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, which has not been made by the Assessee. The Ld. AO is accordingly directed to disallow the aforesaid expenditure under section 40a(i) of the Act. 9.3 Consequently, the ld. DRP directed the AO to complete the assessment as per the above directions and to incorporate the reasons given by the DRP iro various objections at the appropriate places

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

Section 127 of the Act for transfer of respondent’s case from ITO, Dimapur to the AO, Delhi to which response/objection was filed vide letter dated 5th January, 1989. The respondent assessee had objected to transfer of the 2014:DHC:1423-DB ITA 255/2002 + connected Page 6 of 61 case to Delhi. There is nothing on record

COMMISSIONER OF WEALTH TAX vs. S.S. AHLUWALIA

Section 127 of the Act for transfer of respondent’s case from ITO, Dimapur to the AO, Delhi to which response/objection was filed vide letter dated 5th January, 1989. The respondent assessee had objected to transfer of the 2014:DHC:1423-DB ITA 255/2002 + connected Page 6 of 61 case to Delhi. There is nothing on record

ACIT, DELHI vs. M/S. THE INDIAN NEWS PAPER SOCIETY, NEW DELHI

Bench: Shri Sudhanshu Srivastava & Shri Anadee Nath Misshra

61 (Del), it was held that as per the facts and circumstances of the case, even a security deposit under lease agreement can be tantamount to advance rent, hence TDS deduction is required to be made. 11. After careful consideration of the above submissions, contentions and legal propositions of both the parties in the light of factual matrix of present

VARDHMAN INFRA DEVELOPERS (P) LTD.,DELHI vs. INCOME TAX OFFICER WARD-78(3), NEW DELHI, DELHI

In the result, the assessee’s appeal is allowed

Bench: Shri Satbeer Singh Godara & Shri Avdhesh Kumar Mishraita No.511/Del./2024, A.Y. 2014-15 Vardhman Infra Developers Income Tax Officer, (P) Ltd., 401-414, C-58, Ward-78(3), 4Th Floor, Shahpuri, Vs. Income Tax Office, Tirath Singh, Tower Dda, Laxmi Nagar, New Delhi Janakpuri, New Delhi Pan: Aadcv3838M (Appellant) (Respondent) Appellant By None Respondent By Shri Om Prakash, Sr. Dr Date Of Hearing 30/07/2025 Date Of Pronouncement 30/07/2025 Order Per Avdhesh Kumar Mishra, Am The Appeal For The Assessment Year (‘Ay’) 2014-15 Filed By The Assessee Is Directed Against The Order Dated 18.03.2019 Of The Commissioner Of Income Tax (Appeals)-28, New Delhi [‘Cit(A)’].

61 1090 2681725/- Total 10248566/- Notice Col. No. G: - ……………………………….. Accordingly, penalty of an amount of Rs. 10248566/- under section 271A(2)(g) of the IT Act, 1961 is imposed relevant to the F.Y. 2013-14 in the case of the assessee company.” 3.3 Aggrieved, the assessee filed appeal before the CIT(A), who restricted the penalty to Rs.90

ACIT, CC- 31, NEW DELHI vs. PERNOD RICHARD INDIA PVT. LTD., NEW DELHI

In the result, the appeals filed by the Revenue are dismissed and the appeals filed by the assessee are partly allowed for statistical purposes

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

TDS by the Ld. CIT(A) in the orders passed in the case of Appellant’s sister concern, Seagram Distilleries Pvt Ltd for the Assessment Years 2005-06 to 2009-10. 29. That the Ld. AO/ Ld. CIT(A) failed to appreciate that the trade schemes reimbursed to sales promoters is already part of the Transfer Pricing Adjustment on account

PERNOD RICARD INDIA PVT. LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result, the appeals filed by the Revenue are dismissed and the appeals filed by the assessee are partly allowed for statistical purposes

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

TDS by the Ld. CIT(A) in the orders passed in the case of Appellant’s sister concern, Seagram Distilleries Pvt Ltd for the Assessment Years 2005-06 to 2009-10. 29. That the Ld. AO/ Ld. CIT(A) failed to appreciate that the trade schemes reimbursed to sales promoters is already part of the Transfer Pricing Adjustment on account

DCIT, CC-31, NEW DELHI vs. PERNOD RICARD INDIA PVT. LTD., NEW DELHI

In the result, the appeals filed by the Revenue are dismissed and the appeals filed by the assessee are partly allowed for statistical purposes

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

TDS by the Ld. CIT(A) in the orders passed in the case of Appellant’s sister concern, Seagram Distilleries Pvt Ltd for the Assessment Years 2005-06 to 2009-10. 29. That the Ld. AO/ Ld. CIT(A) failed to appreciate that the trade schemes reimbursed to sales promoters is already part of the Transfer Pricing Adjustment on account

PERNOD RICARD INDIA PVT. LTD,GURGAON vs. DCIT, CENTRAL CIRCLE- 31, NEW DELHI

In the result, the appeals filed by the Revenue are dismissed and the appeals filed by the assessee are partly allowed for statistical purposes

