JCIT(OSD), RANGE-10, NEW DELHI , C.R. BUILDING ITO vs. RURAL ELECTRIFICATION CORPORATION LTD. , KASTURBA NAGAR

In the result, appeals filed by the revenue in the AY 2020-21 and AY\n2021-22 are dismissed

TDS) under Section 195 of the Income-tax Act, 1961, as it deemed to\naccrue or arise in India. It is not relevant to the present issue.\n12. Further as held in the case of Meghalaya Steels Ltd (supra), the Hon'ble\nSupreme Court explained the distinction between the terms 'derived from'\n27\nITA Nos.319 & 320/Del/2025\nITA Nos.577& 578/Del/2025\nITA

REC LIMITED,NEW DELHI vs. ACIT-10 (OSD), DELHI, NEW DELHI

TDS) under Section 195 of the Income-tax Act, 1961, as it deemed to\naccrue or arise in India. It is not relevant to the present issue.\n12. Further as held in the case of Meghalaya Steels Ltd (supra), the Hon'ble\nSupreme Court explained the distinction between the terms 'derived from'\n27\nand 'attributable to'. Further they held that

REC LIMITED,NEW DELHI vs. ACIT-10 (OSD), DELHI, NEW DELHI

TDS) under Section 195 of the Income-tax Act, 1961, as it deemed to\naccrue or arise in India. It is not relevant to the present issue.\n12. Further as held in the case of Meghalaya Steels Ltd (supra), the Hon'ble\nSupreme Court explained the distinction between the terms 'derived from'\n27\nITA Nos.319 & 320/Del/2025\nITA Nos.577& 578/Del/2025\nITA

JCIT(OSD), RANGE-10, NEW DELHI , CR BUILDING ITO vs. RURAL ELECTRIFICATION CORPORATION LTD. , KASTURBA NAGAR

TDS) under Section 195 of the Income-tax Act, 1961, as it deemed to\naccrue or arise in India. It is not relevant to the present issue.\n12. Further as held in the case of Meghalaya Steels Ltd (supra), the Hon'ble\nSupreme Court explained the distinction between the terms 'derived from'\nand 'attributable to'. Further they held that

JCIT(OSD), RANGE-10, NEW DELHI , C.R. BUILDING ITO vs. RURAL ELECTRIFICATION CORPORATION LTD., KASTURBA NAGAR

TDS) under Section 195 of the Income-tax Act, 1961, as it deemed to\naccrue or arise in India. It is not relevant to the present issue.\n12. Further as held in the case of Meghalaya Steels Ltd (supra), the Hon'ble\nSupreme Court explained the distinction between the terms 'derived from'\nand 'attributable to'. Further they held that

A2Z INFRASERVICES LIMITED,HARYANA vs. DCIT CENTRAL CIRCLE 27, DELHI

In the result, appeals of the assessee are partly allowed as

Bench: Shri Challa Nagendra Prasad & Shri S Rifaur Rahmanिनधा"रणवष"/Assessment Year: 2017-18 बनाम A2Z Infra Services Limited Dcit, O-116, 1St Floor, Dlf Shopping Mall, Vs. Central Circle-2, Arjun Nagar, Dlf Phase-1, Shankar Chowk, Phase-V, Gurgaon, Haryana. Udyog Vihar, Sector-19, Gurugram, Haryana. Pan No.Aahca0139L अपीलाथ" Appellant ""यथ"/Respondent & िनधा"रणवष"/Assessment Year: 2019-20 बनाम A2Z Infra Services Limited Dcit, O-116, 1St Floor, Dlf Shopping Mall, Vs. Central Circle-27, Arjun Marg, Dlf Qe S.O., New Delhi. Sikanderpur, Gurgaon, Haryana. Pan No.Aahca0139L अपीलाथ" Appellant ""यथ"/Respondent

v) disallowance of deduction claimed under [section 10AA or under any of the provisions of Chapter VI-A under the heading "C.— Deductions in respect of certain incomes", if] the return is furnished beyond the due date specified under sub-section (1) of section 139; or (vi) addition of income appearing in Form 26AS or Form 16A or Form

A2Z INFRASERVICES LIMITED,GURGAON vs. DCIT, CENTRAL CIRCLE-2, FARIDABAD

In the result, appeals of the assessee are partly allowed as

Bench: Shri Challa Nagendra Prasad & Shri S Rifaur Rahmanिनधा"रणवष"/Assessment Year: 2017-18 बनाम A2Z Infra Services Limited Dcit, O-116, 1St Floor, Dlf Shopping Mall, Vs. Central Circle-2, Arjun Nagar, Dlf Phase-1, Shankar Chowk, Phase-V, Gurgaon, Haryana. Udyog Vihar, Sector-19, Gurugram, Haryana. Pan No.Aahca0139L अपीलाथ" Appellant ""यथ"/Respondent & िनधा"रणवष"/Assessment Year: 2019-20 बनाम A2Z Infra Services Limited Dcit, O-116, 1St Floor, Dlf Shopping Mall, Vs. Central Circle-27, Arjun Marg, Dlf Qe S.O., New Delhi. Sikanderpur, Gurgaon, Haryana. Pan No.Aahca0139L अपीलाथ" Appellant ""यथ"/Respondent

v) disallowance of deduction claimed under [section 10AA or under any of the provisions of Chapter VI-A under the heading "C.— Deductions in respect of certain incomes", if] the return is furnished beyond the due date specified under sub-section (1) of section 139; or (vi) addition of income appearing in Form 26AS or Form 16A or Form

