ORAVEL STAYS LIMITED (FORMERLY KNOWN AS ORAVEL STAYS PRIVATE LIMITED),GURUGRAM vs. DCIT CENTRAL CIRCLE 6, NEW DELHI

In the result, both appeals of the assessee are allowed as above

Bench: Shri Yogesh Kumar U.S. & Shri Avdhesh Kumar Mishra

69, Gurgaon-122001 Laxmi Nagar, New Delhi PAN: AABCO6063D (Appellant) (Respondent) Appellant by Sh. Ajay Vohra, Sr. Advocate Ms. Somya Jain, CA Respondent by Sh. Sumer Singh Meena, CIT- DR, Sh. Gouranga Chandra, Sr. DR Date of Hearing 27/08/2025 Date of Pronouncement 21/11/2025 ORDER PER AVDHESH KUMAR MISHRA, AM Similar grounds and facts are involved in the above captioned appeals

SUMITA SINGHAL,NEW DELHI vs. ITO, WARD-17(4), NEW DELHI

In the result, both appeals of the assessee are allowed as above

Bench: Shri Yogesh Kumar U.S. & Shri Avdhesh Kumar Mishra

69, Gurgaon-122001 Laxmi Nagar, New Delhi PAN: AABCO6063D (Appellant) (Respondent) Appellant by Sh. Ajay Vohra, Sr. Advocate Ms. Somya Jain, CA Respondent by Sh. Sumer Singh Meena, CIT- DR, Sh. Gouranga Chandra, Sr. DR Date of Hearing 27/08/2025 Date of Pronouncement 21/11/2025 ORDER PER AVDHESH KUMAR MISHRA, AM Similar grounds and facts are involved in the above captioned appeals

R V INTERIOR PVT. LTD. ,DELHI vs. PCIT, DELHI

In the result, both appeals of the assessee are allowed as above

Bench: Shri Yogesh Kumar U.S. & Shri Avdhesh Kumar Mishra

69, Gurgaon-122001 Laxmi Nagar, New Delhi PAN: AABCO6063D (Appellant) (Respondent) Appellant by Sh. Ajay Vohra, Sr. Advocate Ms. Somya Jain, CA Respondent by Sh. Sumer Singh Meena, CIT- DR, Sh. Gouranga Chandra, Sr. DR Date of Hearing 27/08/2025 Date of Pronouncement 21/11/2025 ORDER PER AVDHESH KUMAR MISHRA, AM Similar grounds and facts are involved in the above captioned appeals

VODAFONE IDEA LTD. (EARLIER KNWON AS VODAFONE MOBILE SERVICES LTD.),NEW DELHI vs. ITO, TDS, KARNAL

The appeals of the Assessee are allowed

Bench: Shri Amit Shukla & Shri Prashant Maharishi

TDS) [(2016) 69 taxmann.com 307 (Mum-Trib)]. The Ld. Counsel submitted that both the issues now stand decided in favour of the Assessee where it was held that there was no obligation on the assessee to withhold tax under the provisions of Section

VODAFONE IDEA LTD,NEW DELHI vs. ITO (TDS), KARNAL

The appeals of the Assessee are allowed

Bench: Shri Amit Shukla & Shri Prashant Maharishi

TDS) [(2016) 69 taxmann.com 307 (Mum-Trib)]. The Ld. Counsel submitted that both the issues now stand decided in favour of the Assessee where it was held that there was no obligation on the assessee to withhold tax under the provisions of Section

VODAFONE IDEA LTD,NEW DELHI vs. ITO (TDS), KARNAL

The appeals of the Assessee are allowed

Bench: Shri Amit Shukla & Shri Prashant Maharishi

TDS) [(2016) 69 taxmann.com 307 (Mum-Trib)]. The Ld. Counsel submitted that both the issues now stand decided in favour of the Assessee where it was held that there was no obligation on the assessee to withhold tax under the provisions of Section

VODAFONE IDEA LTD. (EARLIER KNWON AS VODAFONE MOBILE SERVICES LTD.),NEW DELHI vs. ITO, TDS, KARNAL

The appeals of the Assessee are allowed

Bench: Shri Amit Shukla & Shri Prashant Maharishi

TDS) [(2016) 69 taxmann.com 307 (Mum-Trib)]. The Ld. Counsel submitted that both the issues now stand decided in favour of the Assessee where it was held that there was no obligation on the assessee to withhold tax under the provisions of Section

