DCIT, NEW DELHI vs. M/S SAHARA INDIA MASS COMMUNICATION LTD., MUMBAI

In the result, appeals filed by the Revenue are partly allowed

Bench: Shri S. Rifaur Rahman & Shri Vimal Kumar

TDS deduction on the reimbursement payment to JVC. 4. Unreconciled difference: A massive difference of Rs. 58,85,443 existed between the assessee's booking of reimbursement (Rs. 49,32,507) and the JVC's recording of receipt of these funds (Rs. 10,39,2583 [sic in original document]). The assessee's explanation (differing finalization dates) was unsatisfactory . Revenue

INDIA TRADE PROMOTION ORG

The appeals are disposed of

Bench: HON'BLE MR. JUSTICE SANJIV KHANNA,HON'BLE MR. JUSTICE SANJEEV SACHDEVA

240 of the Act. Merely because this was inclusive of an amount which was payable under Section 214 of the Act, that would not make the position any different. It is an amount which became due to the assessee on the basis of the appellate order. Therefore, the assessee was entitled to interest in terms of Section

INDIA TRADE PROMOTION ORGANISATION vs. COMMISSIONER OF INCOME TAX

The appeals are disposed of

240 of the Act. Merely because this was inclusive of an amount which was payable under Section 214 of the Act, that would not make the position any different. It is an amount which became due to the assessee on the basis of the appellate order. Therefore, the assessee was entitled to interest in terms of Section

The Motor & General Finance Ltd. etc. etc. vs. Commissioner of Income Tax-VI, New Delhi

TDS and advance tax and, therefore, refund was claimed. An intimation under Section 143(1)(a) of the Act had been passed and refund, along with interest, under Section 254A of the Act had been issued to the assessee. It was paid within the time prescribed under the Act. Subsequently, the assessment had been completed under Section

DIPANKAR MOHAN GHOSH,NEW DELHI vs. ITO, TDS WARD-1(3)(2) INT. TAXATION, NEW DELHI

In the result, the appeal filed by the Assessee stands allowed

Bench: Shri N.K. Billaiya & Shri N.K. Choudhryassessment Year: 2012-13

TDS) 4/80, Janpath, New Delhi New Delhi. PAN: AMRPG9569K (Appellant) (Respondent) Appellant by : Shri U.N. Marwah, Ld. CA Shri Praveen Goel, Ld. Adv. Respondent by : Shri Sanjay Kumar, Ld. Sr. DR Date of hearing : 19.07.2022 Date of order : 26.07.2022 ORDER PER N.K. CHOUDHRY, J.M. This appeal has been preferred by the Assessee against the order dated 08.05.2019, impugned herein, passed

ABDUL RAHMAN ASAD ,RIYADH, SAUDI ARABIA vs. DEPUTY COMMISSIONER OF INCOME TAX, INTL. TAX 1(1)(1), NEW DELHI

In the result, the appeal filed by the assessee is allowed

Bench: Shris.Rifaur Rahman & Shri Yogesh Kumar U.S.Abdul Rahman Asad, Vs. Dcit, House No.47, Behind Jain Mandi, Circle Int. Tax 1(1)(1), Mohalla Barihat, New Delhi. Bahraich – 271 801 (Uttar Pradesh). (Pan : Aofpa6981F) (Appellant) (Respondent) Assessee By : Shri Alok Vasant, Fca Ms. Poonam Ahuja, Advocate Revenue By : Shri Vikram Singh Sharma, Sr. Dr Date Of Hearing : 21.08.2025 Date Of Order : 12.11.2025 O R D E R Per S. Rifaur Rahman: 1. The Assessee Has Filed Appeal Against The Order Of The Learned Commissioner Of Income-Tax (Appeals), Delhi - 42 [“Ld. Cit(A)”, For Short] Dated 03.03.2025 For The Assessment Year 2022-23. 2. Brief Facts Of The Case Are, The Assessee Is A Non-Resident & Filed The Original Return Of Income For Ay 2022-23 On 27.07.2022 Declaring Taxable Income Of Rs.4,86,560/- (Income From House Property Rs.4,64,444/-, Income From Other Sources Rs.32,115/- & Loss From Long

