 being enhanced value and solatium not been considered for deduction of tax at source. Hence it is clear that the authority has not considered the entire amount as enhanced value of compensation attributable

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)

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

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

2 taxmann.com 32 (Del) and CIT v. Cadbury India Ltd (2011) 11 taxmann.com 66(Del) and submitted that there was reasonable cause for the Appellant‟s failure to deduct TDS under Section 194-I of the Act. 32. Mr. Raghvendra Singh, learned counsel for the Revenue, first submitted that the conduct of the Assessee did not entitle

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

35. The Ld. AR submitted that in AY 2007-08, the Tribunal decided the issue in favour of the assessee by holding that assessee’s intention did not reflect that the amount was received as loan or advance so as to attract the provisions of section 2(22)(e) of the Act. The Tribunal further held that the assessee

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)

Section 2(22)(e) will not be applicable in the present case. The issue is squarely covered by the order of the Tribunal for A.Ys. 2010-11 and 2011-12. Therefore, Ground Nos. 10 to 10.3 are allowed in favour of the assessee. 34. As regards to Ground No. 11 to11.1 relating to disallowance of payments made for advisory services

INFANT JESUS SCHOOL,MUZAFFARNAGAR vs. ACIT, TDS(CPC), MUZAFFARNAGAR

In the result, all appeals of different assesses are allowed

Bench: Ms. Sushma Chowla, Vp & Dr. B.R.R. Kumar, Am [Through Video Conferencing]

35,00,000/-, the assessee' contention has been that it was not required to deduct TDS, because the payments made to each seller was less than the prescribed limit of Rs.50 lacs and therefore, provision of section 194IA was not applicable. The demand has been raised by the department u/s 200 in terms of failure to comply with Section 200A

SIPL TEXTILES PVT. LTD.,NEW DELHI vs. ACIT, CIRCLE- 77(1), NEW DELHI

In the result, all appeals of different assesses are allowed

Bench: Ms. Sushma Chowla, Vp & Dr. B.R.R. Kumar, Am [Through Video Conferencing]

35,00,000/-, the assessee' contention has been that it was not required to deduct TDS, because the payments made to each seller was less than the prescribed limit of Rs.50 lacs and therefore, provision of section 194IA was not applicable. The demand has been raised by the department u/s 200 in terms of failure to comply with Section 200A

SIPL TEXTILES PVT. LTD.,NEW DELHI vs. ACIT, CIRCLE- 77(1), NEW DELHI

In the result, all appeals of different assesses are allowed

Bench: Ms. Sushma Chowla, Vp & Dr. B.R.R. Kumar, Am [Through Video Conferencing]

35,00,000/-, the assessee' contention has been that it was not required to deduct TDS, because the payments made to each seller was less than the prescribed limit of Rs.50 lacs and therefore, provision of section 194IA was not applicable. The demand has been raised by the department u/s 200 in terms of failure to comply with Section 200A

SIPL TEXTILES PVT. LTD.,NEW DELHI vs. ACIT, CIRCLE- 77(1), NEW DELHI

In the result, all appeals of different assesses are allowed

Bench: Ms. Sushma Chowla, Vp & Dr. B.R.R. Kumar, Am [Through Video Conferencing]

35,00,000/-, the assessee' contention has been that it was not required to deduct TDS, because the payments made to each seller was less than the prescribed limit of Rs.50 lacs and therefore, provision of section 194IA was not applicable. The demand has been raised by the department u/s 200 in terms of failure to comply with Section 200A

INFANT JESUS SCHOOL,MUZAFFARNAGAR vs. ACIT, TDS(CPC), MUZAFFARNAGAR

In the result, all appeals of different assesses are allowed

Bench: Ms. Sushma Chowla, Vp & Dr. B.R.R. Kumar, Am [Through Video Conferencing]

35,00,000/-, the assessee' contention has been that it was not required to deduct TDS, because the payments made to each seller was less than the prescribed limit of Rs.50 lacs and therefore, provision of section 194IA was not applicable. The demand has been raised by the department u/s 200 in terms of failure to comply with Section 200A

INFANT JESUS SCHOOL,MUZAFFARNAGAR vs. ACIT, TDS(CPC), MUZAFFARNAGAR

In the result, all appeals of different assesses are allowed

Bench: Ms. Sushma Chowla, Vp & Dr. B.R.R. Kumar, Am [Through Video Conferencing]

35,00,000/-, the assessee' contention has been that it was not required to deduct TDS, because the payments made to each seller was less than the prescribed limit of Rs.50 lacs and therefore, provision of section 194IA was not applicable. The demand has been raised by the department u/s 200 in terms of failure to comply with Section 200A

DAR LANDMARKS P.LTD,NOID vs. ACIT, TDS, GHAZIABAD

In the result, all appeals of different assesses are allowed

Bench: Ms. Sushma Chowla, Vp & Dr. B.R.R. Kumar, Am [Through Video Conferencing]

35,00,000/-, the assessee' contention has been that it was not required to deduct TDS, because the payments made to each seller was less than the prescribed limit of Rs.50 lacs and therefore, provision of section 194IA was not applicable. The demand has been raised by the department u/s 200 in terms of failure to comply with Section 200A