MR. SANJEEV GUPTA,NEW DELHI vs. ADDL.CIT, NEW DELHI

In the result, ground No. 3 and 4 With respect to the disallowance of export commission of the appeal of the assessee are allowed

Bench: Shri Amit Shukla & Shri Prashant Maharishisanjeev Gupta, Vs. Addl. Cit, E-31, Kamla Nagar, Range-20, New Delhi New Delhi Pan:Ahcpg7326A (Appellant) (Respondent)

32. So far as deeming fiction under section 9(1)(i) is concerned, it cannot be invoked in the present case since no part of the operations of the recipient's business, as commission agent, was carried out in India. Even though deeming fiction under section 9(1)(i) is triggered on the facts of this case, on account

MARUTI SUZUKI INDIA LTD.,NEW DELHI vs. JCIT (OSD), NEW DELHI

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

Bench: Sh. Amit Shukladr. B. R. R. Kumar(E-Court Module) Ita No. 2553/Del/2013 : Asstt. Year : 1999-00 Maruti Suzuki India Ltd., Vs Commissioner Of Income Tax Plot No. 1, Nelson Mandela Road, (Appeals)-Ix, Income Tax Vasant Kunj, New Delhi-110070 Office, Laxmi Nagar, New Delhi (Appellant) (Respondent) Pan No. Aaacm0829Q Ita No. 2641/Del/2013 : Asstt. Year : 1999-00 Dcit, Vs Maruti Suzuki India Ltd., Circle-6(1), Plot No. 1, Nelson Mandela Road, New Delhi Vasant Kunj, New Delhi-110070 (Appellant) (Respondent) Pan No. Aaacm0829Q Ita No. 468/Del/2014 : Asstt. Year : 1994-95 Maruti Suzuki India Ltd., Vs Jcit(Osd), Plot No. 1, Nelson Mandela Road, Circle-6(1), Vasant Kunj, New Delhi-110070 New Delhi (Appellant) (Respondent) Pan No. Aaacm0829Q

TDS, advance tax. The provisions of self-assessment tax are governed by Section 140A which is not covered by the provision u/s 244A(1)(a). The opening sentence of the Section 140A reads as under: (1) Where any tax is payable on the basis of any return required to be furnished u/s 139 --------- 19. This clearly gives a meaning that

DCIT, NEW DELHI vs. M/S MARUTI SUZUKI INDIA LTD.,, NEW DELHI

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

Bench: Sh. Amit Shukladr. B. R. R. Kumar(E-Court Module) Ita No. 2553/Del/2013 : Asstt. Year : 1999-00 Maruti Suzuki India Ltd., Vs Commissioner Of Income Tax Plot No. 1, Nelson Mandela Road, (Appeals)-Ix, Income Tax Vasant Kunj, New Delhi-110070 Office, Laxmi Nagar, New Delhi (Appellant) (Respondent) Pan No. Aaacm0829Q Ita No. 2641/Del/2013 : Asstt. Year : 1999-00 Dcit, Vs Maruti Suzuki India Ltd., Circle-6(1), Plot No. 1, Nelson Mandela Road, New Delhi Vasant Kunj, New Delhi-110070 (Appellant) (Respondent) Pan No. Aaacm0829Q Ita No. 468/Del/2014 : Asstt. Year : 1994-95 Maruti Suzuki India Ltd., Vs Jcit(Osd), Plot No. 1, Nelson Mandela Road, Circle-6(1), Vasant Kunj, New Delhi-110070 New Delhi (Appellant) (Respondent) Pan No. Aaacm0829Q

TDS, advance tax. The provisions of self-assessment tax are governed by Section 140A which is not covered by the provision u/s 244A(1)(a). The opening sentence of the Section 140A reads as under: (1) Where any tax is payable on the basis of any return required to be furnished u/s 139 --------- 19. This clearly gives a meaning that