TDS of INR 20,99,240/- which is duly reflecting in the Form 26AS of AY 2023-24 and the corresponding income has been duly offered to tax in the return of income filed for AY 2022-23 and as per section

M/S. BAIN & COMPANY INDIA PVT. LTD.,GURGAON vs. ITO (TDS) (INTERNATIONAL TAXATION), NEW DELHI

Section 195 of the Income Tax Act, 1961 (‘the Act’) on payments amounting to Rs. 82,34,240 made by it to its parent company, Bain & Company Inc. (Bain US) on account of payments made to third parties. 2. The Ld. CIT (A) has erred in holding that there is no evidence that such expenses were reimbursement of expenses

CANON INDIA PVT. LTD.,GURGAON vs. ACIT, CIRCLE- 5(2), NEW DELHI

In the result appeal for A

Bench: Shri R.K.Panda & Smt. Beena A Pillaia.Y. 2012-13 & A.Y. 2013-14 Canon India Pvt.Ltd. Acit, Circle 5(2) 7Th Floor, Tower B Vs. New Delhi Building No.5 Dlf Epitome Dlf Phase Iii Gurgaon

TDS under section 195 of the Act on such reimbursements, and consequently made disallowance under section 40 (a) (i) of the Act. ITA 1672/Del/2017 AY 2012-13 ITA 6742/Del/17 AY 2013-14 Canon India P.Ltd. vs. ACIT 19. Ld.AR thereafter, took us through paper book and submitted that employees from Cannon Inc., (being Overseas entity) were seconded at request

CANON INDIA PVT. LTD.,,GURGAON vs. ACIT, NEW DELHI

In the result appeal for A

Bench: Shri R.K.Panda & Smt. Beena A Pillaia.Y. 2012-13 & A.Y. 2013-14 Canon India Pvt.Ltd. Acit, Circle 5(2) 7Th Floor, Tower B Vs. New Delhi Building No.5 Dlf Epitome Dlf Phase Iii Gurgaon

TDS under section 195 of the Act on such reimbursements, and consequently made disallowance under section 40 (a) (i) of the Act. ITA 1672/Del/2017 AY 2012-13 ITA 6742/Del/17 AY 2013-14 Canon India P.Ltd. vs. ACIT 19. Ld.AR thereafter, took us through paper book and submitted that employees from Cannon Inc., (being Overseas entity) were seconded at request

MRINAL ROY,NOIDA vs. DCIT, CIRCLE-2, NOIDA

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

Bench: Ms. Sushma Chowlaआयकर अपील सं. / Ita No.1682/Del/2019 "नधा"रण वष" / Assessment Year 2009-10

section 147/143(3) of the Act on the income declared by the assessee. Though the AO directs the grant credit of prepaid taxes, but the assessee is aggrieved by non allowance of credit of TDS of Rs. 12,36,240

M/S HCL TECHNOLOGIES LTD.,,NOIDA vs. ACIT (TDS), NOIDA

In the result appeal of assessee is allowed

Bench: Shri Amit Shukla & Shri Prashant Maharishihcl Technologies Ltd, Acit(Tds), Plot No. 3A, Tower 6, 14Th Floor, Vs. Noida Sector-126, Noida Pan: Aaach1645P (Appellant) (Respondent)

TDS Statement had not been filed. However, section 201(3) of the Act as amended by Finance Act No.2 of 2014, as mentioned in the memorandum of the Finance Bill No.2 of 2014 is stated to have effect from 1st October, 2014. Thus, wherever the Parliament / Legislature wanted to make provisions applicable retrospectively, it has been so provided

DDIT, NEW DELHI vs. M/S. UNOCOL BHARAT LTD., NEW DELHI

In the result appeal of the revenue is dismissed

Bench: Shri G.D. Agrawal, Hon’Ble & Shri Amit Shukla

240/- by holding that in the absence of any restrictive clause in Article 7 of Indo-Mauritius DTTA no disallowance could be made for non deduction of TDS on salary paid to employee(s) and that section

