CAIRN ENERGY HYDROCARBON LTD. ,GURGAON vs. DCIT, INTL. TAXATION, CIRCLE, GURGAON

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

Bench: Sh. Saktijit Deydr. B. R. R. Kumarita No. 6357/Del/2013: Asstt. Year : 2010-11 Dcit, Vs Cairn Energy Hydrocarbon Ltd., C/O. Cairn India Ltd., 3Rd & 4Th Circle-3(2), International Taxation, Floor, Vipul Plaza, Suncity, Sector- New Delhi 54, Gurgaon (Appellant) (Respondent) Pan No. Aaccc3279J

32 was modified from the phrase "[For the purposes of this [clause]" to "For the purposes of this [sub-section]" by the Finance Act, 2002, w.e.f. 1-4-2003. 24. The case laws cited by the assessee do not pertain to Income Tax Act but to Evidence Act and Agriculture Income Tax Act and there may be ambiguity

DCIT, INTL. TAXATION, CIRCLE, GURGAON vs. CAIRN ENERGY HYDROCARBON LTD. , GURGAON

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

Bench: Sh. Saktijit Deydr. B. R. R. Kumarita No. 6357/Del/2013: Asstt. Year : 2010-11 Dcit, Vs Cairn Energy Hydrocarbon Ltd., C/O. Cairn India Ltd., 3Rd & 4Th Circle-3(2), International Taxation, Floor, Vipul Plaza, Suncity, Sector- New Delhi 54, Gurgaon (Appellant) (Respondent) Pan No. Aaccc3279J

32 was modified from the phrase "[For the purposes of this [clause]" to "For the purposes of this [sub-section]" by the Finance Act, 2002, w.e.f. 1-4-2003. 24. The case laws cited by the assessee do not pertain to Income Tax Act but to Evidence Act and Agriculture Income Tax Act and there may be ambiguity

DDIT, NEW DELHI vs. M/S. CAIRN ENERGY HYDROCARBONS LTD., GURGAON

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

Bench: Sh. Saktijit Deydr. B. R. R. Kumarita No. 6357/Del/2013: Asstt. Year : 2010-11 Dcit, Vs Cairn Energy Hydrocarbon Ltd., C/O. Cairn India Ltd., 3Rd & 4Th Circle-3(2), International Taxation, Floor, Vipul Plaza, Suncity, Sector- New Delhi 54, Gurgaon (Appellant) (Respondent) Pan No. Aaccc3279J

32 was modified from the phrase "[For the purposes of this [clause]" to "For the purposes of this [sub-section]" by the Finance Act, 2002, w.e.f. 1-4-2003. 24. The case laws cited by the assessee do not pertain to Income Tax Act but to Evidence Act and Agriculture Income Tax Act and there may be ambiguity

CAIRN ENERGY HYDROCARBONS LTD.,GURGAON vs. DDIT, NEW DELHI

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

Bench: Sh. Saktijit Deydr. B. R. R. Kumarita No. 6357/Del/2013: Asstt. Year : 2010-11 Dcit, Vs Cairn Energy Hydrocarbon Ltd., C/O. Cairn India Ltd., 3Rd & 4Th Circle-3(2), International Taxation, Floor, Vipul Plaza, Suncity, Sector- New Delhi 54, Gurgaon (Appellant) (Respondent) Pan No. Aaccc3279J

32 was modified from the phrase "[For the purposes of this [clause]" to "For the purposes of this [sub-section]" by the Finance Act, 2002, w.e.f. 1-4-2003. 24. The case laws cited by the assessee do not pertain to Income Tax Act but to Evidence Act and Agriculture Income Tax Act and there may be ambiguity

CAIRN ENERGY HYDROCARBON LTD. ,GURGAON vs. DCIT, INTL. TAXATION, CIRCLE, GURGAON

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

Bench: Sh. Saktijit Deydr. B. R. R. Kumarita No. 6357/Del/2013: Asstt. Year : 2010-11 Dcit, Vs Cairn Energy Hydrocarbon Ltd., C/O. Cairn India Ltd., 3Rd & 4Th Circle-3(2), International Taxation, Floor, Vipul Plaza, Suncity, Sector- New Delhi 54, Gurgaon (Appellant) (Respondent) Pan No. Aaccc3279J

32 was modified from the phrase "[For the purposes of this [clause]" to "For the purposes of this [sub-section]" by the Finance Act, 2002, w.e.f. 1-4-2003. 24. The case laws cited by the assessee do not pertain to Income Tax Act but to Evidence Act and Agriculture Income Tax Act and there may be ambiguity

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

TDS returns/statements prior to 01.06.2015. 32. We further find that in recent judgment dated 26.08.2016, the Hon'ble Karnataka High Court in Writ Appeal Nos. 2663-2674/2015(T-IT) in Fatheraj Singhvi v. Union of India [2016] 73 taxmann.com 252 has quashed the intimation issued under section

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

TDS returns/statements prior to 01.06.2015. 32. We further find that in recent judgment dated 26.08.2016, the Hon'ble Karnataka High Court in Writ Appeal Nos. 2663-2674/2015(T-IT) in Fatheraj Singhvi v. Union of India [2016] 73 taxmann.com 252 has quashed the intimation issued under section

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

TDS returns/statements prior to 01.06.2015. 32. We further find that in recent judgment dated 26.08.2016, the Hon'ble Karnataka High Court in Writ Appeal Nos. 2663-2674/2015(T-IT) in Fatheraj Singhvi v. Union of India [2016] 73 taxmann.com 252 has quashed the intimation issued under section

