HERO FINCORP LIMITED,NEW DELHI vs. ACIT, CIRCLE 11(1), DELHI, C.R. BUILDING

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

2)(viib) of the Act were, both on facts and in law, not\n3\nITA No. 2542/Del/2024\napplicable and hence, there was no warrant to make addition of\nRs.418,66,34,625.”\n3.\nGround nos. 1 to 7 of the appeal are against the disallowance of provisions for collection\ncharges amounting to Rs.9,75,00,000/-. The AO noted that

INDIA TODAY ONLINE PVT. LTD.,NEW DELHI vs. ITO, WARD- 12(2), NEW DELHI

In the result both the appeals of the assessee are allowed

Bench: Shri Amit Shukla & Shri L.P. Sahuita Nos. 6453 & 6454/Del/2018 Assessment Years 2013-14 & 2014-15

TDS Payable 4.363.060 4.363.060 Other Current Liabilities 583.059 583.059 Provision for Interest on Loan 39.267.539 39.267.539 Liabilities (B) 44,483,658 44,483,658 C=(A+B) 1,243,424,451 2,984,397,259 Unsecured Loan (Thomson Press India Limited) 819.187,525 819,187,525 Total Firm Value 4.24.236.926 2.165.749.734 Net Finn Value 424,236,926 2

INDIA TODAY ONLINE PVT. LTD.,NEW DELHI vs. ITO, WARD- 12(2), NEW DELHI

In the result both the appeals of the assessee are allowed

Bench: Shri Amit Shukla & Shri L.P. Sahuita Nos. 6453 & 6454/Del/2018 Assessment Years 2013-14 & 2014-15

TDS Payable 4.363.060 4.363.060 Other Current Liabilities 583.059 583.059 Provision for Interest on Loan 39.267.539 39.267.539 Liabilities (B) 44,483,658 44,483,658 C=(A+B) 1,243,424,451 2,984,397,259 Unsecured Loan (Thomson Press India Limited) 819.187,525 819,187,525 Total Firm Value 4.24.236.926 2.165.749.734 Net Finn Value 424,236,926 2

YOSHIO KUBO vs. COMMISSIONER OF INCOME TAX

The appeals are disposed of accordingly

TDS amounts deposited with the income tax authorities, by the assessee‘s employers. These excess amount, according to the Assessing Officer, were not exempt under Section 10(5B) but were taxable income of the assessee, as ―disguised perquisites‖. The assessees contended that refund issued in their name could not be treated as a perquisite, as neither any benefit accrued

YOSHIO KUBO vs. COMMISSIONER OF INCOME TAX

The appeals are disposed of accordingly

TDS amounts deposited with the income tax authorities, by the assessee‘s employers. These excess amount, according to the Assessing Officer, were not exempt under Section 10(5B) but were taxable income of the assessee, as ―disguised perquisites‖. The assessees contended that refund issued in their name could not be treated as a perquisite, as neither any benefit accrued

YOSHIO KUBO vs. COMMISSIONER OF INCOME TAX

The appeals are disposed of accordingly

TDS amounts deposited with the income tax authorities, by the assessee‘s employers. These excess amount, according to the Assessing Officer, were not exempt under Section 10(5B) but were taxable income of the assessee, as ―disguised perquisites‖. The assessees contended that refund issued in their name could not be treated as a perquisite, as neither any benefit accrued

ADIT, DEHRADUN vs. M/S. HALLIBURTON OFFSHORE SERVICES INC., DEHRADUN

Bench: Shri I.C.Sudhir & Shri Prashant Maharishiadit, Halliburton Offshore Services International Taxation, Inc. , Vs. 13-A,Subhash Road, C/O. Nangia & Company, Ca, Aayakar Bhawan, 75/7, Rajpur Road, Dehradun Dehradun Pan:Aaach5154M (Appellant) (Respondent) Halliburton Offshore Services Addl. Cit, Inc. , International Taxation, Vs. C/O. Nangia & Company, Ca, Subhash Road, Suite-4A, Plaza M-6, Jasola, Dehradun New Delhi Pan:Aaach5154M (Appellant) (Respondent) Halliburton Offshore Services Inc. , Adit, C/O. Nangia & Company, Ca, International Taxation, Vs. Suite-4A, Plaza M-6, Jasola, 13-A,Subhash Road, New Delhi Aayakar Bhawan, Pan:Aaach5154M Dehradun (Appellant) (Respondent) Halliburton Offshore Services Inc. Vs Ddit (International Taxation)