MARUTI SUZUKI INDIA LTD.,NEW DELHI vs. DCIT, NEW DELHI

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

Bench: Sh. Amit Shukladr. B. R. R. Kumar(E-Court Module) Ita No. 2553/Del/2013 : Asstt. Year : 1999-00 Maruti Suzuki India Ltd., Vs Commissioner Of Income Tax Plot No. 1, Nelson Mandela Road, (Appeals)-Ix, Income Tax Vasant Kunj, New Delhi-110070 Office, Laxmi Nagar, New Delhi (Appellant) (Respondent) Pan No. Aaacm0829Q Ita No. 2641/Del/2013 : Asstt. Year : 1999-00 Dcit, Vs Maruti Suzuki India Ltd., Circle-6(1), Plot No. 1, Nelson Mandela Road, New Delhi Vasant Kunj, New Delhi-110070 (Appellant) (Respondent) Pan No. Aaacm0829Q Ita No. 468/Del/2014 : Asstt. Year : 1994-95 Maruti Suzuki India Ltd., Vs Jcit(Osd), Plot No. 1, Nelson Mandela Road, Circle-6(1), Vasant Kunj, New Delhi-110070 New Delhi (Appellant) (Respondent) Pan No. Aaacm0829Q

TDS, advance tax. The provisions of self-assessment tax are governed by Section 140A which is not covered by the provision u/s 244A(1)(a). The opening sentence of the Section 140A reads as under: (1) Where any tax is payable on the basis of any return required to be furnished u/s 139 --------- 19. This clearly gives a meaning that

DCIT, NEW DELHI vs. M/S. MARUTI SUZUKI INDIA LTD., NEW DELHI

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

Bench: Sh. Amit Shukladr. B. R. R. Kumar(E-Court Module) Ita No. 2553/Del/2013 : Asstt. Year : 1999-00 Maruti Suzuki India Ltd., Vs Commissioner Of Income Tax Plot No. 1, Nelson Mandela Road, (Appeals)-Ix, Income Tax Vasant Kunj, New Delhi-110070 Office, Laxmi Nagar, New Delhi (Appellant) (Respondent) Pan No. Aaacm0829Q Ita No. 2641/Del/2013 : Asstt. Year : 1999-00 Dcit, Vs Maruti Suzuki India Ltd., Circle-6(1), Plot No. 1, Nelson Mandela Road, New Delhi Vasant Kunj, New Delhi-110070 (Appellant) (Respondent) Pan No. Aaacm0829Q Ita No. 468/Del/2014 : Asstt. Year : 1994-95 Maruti Suzuki India Ltd., Vs Jcit(Osd), Plot No. 1, Nelson Mandela Road, Circle-6(1), Vasant Kunj, New Delhi-110070 New Delhi (Appellant) (Respondent) Pan No. Aaacm0829Q

TDS, advance tax. The provisions of self-assessment tax are governed by Section 140A which is not covered by the provision u/s 244A(1)(a). The opening sentence of the Section 140A reads as under: (1) Where any tax is payable on the basis of any return required to be furnished u/s 139 --------- 19. This clearly gives a meaning that

COMMISSIONER OF WEALTH TAX vs. S.S. AHLUWALIA

TDS and self assessment advance tax challans had not been attached etc. The respondent has not stated or averred that he had filed the requisite papers as mentioned in the said notice dated 6th July, 1988. However, there is no order of the income tax authority at Dimapur declaring the return to be void or invalid. 14. The assessment orders

COMMSSIONER OF INCOME TAX DELHI-XVI vs. S.S. AHLUWALIA

TDS and self assessment advance tax challans had not been attached etc. The respondent has not stated or averred that he had filed the requisite papers as mentioned in the said notice dated 6th July, 1988. However, there is no order of the income tax authority at Dimapur declaring the return to be void or invalid. 14. The assessment orders

COMMISSIONER OF INCOME TAX vs. BRIJBASI ART PRESS LIMITED

The appeals are dismissed

32. The third submission of Mr Vohra was that the provisions called for an equitable construction. He referred to the proviso to section 115 JAA(2) of the said act which stipulated that the no interest shall be payable on the tax credit allowed under subsection (1) of section 115JAA. In the context of this provision, he submitted that