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

Appeal of the assessee is partly allowed for statistical purpose

Bench: Shri N. K. Billaiya & Ms Suchitra Kamble

TDS under section 194C of the Act. 39.2 That on the facts and circumstances of the case, the assessing officer failed to appreciate that the provisions of section 194C of the Act were not applicable in relation to the aforesaid transactions, as the same were in the nature of contract of sale. 39.3 That the assessing officer erred on facts

M/S DCM SHRIIRAM LTD.,,NEW DELHI vs. DCIT, NEW DELHI

In the result, both the appeals of the assessee are allowed

Bench: Ms. Sushma Chowla & Dr. B.R.R.Kumarआयकर अपील सं आयकर अपील सं. / Ita Nos. 5221 & 5222/Del/2016 आयकर अपील सं आयकर अपील सं िनधा"रण वष" / Assessment Years: 2005-06 & 2009-10 िनधा"रण वष" िनधा"रण वष" िनधा"रण वष" Dcm Shriram Ltd., 5Th Floor, Kanchenjunga Building, 18, Barakhamba Road, New Delhi-110001. …...........अपीलाथ"/Appellant Pan-Aaacd0097R Vs Dcit, Circle-7(1), …………. ू"यथ" / Respondent C.R.Building, New Delhi.

240 of the Act amount refundable consist of tax as well as interest allowable to an assessee. 4. That the CIT(A) also failed to appreciate that since the refund allowable to the appellant company had been wrongly withheld by the Department for the period of more than 5 years, the Department was liable to pay interest thereon

M/S DCM SHRIIRAM LTD.,,NEW DELHI vs. DCIT, NEW DELHI

In the result, both the appeals of the assessee are allowed

Bench: Ms. Sushma Chowla & Dr. B.R.R.Kumarआयकर अपील सं आयकर अपील सं. / Ita Nos. 5221 & 5222/Del/2016 आयकर अपील सं आयकर अपील सं िनधा"रण वष" / Assessment Years: 2005-06 & 2009-10 िनधा"रण वष" िनधा"रण वष" िनधा"रण वष" Dcm Shriram Ltd., 5Th Floor, Kanchenjunga Building, 18, Barakhamba Road, New Delhi-110001. …...........अपीलाथ"/Appellant Pan-Aaacd0097R Vs Dcit, Circle-7(1), …………. ू"यथ" / Respondent C.R.Building, New Delhi.

240 of the Act amount refundable consist of tax as well as interest allowable to an assessee. 4. That the CIT(A) also failed to appreciate that since the refund allowable to the appellant company had been wrongly withheld by the Department for the period of more than 5 years, the Department was liable to pay interest thereon

PRINCIPAL COMMISSIONER OF INCOME TAX, DELHI - 07 vs. M/S PUNJAB NATIONAL BANK (ERSTWHILE UNITED BANK OF INDIA)

In the result, the appeals filed by the

Bench: HON'BLE MR. JUSTICE MANMOHAN,HON'BLE MS. JUSTICE MANMEET PRITAM SINGH ARORA

240/- made by JAO under Section 40(a)(ia) of the Act. 12. In this regard, it is noted that the Tribunal has observed that the Respondent had duly deposited the Tax Deducted at Source (TDS

COMMISSIONER OF INCOME TAX-IX vs. RAMAN KHERA

The appeals are disposed of in the above terms but in the facts and

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

TDS was also deducted on that basis. The agreements purportedly entered into between each of the Assessees and UGHPL was a document drawn up four years ITA Nos. 653 of 2012, 476 of 2014, 19 of 2015, 21 of 2015 & 326 of 2015 Page 25 of 28 after they received the entire remuneration upfront in December 2005. Consequently, the Court

COMMISSIONER OF INCOME TAX-IX vs. RAMAN KHERA

The appeals are disposed of in the above terms but in the facts and

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

TDS was also deducted on that basis. The agreements purportedly entered into between each of the Assessees and UGHPL was a document drawn up four years ITA Nos. 653 of 2012, 476 of 2014, 19 of 2015, 21 of 2015 & 326 of 2015 Page 25 of 28 after they received the entire remuneration upfront in December 2005. Consequently, the Court