VODAFONE IDEA LTD. (EARLIER KNWON AS VODAFONE MOBILE SERVICES LTD.),NEW DELHI vs. ITO, TDS, KARNAL

The appeals of the Assessee are allowed

Bench: Shri Amit Shukla & Shri Prashant Maharishi

TDS) [(2016) 69 taxmann.com 307 (Mum-Trib)]. The Ld. Counsel submitted that both the issues now stand decided in favour of the Assessee where it was held that there was no obligation on the assessee to withhold tax under the provisions of Section

PAWAN KUMAR JAIN,GHAZIABAD vs. ITO, WARD- 2(1), GHAZIABAD

In the result, appeal of the assessee is partly allowed on ground no

69 of I. Tax Act as unexplained and undisclosed Investment. I.T.A.No.6578/Del/2018 2. That a legal question of law arise whether the action of CIT(A) justified for conversion of addition as made by AO under any wrong section which is challenge by the appellant by way of grounds of appeal. 3. That the Learned CIT(A) has not serious

AYESA INGENIERIA Y ARQUITECTURA S.A.,NOIDA vs. ACIT INTL. TAXATION, GURGAON

In the result, appeal of the assessee is allowed

Bench: Shri G.S. Pannu, Hon’Ble & Ms. Astha Chandra

TDS falling under different provisions, no disallowance can be made by invoking provisions of section 40(a)(i) of the Act. The Judgment passed by Calucutta High Court in the case of CIT vs. S. K. Tekriwal [2014] 46 taxmann.com 444 (Calcutta) (PB-688 to 689) is relevant on this issue, which has been subsequently followed by Hon’ble high

AYESA INGENIERIA Y ARQUITECTURA S.A.,NOIDA vs. ACIT INTL. TAXATION, GURGAON

In the result, appeal of the assessee is allowed

Bench: Shri G.S. Pannu, Hon’Ble & Ms. Astha Chandra

TDS falling under different provisions, no disallowance can be made by invoking provisions of section 40(a)(i) of the Act. The Judgment passed by Calucutta High Court in the case of CIT vs. S. K. Tekriwal [2014] 46 taxmann.com 444 (Calcutta) (PB-688 to 689) is relevant on this issue, which has been subsequently followed by Hon’ble high

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 of Rs. 1,16,97,590/- under section 14A; disallowance of Rs. 1,76,16,528/- under section 36(1)(viii) and disallowance of Rs. 9,69

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 of Rs. 1,16,97,590/- under section 14A; disallowance of Rs. 1,76,16,528/- under section 36(1)(viii) and disallowance of Rs. 9,69

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 of Rs. 1,16,97,590/- under section 14A; disallowance of Rs. 1,76,16,528/- under section 36(1)(viii) and disallowance of Rs. 9,69

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 of Rs. 1,16,97,590/- under section 14A; disallowance of Rs. 1,76,16,528/- under section 36(1)(viii) and disallowance of Rs. 9,69

M/S. ATS INFRASTRUCTURE LIMITED,NEW DELHI vs. ACIT, MEERUT

Bench: Shri N.K. Billaiya & Shri Kuldip Singh

69 of the Act and the same deserves to be deleted in full. 5. BECAUSE the Ld. CIT (A) has wrongly held that the assessee is not entitled to revise the return and therefore, the assessee is not entitled to be assessed at the correct income in accordance with the provisions of the Act. The facts of the cases relied

M/S. ATS INFRASTRUCTURE LIMITED,NEW DELHI vs. ACIT, MEERUT

Bench: Shri N.K. Billaiya & Shri Kuldip Singh

69 of the Act and the same deserves to be deleted in full. 5. BECAUSE the Ld. CIT (A) has wrongly held that the assessee is not entitled to revise the return and therefore, the assessee is not entitled to be assessed at the correct income in accordance with the provisions of the Act. The facts of the cases relied

M/S. ATS INFRASTRUCTURE LIMITED,NEW DELHI vs. ACIT, MEERUT

Bench: Shri N.K. Billaiya & Shri Kuldip Singh

69 of the Act and the same deserves to be deleted in full. 5. BECAUSE the Ld. CIT (A) has wrongly held that the assessee is not entitled to revise the return and therefore, the assessee is not entitled to be assessed at the correct income in accordance with the provisions of the Act. The facts of the cases relied