BCL SECURITIES PVT LTD,GURGAON vs. ACIT CIRCLE-4(1), NEW DELHI

In the result, the appeal of the assessee is allowed

Bench: Shri Amit Shukla & Shri Prashant Maharishi

section 36(2) which provides that no deduction on account of bad debts shall be allowed unless such bad debt or part thereof has been taken into account in computing the income of the assessee of the previous year in which amount of such debts or part thereof is written off or of an earlier previous year, or represents money

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

vii) and\nsection 36(1) (viia) (c) of the Act i.e., deductions under both section is\nindependent on each other?\"\n4. Since the issue raised by the revenue and assessee relating to the issue of\ndeduction claimed u/s 36(1)(viii) are common, the same are adjudicated\ntogether below.\n5. Ground Nos.1 & 2 raised by the assessee are general

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

vii) and\nsection 36(1) (viia) (c) of the Act i.e., deductions under both section is\nindependent on each other?\"\n4. Since the issue raised by the revenue and assessee relating to the issue of\ndeduction claimed u/s 36(1)(viii) are common, the same are adjudicated\ntogether below.\n5. Ground Nos.1 & 2 raised by the assessee are general

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

vii) and\nsection 36(1) (viia) (c) of the Act i.e., deductions under both section is\nindependent on each other?\"\n4. Since the issue raised by the revenue and assessee relating to the issue of\ndeduction claimed u/s 36(1)(viii) are common, the same are adjudicated\ntogether below.\n5. Ground Nos.1 & 2 raised by the assessee are general

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

vii) and\nsection 36(1) (viia) (c) of the Act i.e., deductions under both section is\nindependent on each other?\"\n4. Since the issue raised by the revenue and assessee relating to the issue of\ndeduction claimed u/s 36(1)(viii) are common, the same are adjudicated\ntogether below.\n5. Ground Nos.1 & 2 raised by the assessee are general

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

vii) and\nsection 36(1) (viia) (c) of the Act i.e., deductions under both section is\nindependent on each other?\"\n4. Since the issue raised by the revenue and assessee relating to the issue of\ndeduction claimed u/s 36(1)(viii) are common, the same are adjudicated\ntogether below.\n5. Ground Nos.1 & 2 raised by the assessee are general

DIRECTOR OF INCOME TAX DELHI vs. M/S LUFTHANSA CARGO INDIA P .

Bench: HON'BLE MR. JUSTICE S. RAVINDRA BHAT,HON'BLE MR. JUSTICE R.K.GAUBA

TDS. With reference to payments made to residents of UK and USA, the CIT (A) held that they were not in the nature of „fees for technical or included services‟ under Article 12 of the DTAA read with the Memorandum of Understanding with USA which equally applied to the UK Treaty. Payments made to residents of USA and UK were

DIRECTOR OF INCOME TAX DELHI vs. M/S LUFTHANSA CARGO INDIA P .

TDS. With reference to payments made to residents of UK and USA, the CIT (A) held that they were not in the nature of „fees for technical or included services‟ under Article 12 of the DTAA read with the Memorandum of Understanding with USA which equally applied to the UK Treaty. Payments made to residents of USA and UK were

ITO (TDS), NEW DELHI vs. BHARTI AIRTEL LTD., GURGAON

In the result, all the Appeals of the Assessee are allowed and all the Revenue’s Appeals are dismissed

Bench: Shri H.S. Sidhu & Shri J. Sudhakar Reddy

TDS) vs. Bharti Airtel Ltd.] held that call charges received from telecom operators from firms and companies subscribing to cellular mobile services provided by them do not come within the definition of technical services u/s. 194J read with section 9(1)(vii) Expln. 2, as it a mere collection of Fee for use of standard facility provided to all those

BHARTI AIRTEL LTD.,GURGAON vs. ITO (TDS), NEW DELHI

In the result, all the Appeals of the Assessee are allowed and all the Revenue’s Appeals are dismissed

Bench: Shri H.S. Sidhu & Shri J. Sudhakar Reddy

TDS) vs. Bharti Airtel Ltd.] held that call charges received from telecom operators from firms and companies subscribing to cellular mobile services provided by them do not come within the definition of technical services u/s. 194J read with section 9(1)(vii) Expln. 2, as it a mere collection of Fee for use of standard facility provided to all those

BHARTI AIRTEL LTD.,GURGAON vs. ITO (TDS), NEW DELHI

In the result, all the Appeals of the Assessee are allowed and all the Revenue’s Appeals are dismissed

Bench: Shri H.S. Sidhu & Shri J. Sudhakar Reddy

TDS) vs. Bharti Airtel Ltd.] held that call charges received from telecom operators from firms and companies subscribing to cellular mobile services provided by them do not come within the definition of technical services u/s. 194J read with section 9(1)(vii) Expln. 2, as it a mere collection of Fee for use of standard facility provided to all those

BHARTI AIRTEL LTD.,GURGAON vs. ITO (TDS), NEW DELHI

In the result, all the Appeals of the Assessee are allowed and all the Revenue’s Appeals are dismissed

Bench: Shri H.S. Sidhu & Shri J. Sudhakar Reddy

TDS) vs. Bharti Airtel Ltd.] held that call charges received from telecom operators from firms and companies subscribing to cellular mobile services provided by them do not come within the definition of technical services u/s. 194J read with section 9(1)(vii) Expln. 2, as it a mere collection of Fee for use of standard facility provided to all those

ITO (TDS), NEW DELHI vs. BHARTI AIRTEL LTD., GURGAON

In the result, all the Appeals of the Assessee are allowed and all the Revenue’s Appeals are dismissed

Bench: Shri H.S. Sidhu & Shri J. Sudhakar Reddy

TDS) vs. Bharti Airtel Ltd.] held that call charges received from telecom operators from firms and companies subscribing to cellular mobile services provided by them do not come within the definition of technical services u/s. 194J read with section 9(1)(vii) Expln. 2, as it a mere collection of Fee for use of standard facility provided to all those

BHARTI AIRTEL LTD.,GURGAON vs. ITO (TDS), NEW DELHI

In the result, all the Appeals of the Assessee are allowed and all the Revenue’s Appeals are dismissed

Bench: Shri H.S. Sidhu & Shri J. Sudhakar Reddy

TDS) vs. Bharti Airtel Ltd.] held that call charges received from telecom operators from firms and companies subscribing to cellular mobile services provided by them do not come within the definition of technical services u/s. 194J read with section 9(1)(vii) Expln. 2, as it a mere collection of Fee for use of standard facility provided to all those

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

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 (1-5-1990-31-10-1990), i.e., @ Rs. 9% on 80,000 30. This example illustrates payment of interest on the refund from the date of payment of tax (01.05.1990) to the date of issue

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

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 (1-5-1990-31-10-1990), i.e., @ Rs. 9% on 80,000 30. This example illustrates payment of interest on the refund from the date of payment of tax (01.05.1990) to the date of issue

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

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 (1-5-1990-31-10-1990), i.e., @ Rs. 9% on 80,000 30. This example illustrates payment of interest on the refund from the date of payment of tax (01.05.1990) to the date of issue

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

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 (1-5-1990-31-10-1990), i.e., @ Rs. 9% on 80,000 30. This example illustrates payment of interest on the refund from the date of payment of tax (01.05.1990) to the date of issue