54 of List I and Entry 22 of Halliburton Offshore Services Inc. VS DDIT (International taxation) ITA No.1332/DEL/2012 A.Y.: 2005-06 ITA No 5284/Del/2010 A Y 2007-08 IAT no 242/Del/2010 A Y 2008-09 ITA No 6161/Del/2012, 6003/DEL/2012 CO 21/Del/2013 A Y 2009-10 ITA No 5936/DEL/2013 & CO No 148/Del/2014 A Y 2010-11 9 List

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(1), MEERUT, MEERUT vs. PREM SAPRA, NEW DELHI

The appeal of the revenue is dismissed

Bench: Smt. Annapurna Gupta & Ms. Madhumita Royassessment Year: 2021-22

section 54 of the Act except to the extent that the assessee submitted a sale agreement which is not registered, agreement may be not completed/obeyed fully or revoked in future. Thus Ld. AO denied the exemption of Rs. 2,81,58,300/- u/s 54 of the Act solely on this reasoning and has assessed the income of the 3 ACIT

DCIT, CIRCLE- 62(1), NEW DELHI vs. RAMESH KUMAR PABBI, NEW DELHI

In the result, appeal of the Revenue is dismissed

Bench: Sh. Anil Chaturvedi & Ms. Suchitra Kamble(Through Video Conferencing) Assessment Year : 2013-14 Dcit Vs. Ramesh Kumar Pabbi Circle – 62(1), A-41, Phase-Ii, New Delhi Mayapuri Industrial Area, New Delhi-110017 Pan – Aanpp 5995 Q (Appellant) (Respondent) Assessee By Shri Sohail Malik, Sr.D.R. Revenue By Shri Lalit Mohan, Adv. Date Of Hearing: 16/03/2021 Date Of Pronouncement: 16/03/2021 Order Per Anil Chaturvedi, Am:

TDS on payment of Rs.3,93,035/- towards testing charges payable to RITES Ltd as mandated u/s 194J of the I.T. Act, 1961. (III) The appellant craves leave to add, to alter or amend any ground of appeal raised above at the time of hearing. 4. First ground is with respect to the deleting of addition of deemed dividend made

HERO MOTOCORP LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result appeal No. 2424/Del/ 2015 filed by the revenue in assessment year 2010-11 is partly allowed

Bench: Shri R. K. Panda & Ms Suchitra Kamble

section 194C was amended by the Finance (2) Act, 2009 w.e.f. 1.10.2009, whereby the definition of “work” was enlarged to include contract for manufacturing or supplying a product according to the requirement or specification of a customer by using material purchased from such customer. The said amendment also provided that contract for carrying out work shall not include contract

HERO MOTOCORP LTD.,,NEW DELHI vs. ADDL.CIT, RANGE-11, NEW DELHI

In the result ground No

Bench: Shri R. K. Panda & Ms Suchitra Kamblei.T.A. No. 6990/Del/2017 (A.Y 2013-14)

2 - Grant of License and Exclusivity ii) ARTICLE 3-No sublicense iii) ARTICLE 9 - Use and Disclosure of Technical Information iv) ARTICLE 13 - Terms of agreement (upto 30.06.2007) v) ARTICLE 21/22 Termination/Effect of Expiry and Termination vi) ARTICLE 25/26 Certain Prohibitions/Maintenance of Secrecy To the same effect are the following clauses placing restrictions on use of knowhow by the assessee

RAJNI KUMAR WIFE OF SHRI BRIG. NARENDER KUMAR H.NO.394, SECTOR-21, GURGAONN,GURGAON vs. THE INCOME TAX OFFICER WARD-3(1), GURGAON, GURGAON