C.I.T vs. INDIAN SUGAR EXIM CORPORATION LTD

The appeals are dismissed

32. The third submission of Mr Vohra was that the provisions called for an equitable construction. He referred to the proviso to section 115 JAA(2) of the said act which stipulated that the no interest shall be payable on the tax credit allowed under subsection (1) of section 115JAA. In the context of this provision, he submitted that

COMMISSIONER OF INCOME TAX vs. BIOSEED RESEARCH (INDIA) PVT. LIMITED

The appeals are dismissed

32. The third submission of Mr Vohra was that the provisions called for an equitable construction. He referred to the proviso to section 115 JAA(2) of the said act which stipulated that the no interest shall be payable on the tax credit allowed under subsection (1) of section 115JAA. In the context of this provision, he submitted that

CIT vs. OCL INDIA LTD

The appeals are dismissed

32. The third submission of Mr Vohra was that the provisions called for an equitable construction. He referred to the proviso to section 115 JAA(2) of the said act which stipulated that the no interest shall be payable on the tax credit allowed under subsection (1) of section 115JAA. In the context of this provision, he submitted that

COMMISSIONER OF INCOME TAX DELHI I vs. ANANT RAJ INDUSTRIES P. LTD.

The appeals are dismissed

32. The third submission of Mr Vohra was that the provisions called for an equitable construction. He referred to the proviso to section 115 JAA(2) of the said act which stipulated that the no interest shall be payable on the tax credit allowed under subsection (1) of section 115JAA. In the context of this provision, he submitted that

COMMISSIONER OF INCOME TAX DELHI I vs. ANANT RAJ INDUSTRIES P. LTD.

The appeals are dismissed

32. The third submission of Mr Vohra was that the provisions called for an equitable construction. He referred to the proviso to section 115 JAA(2) of the said act which stipulated that the no interest shall be payable on the tax credit allowed under subsection (1) of section 115JAA. In the context of this provision, he submitted that

CIT vs. NEGOLICE INDIA PVT LTD

The appeals are dismissed

32. The third submission of Mr Vohra was that the provisions called for an equitable construction. He referred to the proviso to section 115 JAA(2) of the said act which stipulated that the no interest shall be payable on the tax credit allowed under subsection (1) of section 115JAA. In the context of this provision, he submitted that

COMMISSIONER OF INCOME TAX DELHI I vs. CONTINENTAL PACKAGING P.LTD.

The appeals are dismissed

32. The third submission of Mr Vohra was that the provisions called for an equitable construction. He referred to the proviso to section 115 JAA(2) of the said act which stipulated that the no interest shall be payable on the tax credit allowed under subsection (1) of section 115JAA. In the context of this provision, he submitted that

COMMISSIONER OF INCOME TAX vs. C.J.INTERNATIONAL HOTELS LTD.

The appeals are dismissed

32. The third submission of Mr Vohra was that the provisions called for an equitable construction. He referred to the proviso to section 115 JAA(2) of the said act which stipulated that the no interest shall be payable on the tax credit allowed under subsection (1) of section 115JAA. In the context of this provision, he submitted that

THE COMMISSIONER OF INCOME TAX vs. NOKIA INDIA LTD.

The appeals are dismissed

32. The third submission of Mr Vohra was that the provisions called for an equitable construction. He referred to the proviso to section 115 JAA(2) of the said act which stipulated that the no interest shall be payable on the tax credit allowed under subsection (1) of section 115JAA. In the context of this provision, he submitted that

COMMISSIONER OF INCOME TAX DELHI II vs. LEROY SOMER & CONTROLS INDIA P.LTD.

The appeals are dismissed

32. The third submission of Mr Vohra was that the provisions called for an equitable construction. He referred to the proviso to section 115 JAA(2) of the said act which stipulated that the no interest shall be payable on the tax credit allowed under subsection (1) of section 115JAA. In the context of this provision, he submitted that