COMMISSIONER OF INCOME TAX vs. M/S INTERNATIONAL TRACTORS LTD

Bench: CASES PERTAINING TO SPL.DIVISION BENCHES

TDS, reliance was placed on the decision of the Supreme Court in DIT v. A.P. Moller Moersk (2017) 392 ITR 186 (SC). 32. On the issue of exercise of jurisdictional powers under Section 263 of the Act, reliance was placed on the decision in Malabar Industrial Co. Ltd. v. CIT (2000) 243 ITR 83 (SC) and the decision of Punjab

JCIT(OSD), RANGE-10, NEW DELHI , ITO C.R. BUILDING 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

80J. In our view, since the\n18\nITA Nos.319 & 320/Del/2025\nITA Nos.577& 578/Del/2025\nITA Nos.609& 579/Del/2025\nexpression of wider import, namely, 'attributable to', has been used,\nthe Legislature intended to cover receipts from sources other than the\nactual conduct of the business of generation and distribution of\nelectricity.\"\n6. The word \"derived\" has been construed as far back

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

80J. In our view, since the\n18\nITA Nos.319 & 320/Del/2025\nITA Nos.577& 578/Del/2025\nITA Nos.609& 579/Del/2025\nexpression of wider import, namely, 'attributable to', has been used,\nthe Legislature intended to cover receipts from sources other than the\nactual conduct of the business of generation and distribution of\nelectricity.\"\n6. The word \"derived\" has been construed as far back

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

80J. In our view, since the\n18\nexpression of wider import, namely, 'attributable to', has been used,\nthe Legislature intended to cover receipts from sources other than the\nactual conduct of the business of generation and distribution of\nelectricity.\"\n6. The word \"derived\" has been construed as far back in 1948 by the\nPrivy Council in CIT v. Raja Bahadur

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

80J. In our view, since the\n18\nITA Nos.319 & 320/Del/2025\nITA Nos.577& 578/Del/2025\nITA Nos.609& 579/Del/2025\nexpression of wider import, namely, 'attributable to', has been used,\nthe Legislature intended to cover receipts from sources other than the\nactual conduct of the business of generation and distribution of\nelectricity.\"\n6. The word \"derived\" has been construed as far back

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

80J. In our view, since the\nexpression of wider import, namely, 'attributable to', has been used,\nthe Legislature intended to cover receipts from sources other than the\nactual conduct of the business of generation and distribution of\nelectricity.\"\n6. The word \"derived\" has been construed as far back in 1948 by the\nPrivy Council in CIT v. Raja Bahadur Kamakhaya

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

80J. In our view, since the\nexpression of wider import, namely, 'attributable to', has been used,\nthe Legislature intended to cover receipts from sources other than the\nactual conduct of the business of generation and distribution of\nelectricity.\"\n6. The word \"derived\" has been construed as far back in 1948 by the\nPrivy Council in CIT v. Raja Bahadur Kamakhaya

M/S. SHIVALIK PRINTS LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result, assessees’ appeals in ITA nos

Bench: Shri Kul Bharat & Shri Avdhesh Kumar Mishraassessment Year: 2011-12 & Assessment Year: 2012-13

TDS credit the learned CIT(A) restored the issue to the Assessing Officer for examining the claim of the assessee from the records and allow the tax credit. However, the claim of the assessee regarding deduction u/s 80JJAA was rejected. Against this rejection, the assessee is in appeal before this Tribunal. 5. Apropos to the grounds of appeal learned counsel

SHIVALIK PRINTS LTD.,NEW DELHI vs. JCIT, SPECIAL RANGE-8, NEW DELHI

In the result, assessees’ appeals in ITA nos

Bench: Shri Kul Bharat & Shri Avdhesh Kumar Mishraassessment Year: 2011-12 & Assessment Year: 2012-13

TDS credit the learned CIT(A) restored the issue to the Assessing Officer for examining the claim of the assessee from the records and allow the tax credit. However, the claim of the assessee regarding deduction u/s 80JJAA was rejected. Against this rejection, the assessee is in appeal before this Tribunal. 5. Apropos to the grounds of appeal learned counsel

ADDL.CIT, SPECIAL RANGE-3, NEW DELHI vs. DELHI TOURISM TRANSPORTATION AND DEVELOPMENT CORPORATION LTD., NEW DELHI

In the result, Appeal filed by the Department in ITA No

Bench: SHRI N. K. BILLAIYA (Accountant Member), SHRI YOGESH KUMAR U.S. (Judicial Member)

80J(6A) which are similar to the provisions of section 80-IA(7), we feel that the Tribunal has arrived at the correct conclusion that the requirement of filing the audit report along with the return is not mandatory but directory and that if the audit report is filed at any time before the framing of the assessment, the requirement

ADDL.CIT, SPECIAL RANGE-3, NEW DELHI vs. DELHI TOURISM TRANSPORTATION AND DEVELOPMENT CORPORATION LTD., NEW DELHI

In the result, Appeal filed by the Department in ITA No

Bench: SHRI N. K. BILLAIYA (Accountant Member), SHRI YOGESH KUMAR U.S. (Judicial Member)

80J(6A) which are similar to the provisions of section 80-IA(7), we feel that the Tribunal has arrived at the correct conclusion that the requirement of filing the audit report along with the return is not mandatory but directory and that if the audit report is filed at any time before the framing of the assessment, the requirement