YOSHIO KUBO vs. COMMISSIONER OF INCOME TAX

The appeals are disposed of accordingly

36. The Tribunal held, after noticing the nature of the scheme that before attaining the age of 65 or before death, neither the assessee nor his survivors were entitled to get any benefit from the scheme and at the most the employee only had a contingent right which cannot attract Section 17(2)(v) of the Act. The Tribunal also

YOSHIO KUBO vs. COMMISSIONER OF INCOME TAX

The appeals are disposed of accordingly

36. The Tribunal held, after noticing the nature of the scheme that before attaining the age of 65 or before death, neither the assessee nor his survivors were entitled to get any benefit from the scheme and at the most the employee only had a contingent right which cannot attract Section 17(2)(v) of the Act. The Tribunal also

YOSHIO KUBO vs. COMMISSIONER OF INCOME TAX

The appeals are disposed of accordingly

36. The Tribunal held, after noticing the nature of the scheme that before attaining the age of 65 or before death, neither the assessee nor his survivors were entitled to get any benefit from the scheme and at the most the employee only had a contingent right which cannot attract Section 17(2)(v) of the Act. The Tribunal also

KOTA TRUCKS P.LTD,DELHI vs. ACIT, CIRCLE 14(2), NEW DELHI

In the result, appeals of the assessee are partly allowed as indicated above

Bench: Shri C.N. Prasad & Shri M. Balaganesh[Assessment Year: 2018-19] Kota Trucks P. Ltd. Vs. Acit Bg-223, Sanjay Gandhi Circle -14(2) Transport Nagar, Gt New Delhi Karnal Road, New Delhi- 110042 Pan No.Aadck3550H Appellant Respondent Appellant Sh. Pratap Gupta, Ca (Virtual) Respondent Sh. Om Prakash, Sr. Dr

v) disallowance of deduction claimed under [section 10AA or under any of the provisions of Chapter VI-A under the heading "C.— Deductions in respect of certain incomes", if] the return is furnished beyond the due date specified under sub-section (1) of section 139; or (vi) addition of income appearing in Form 26AS or Form 16A or Form

M/S. PTC INDIA FINANCIAL SERVICES LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result, the appeals of the assessee for AY 2013-14 and 2014-15

Bench: Shri N.K. Billaiya & Ms. Astha Chandraasstt. Year 2013-14 & Asstt. Year 2014-15

TDS disallowance under section 40(a)(ia) could not be made. The correct course of action would be to invoke section 201 of the Act. 30.5 On consideration of the rival submissions, we are of the view that there is no infirmity in the order of the Ld. CIT(A) which is duly supported by the decisions (supra

PTC INDIA FINANCIAL SERVICES LTD.,NEW DELHI vs. DCIT, CIRCLE- 19(2), NEW DELHI

In the result, the appeals of the assessee for AY 2013-14 and 2014-15

Bench: Shri N.K. Billaiya & Ms. Astha Chandraasstt. Year 2013-14 & Asstt. Year 2014-15

TDS disallowance under section 40(a)(ia) could not be made. The correct course of action would be to invoke section 201 of the Act. 30.5 On consideration of the rival submissions, we are of the view that there is no infirmity in the order of the Ld. CIT(A) which is duly supported by the decisions (supra

ADDL. CIT, SPECIAL RANGE- 7, NEW DELHI vs. PTC INDIA FINANCIAL SERVICES LTD, NEW DELHI

In the result, the appeals of the assessee for AY 2013-14 and 2014-15

Bench: Shri N.K. Billaiya & Ms. Astha Chandraasstt. Year 2013-14 & Asstt. Year 2014-15

TDS disallowance under section 40(a)(ia) could not be made. The correct course of action would be to invoke section 201 of the Act. 30.5 On consideration of the rival submissions, we are of the view that there is no infirmity in the order of the Ld. CIT(A) which is duly supported by the decisions (supra

ACIT, NEW DELHI vs. M/S. PTC INDIA FINANCIAL SERVICES LTD., NEW DELHI

In the result, the appeals of the assessee for AY 2013-14 and 2014-15

Bench: Shri N.K. Billaiya & Ms. Astha Chandraasstt. Year 2013-14 & Asstt. Year 2014-15

TDS disallowance under section 40(a)(ia) could not be made. The correct course of action would be to invoke section 201 of the Act. 30.5 On consideration of the rival submissions, we are of the view that there is no infirmity in the order of the Ld. CIT(A) which is duly supported by the decisions (supra

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

v) Tax determined as a result to Rs. 3,20,000 appellate order under section 250 on 30-9-1990 (vi) Refund due as a result of appeal Rs. 80,000 (vii) Date of grant of actual refund 31-10-1990 (viii) Interest payable by the Department @ 1.5% per month for 6 Rs. 7,200 months (1

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

v) Tax determined as a result to Rs. 3,20,000 appellate order under section 250 on 30-9-1990 (vi) Refund due as a result of appeal Rs. 80,000 (vii) Date of grant of actual refund 31-10-1990 (viii) Interest payable by the Department @ 1.5% per month for 6 Rs. 7,200 months (1

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

v) Tax determined as a result to Rs. 3,20,000 appellate order under section 250 on 30-9-1990 (vi) Refund due as a result of appeal Rs. 80,000 (vii) Date of grant of actual refund 31-10-1990 (viii) Interest payable by the Department @ 1.5% per month for 6 Rs. 7,200 months (1