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

Bench: Shri S.Rifaur Rahman & Shri Vimal Kumarrajni Kumar, Vs. Ito, Ward 3 (1), W/O Shri Brig. Narender Kumar, Gurgaon. House No.394, Sector 21, Gurgaon – 122 001 (Haryana). (Pan : Ayypk1781A) (Appellant) (Respondent) Assessee By : Shri Sudhir Sehgal, Advocate Revenue By : Shri Rajesh Kumar Dhanesta, Sr. Sr Date Of Hearing : 19.08.2025 Date Of Order : 17.09.2025 O R D E R Per S.Rifaur Rahman,Am: 1. The Assessee Has Filed Appeal Against The Order Of The Learned Commissioner Of Income-Tax (Appeals)/National Faceless Appeal Centre (Nfac), Delhi [“Ld. Cit(A)”, For Short] Dated 27.09.2023 For The Assessment Year 2017-18 & The Assessment Order Was Passed Under Section 143(3) R.W.S. 263 Of The Income-Tax Act, 1961 (For Short ‘The Act’).

section 143(3) r.w.s. 263 of the Income-tax Act, 1961 (for short ‘the Act’). 2 2. Brief facts of the case are, assessee filed her return of income for the AY 2017-18 on 17.07.2017 declaring total income of Rs.2,95,190/-. The case was selected for scrutiny through CASS to verify the deductions/exemption from capital gains and investment

INFANT JESUS SCHOOL,MUZAFFARNAGAR vs. ACIT, TDS(CPC), MUZAFFARNAGAR

In the result, all appeals of different assesses are allowed

Bench: Ms. Sushma Chowla, Vp & Dr. B.R.R. Kumar, Am [Through Video Conferencing]

2), it can be said that a particular set up for imposition and the payment of fee under Section 234E was provided but, it did not provide for making of demand of such fee under Section 200A payable under Section 234E. Hence, considering the aforesaid peculiar facts and circumstances, we are unable to accept the contention of the learned counsel

SIPL TEXTILES PVT. LTD.,NEW DELHI vs. ACIT, CIRCLE- 77(1), NEW DELHI

In the result, all appeals of different assesses are allowed

Bench: Ms. Sushma Chowla, Vp & Dr. B.R.R. Kumar, Am [Through Video Conferencing]

2), it can be said that a particular set up for imposition and the payment of fee under Section 234E was provided but, it did not provide for making of demand of such fee under Section 200A payable under Section 234E. Hence, considering the aforesaid peculiar facts and circumstances, we are unable to accept the contention of the learned counsel

INFANT JESUS SCHOOL,MUZAFFARNAGAR vs. ACIT, TDS(CPC), MUZAFFARNAGAR

In the result, all appeals of different assesses are allowed

Bench: Ms. Sushma Chowla, Vp & Dr. B.R.R. Kumar, Am [Through Video Conferencing]

2), it can be said that a particular set up for imposition and the payment of fee under Section 234E was provided but, it did not provide for making of demand of such fee under Section 200A payable under Section 234E. Hence, considering the aforesaid peculiar facts and circumstances, we are unable to accept the contention of the learned counsel

INFANT JESUS SCHOOL,MUZAFFARNAGAR vs. ACIT, TDS(CPC), MUZAFFARNAGAR

In the result, all appeals of different assesses are allowed

Bench: Ms. Sushma Chowla, Vp & Dr. B.R.R. Kumar, Am [Through Video Conferencing]

2), it can be said that a particular set up for imposition and the payment of fee under Section 234E was provided but, it did not provide for making of demand of such fee under Section 200A payable under Section 234E. Hence, considering the aforesaid peculiar facts and circumstances, we are unable to accept the contention of the learned counsel

INFANT JESUS SCHOOL,MUZAFFARNAGAR vs. ACIT, TDS(CPC), MUZAFFARNAGAR

In the result, all appeals of different assesses are allowed

Bench: Ms. Sushma Chowla, Vp & Dr. B.R.R. Kumar, Am [Through Video Conferencing]

2), it can be said that a particular set up for imposition and the payment of fee under Section 234E was provided but, it did not provide for making of demand of such fee under Section 200A payable under Section 234E. Hence, considering the aforesaid peculiar facts and circumstances, we are unable to accept the contention of the learned counsel

DAR LANDMARKS P.LTD,NOID vs. ACIT, TDS, GHAZIABAD

In the result, all appeals of different assesses are allowed

Bench: Ms. Sushma Chowla, Vp & Dr. B.R.R. Kumar, Am [Through Video Conferencing]

2), it can be said that a particular set up for imposition and the payment of fee under Section 234E was provided but, it did not provide for making of demand of such fee under Section 200A payable under Section 234E. Hence, considering the aforesaid peculiar facts and circumstances, we are unable to accept the contention of the learned counsel