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

TDS by the Ld. CIT(A) in the orders passed in the case of Appellant’s sister concern, Seagram Distilleries Pvt Ltd for the Assessment Years 2005-06 to 2009-10. 29. That the Ld. AO/ Ld. CIT(A) failed to appreciate that the trade schemes reimbursed to sales promoters is already part of the Transfer Pricing Adjustment on account

GREATSHIP GLOBAL ENERGY SERVICES PTE LTD.,MUMBAI vs. DCIT, (INT. TAX.) CIRCLE-1(3)(1), NEW DELHI

The appeal of the Assessee stands dismissed as infractous

Bench: Shri Anil Chaturvedi & Shri Narender Kumar Choudhryasstt. Yr: _2018-19

TDS credit of Rs.7,31,61,839/-. Somehow, in the intimation under section 143(1) dated 23rd February, 2.1 2020, TDS

ACIT (E), NEW DELHI vs. M/S APCO WORLDWIDE INDIA PVT. LTD.,, NEW DELHI

In the result appeal filed by revenue for A

Bench: Smt. Beena A Pillai & Dr. B.R.R. Kumara.Y. 2010-11

TDS), 4 Mumbai [ 2015 ] 61 taxmann.com 335 (Mumbai - Trib.) in the ITAT MUMBAI BENCH 'L' “Section 9, read with section

DCIT, NEW DELHI vs. M/S APCO WORLDWIDE INDIA PVT. LTD.,, NEW DELHI

In the result appeal filed by revenue for A

Bench: Smt. Beena A Pillai & Dr. B.R.R. Kumara.Y. 2010-11

TDS), 4 Mumbai [ 2015 ] 61 taxmann.com 335 (Mumbai - Trib.) in the ITAT MUMBAI BENCH 'L' “Section 9, read with section

THE COMMISSIONER OF INCOME TAX - INTERNATIONAL TAXATION - 3 vs. SUMITOMO COPORATION

Bench: HON'BLE MR. JUSTICE RAJIV SHAKDHER,HON'BLE MR. JUSTICE GIRISH KATHPALIA

61, Section 64, Section 93 or Section 94, in that the total income of another person, the payment shall be deemed to have been made on behalf of, and the credit shall be given to, such other person; (ii) in any other case, where the dividend on any share is assessable as the income of a person other than

THE COMMISSIONER OF INCOME TAX - INTERNATIONAL TAXATION - 3 vs. SUMITOMO COPORATION

61, Section 64, Section 93 or Section 94, in that the total income of another person, the payment shall be deemed to have been made on behalf of, and the credit shall be given to, such other person; (ii) in any other case, where the dividend on any share is assessable as the income of a person other than

SHARDA EDUCATIONAL TRUST ,GREATER NOIDA vs. ITO (TDS), INTERNATIONAL TAXATION, NOIDA

In the result, ITA.No.3377/Del

Bench: Shri R.K. Panda & Shri Anubhav Sharma

61,42,203/- 3,222/- 2015-16 19,99,843/ 3,99,969/- 16,110/- 13,000/- 2016-17 7,76,150/- 1,55,230/- 65,000/- 2,31,81,507/- 46,36,302/- 81,110/- 16,222/- 30,000/- 6,002/- 1,88,28 37,656/- Total TDS 46,96,182/- Interest 19,24,001/- Grand Total

SHARDA EDUCATIONAL TRUST ,GREATER NOIDA vs. ITO (TDS), INTERNATIONAL TAXATION, NOIDA

In the result, ITA.No.3377/Del

Bench: Shri R.K. Panda & Shri Anubhav Sharma

61,42,203/- 3,222/- 2015-16 19,99,843/ 3,99,969/- 16,110/- 13,000/- 2016-17 7,76,150/- 1,55,230/- 65,000/- 2,31,81,507/- 46,36,302/- 81,110/- 16,222/- 30,000/- 6,002/- 1,88,28 37,656/- Total TDS 46,96,182/- Interest 19,24,001/- Grand Total

SHARDA EDUCATIONAL TRUST ,GREATER NOIDA vs. ITO (TDS), INTERNATIONAL TAXATION, NOIDA

In the result, ITA.No.3377/Del

Bench: Shri R.K. Panda & Shri Anubhav Sharma

61,42,203/- 3,222/- 2015-16 19,99,843/ 3,99,969/- 16,110/- 13,000/- 2016-17 7,76,150/- 1,55,230/- 65,000/- 2,31,81,507/- 46,36,302/- 81,110/- 16,222/- 30,000/- 6,002/- 1,88,28 37,656/- Total TDS 46,96,182/- Interest 19,24,001/- Grand Total

SHARDA EDUCATIONAL TRUST ,GREATER NOIDA vs. ITO (TDS), INTERNATIONAL TAXATION, NOIDA

In the result, ITA.No.3377/Del

Bench: Shri R.K. Panda & Shri Anubhav Sharma

61,42,203/- 3,222/- 2015-16 19,99,843/ 3,99,969/- 16,110/- 13,000/- 2016-17 7,76,150/- 1,55,230/- 65,000/- 2,31,81,507/- 46,36,302/- 81,110/- 16,222/- 30,000/- 6,002/- 1,88,28 37,656/- Total TDS 46,96,182/- Interest 19,24,001/- Grand Total