ADDL.CIT, SPECIAL RANGE-3, NEW DELHI vs. DELHI TOURISM TRANSPORTATION AND DEVELOPMENT CORPORATION LTD., NEW DELHI

In the result, Appeal filed by the Department in ITA No

Bench: SHRI N. K. BILLAIYA (Accountant Member), SHRI YOGESH KUMAR U.S. (Judicial Member)

80J(6A) which are similar to the provisions of section 80-IA(7), we feel that the Tribunal has arrived at the correct conclusion that the requirement of filing the audit report along with the return is not mandatory but directory and that if the audit report is filed at any time before the framing of the assessment, the requirement

DELHI TOURISM TRANSPORTATION AND DEVELOPMENT CORPORATION LTD.,NEW DELHI vs. ADDL.CIT, SPECIAL RANGE-3, NEW DELHI

In the result, Appeal filed by the Department in ITA No

Bench: SHRI N. K. BILLAIYA (Accountant Member), SHRI YOGESH KUMAR U.S. (Judicial Member)

80J(6A) which are similar to the provisions of section 80-IA(7), we feel that the Tribunal has arrived at the correct conclusion that the requirement of filing the audit report along with the return is not mandatory but directory and that if the audit report is filed at any time before the framing of the assessment, the requirement

DELHI TOURISM & TRANSPORTATION DEVELOPMENT CORPORATION LTD. ,NEW DELHI vs. DCIT CIRCLE-10(1), NEW DELHI

In the result, Appeal filed by the Department in ITA No

Bench: SHRI N. K. BILLAIYA (Accountant Member), SHRI YOGESH KUMAR U.S. (Judicial Member)

80J(6A) which are similar to the provisions of section 80-IA(7), we feel that the Tribunal has arrived at the correct conclusion that the requirement of filing the audit report along with the return is not mandatory but directory and that if the audit report is filed at any time before the framing of the assessment, the requirement

ADDI. CIT SPL. RANGE-3, NEW DELHI vs. DELHI TOURISM & TRANSPORTATION DEVELOPMENT CORPORATION LTD. , NEW DELHI

In the result, Appeal filed by the Department in ITA No

Bench: SHRI N. K. BILLAIYA (Accountant Member), SHRI YOGESH KUMAR U.S. (Judicial Member)

80J(6A) which are similar to the provisions of section 80-IA(7), we feel that the Tribunal has arrived at the correct conclusion that the requirement of filing the audit report along with the return is not mandatory but directory and that if the audit report is filed at any time before the framing of the assessment, the requirement

ACIT SPECIAL RANGE-3, NEW DELHI vs. DELHI TOURISM & TRANSPORTATION DEVELOPMENT CORPORATION LTD., NEW DELHI

In the result, Appeal filed by the Department in ITA No

Bench: SHRI N. K. BILLAIYA (Accountant Member), SHRI YOGESH KUMAR U.S. (Judicial Member)

80J(6A) which are similar to the provisions of section 80-IA(7), we feel that the Tribunal has arrived at the correct conclusion that the requirement of filing the audit report along with the return is not mandatory but directory and that if the audit report is filed at any time before the framing of the assessment, the requirement

DY. COMMISSIONER OF INCOME TAX, CIRCLE, HISAR vs. SYNERGY WASTE MANAGEMENT PRIVATE LIMITED, HISAR

Appeal is dismissed in above terms

Bench: Sh. Satbeer Singh Godara & Sh. S. Rifaur Rahmanita No. 3557/Del/2023 : Asstt. Year : 2017-18 Dcit, Vs Synergy Waste Management Pvt. Circle, Ltd., #168, Sector-27-28, Hisar, Hisar, Haryana-125001 Haryana-125001 (Appellant) (Respondent) Pan No. Aaics9088H Assessee By : Sh. S. K. Gupta, Ca Revenue By : Sh. Sahil Kumar Bansal, Sr. Dr Date Of Hearing: 12.12.2024 Date Of Pronouncement: 20.12.2024 Order Per Satbeer Singh Godara: This Revenue’S Appeal For Assessment Year 2017-18, Arises Against The Cit(A)/Nfac, Delhi’S Din & Order No. Itba/Nfac/S/250/2023-24/105727025(1) Dated 20.10.2023, In Proceedings U/S 143(3) Of The Income Tax Act, 1961 (In Short “The Act”).

TDS etc within the statutory due dates as is clear from the following records: Assessment Year Date of filling Income Tax Return Due Date 2006-07 20.11.2006 30.11.2006 2007-08 29.10.2007 31.10.2007 2008-09 25.09.2008 30.09.2008 2009-10 29.09.2009 30.09.2009 2010-11 28.09.2010 30.09.2010 4 Synergy Waste Management

DCIT, HISAR vs. M/S SYNERGY WASTE MANAGEMENT PVT. LTD.,, HISAR

In the result, all the five captioned appeals filed by the Revenue are dismissed

Bench: Shri C.M. Garg & Shri Pradip Kumar Kedia

TDS etc within the statutory due dates as is clear from the following records: Assessment Year Date of filling Income Tax Return Due Date 2006-07 20.11.2006 30.11.2006 2007-08 29.10.2007 31.10.2007 2008-09 25.09.2008 30.09.2008 2009-10 29.09.2009 30.09.2009 2010-11 28.09.2010 30.09.2010 2011-12 29.09.2011 30.09.2011 2012-13 12.10.2012 30.09.2012 2) The turnover of the company has also