DCIT, INT. TAX. CIRCLE, GURGAON vs. CAIRN ENERGY HYDROCARBONS LIMITED, GURGAON

In the result, all the appeals preferred by the assessee as well as the Revenue

Bench: Shri Kul Bharat & Shri M. Balaganesh[A.Y.: 2015-16] & [A.Y.: 2016-17]

32 was modified from the phrase "[For the purposes of this [clause]" to "For the purposes of this [sub-section]" by the Finance Act, 2002, w.e.f. 1-4-2003. 34. The case laws cited by the assessee do not pertain to Income Tax Act but to Evidence Act and Agriculture Income Tax Act and there may be ambiguity

CAIRN ENERGY HYDROCARBON LTD. ,GURGAON vs. JCIT,(OSD) INTL. TAXATION, CIRCLE, GURGAON

In the result, all the appeals preferred by the assessee as well as the Revenue

Bench: Shri Kul Bharat & Shri M. Balaganesh[A.Y.: 2015-16] & [A.Y.: 2016-17]

32 was modified from the phrase "[For the purposes of this [clause]" to "For the purposes of this [sub-section]" by the Finance Act, 2002, w.e.f. 1-4-2003. 34. The case laws cited by the assessee do not pertain to Income Tax Act but to Evidence Act and Agriculture Income Tax Act and there may be ambiguity

M/S. HERO MOTOCORP LTD.,NEW DELHI vs. ADDL. CIT, NEW DELHI

In the result, the appeal of the Revenue is dismissed

Bench: Shri Sudhanshu Srivastava & Shri O.P. Kantassessment Year: 2005-06

32(1)(iia) of the Act, without appreciating that no such condition existed in the said section for entitling additional depreciation. 4. That the CIT (A) erred on facts and in law in sustaining disallowance of portfolio management expenditure of Rs. 27,68,039 on the ground that the same related to investment activity of the appellant. 4.1 That

DCIT, NEW DELHI vs. M/S. HERO HONDA MOTORS LTD., NEW DELHI

In the result, the appeal of the Revenue is dismissed

Bench: Shri Sudhanshu Srivastava & Shri O.P. Kantassessment Year: 2005-06

32(1)(iia) of the Act, without appreciating that no such condition existed in the said section for entitling additional depreciation. 4. That the CIT (A) erred on facts and in law in sustaining disallowance of portfolio management expenditure of Rs. 27,68,039 on the ground that the same related to investment activity of the appellant. 4.1 That

SERCO INDIA PVT. LTD.,PUNE vs. DCIT, GURGAON

In the result, appeal filed by the Assessee stands allowed

Bench: Shrianil Chaturvedi, Am & Shri N. K. Choudhry, Jm

TDS under section 192 of the Act, hence, cannot be treated as FTS under section 9(1)(vii) of the Act and Article 12 of the tax treaty. Accordingly, there was no obligation on the part of the Assessee to withhold tax at source under section 195 of the Act. Resultantly, we delete the addition made by the Assessing Officer

DHARAMVIR KHOSLA ,. vs. DCIT CC-5, NEW DELHI , .

The appeals are allowed for statistical purposes and ld

32(1)(iia) of the Act.\n3.1 Subsequently, search and seizure operation was carried out on\n22.10.2020 on Shri Imtiyaz Ahmad Shah for which the case of assessee was\nopened vide notice u/s 153C of the Act, in response to which assessee filed\nreturn of income on 01.09.2022 declaring total income at Rs.98,25,914/- as\nwas filed in original

M/S. ARICENT TECHNOLOGIES (HOLDINGS) LTD.,NEW DELHI vs. ADDL. CIT, NEW DELHI

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

Bench: Ms. Sushma Chowla & Shri Prashant Maharishi

32(1 )(ii) of the Act and therefore, the said amount ought to be reduced while computing the taxable income of the appellant. 3. That the DRP/ assessing officer erred on facts and in law in making addition of Rs.2,65,46,256 allegedly holding that the appellant had received interest under section 244A of the Act on the income

ARIVENT TECHNOLOGIES HOLDINGS LTD.,NEW DELHI vs. DCIT, NEW DELHI

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

Bench: Ms. Sushma Chowla & Shri Prashant Maharishi

32(1 )(ii) of the Act and therefore, the said amount ought to be reduced while computing the taxable income of the appellant. 3. That the DRP/ assessing officer erred on facts and in law in making addition of Rs.2,65,46,256 allegedly holding that the appellant had received interest under section 244A of the Act on the income

ARICENT TECHNOLOGIES (HOLDINGS) LTD.,NEW DELHI vs. DCIT, CIRCLE- 3(1), NEW DELHI

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

Bench: Ms. Sushma Chowla & Shri Prashant Maharishi

32(1 )(ii) of the Act and therefore, the said amount ought to be reduced while computing the taxable income of the appellant. 3. That the DRP/ assessing officer erred on facts and in law in making addition of Rs.2,65,46,256 allegedly holding that the appellant had received interest under section 244A of the Act on the income

ADDL. CIT, SPECIAL RANGE- 1 , NEW DELHI vs. ARICENT TECHNOLOGIES (HOLDINGS) LTD., NEW DELHI

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

Bench: Ms. Sushma Chowla & Shri Prashant Maharishi

32(1 )(ii) of the Act and therefore, the said amount ought to be reduced while computing the taxable income of the appellant. 3. That the DRP/ assessing officer erred on facts and in law in making addition of Rs.2,65,46,256 allegedly holding that the appellant had received interest under section 244A of the Act on the income