ACIT, NEW DELHI vs. SH MAHAGUN INDIA PVT. LTD.,, DELHI

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

survey action u/s 133A of the assessee 20.03.2007. Thereafter a search and seizure operation was also conducted by the Investigation Wing V(I), Delhi in Mahagun group of cases on 27.08.2008 which included the premises of the assessee u/s 132 of the Income-tax Act, 1961 [the Act, for short]. After centralizing the assessee’s case, notice u/s 153A

MAHAGUN INDIA PVT. LTD.,NEW DELHI vs. ACIT, NEW DELHI

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

survey action u/s 133A of the assessee 20.03.2007. Thereafter a search and seizure operation was also conducted by the Investigation Wing V(I), Delhi in Mahagun group of cases on 27.08.2008 which included the premises of the assessee u/s 132 of the Income-tax Act, 1961 [the Act, for short]. After centralizing the assessee’s case, notice u/s 153A

SATYA KIRAN HEALTHCARE PRIVATE LIMITED,SONIPAT vs. ITO WARD - TDS, ROHTAL

In the result, appeals of the assessee are allowed for

Bench: Shri G.S. Pannu, Hon’Ble & Shri Challa Nagendra Prasadआ.अ.सं/.I.T.A Nos.9143 & 9144/Del/2019 िनधा"रणवष"/Assessment Years:2017-18 & 2019-20 बनाम Satya Kiran Healthcare Private Ltd., Ito, Near Pwd House, Atlas Road, Vs. Ward-Tds, Sonipat, Haryana. Rohtak, Haryana. Pan No.Aabcs7978K अपीलाथ" Appellant ""यथ"/Respondent

Survey u/s 133A of the Act was done by ITO (TDS) and it was found that the assessee failed to comply

SATYA KIRAN HEALTHCARE PRIVATE LIMITED,SONIPAT vs. ITO WARD - TDS, ROHTAL

In the result, appeals of the assessee are allowed for

Bench: Shri G.S. Pannu, Hon’Ble & Shri Challa Nagendra Prasadआ.अ.सं/.I.T.A Nos.9143 & 9144/Del/2019 िनधा"रणवष"/Assessment Years:2017-18 & 2019-20 बनाम Satya Kiran Healthcare Private Ltd., Ito, Near Pwd House, Atlas Road, Vs. Ward-Tds, Sonipat, Haryana. Rohtak, Haryana. Pan No.Aabcs7978K अपीलाथ" Appellant ""यथ"/Respondent

Survey u/s 133A of the Act was done by ITO (TDS) and it was found that the assessee failed to comply

TCNS CLOTHING CO. LTD,NEW DELHI vs. ACIT (TDS) CIRCLE - 76(1), NEW DELHI

In the result, appeals of the assessee are allowed

Bench: Shri Challa Nagendra Prasad & Shri Pradip Kumar Kediaआ.अ.सं/.I.T.A Nos.1994 & 1995/Del/2020 िनधा"रणवष"/Assessment Years:2011-12 & 2012-13 बनाम Tcns Clothing Co. Limited, Acit (Tds), 119, W-House, New Vs. Circle-76(1), Manglapuri, Aaykar Bhawan, Mandi Road, Sultanpur, District Centre, Mehrauli, New Delhi. Laxmi Nagar, Delhi. Pan No. Aaact4432E अपीलाथ" Appellant ""यथ"/Respondent

u/s 133A(2A) of the Act was carried out in the case of the Ambience Group by the ACIT(TDS)-73(1), New Delhi on 12.02.2018 for the purpose of verification of compliances of TDS provisions. Survey

TCNS CLOTHING CO. LTD,NEW DELHI vs. ACIT (TDS) CIRCLE - 76(1), NEW DELHI

In the result, appeals of the assessee are allowed

Bench: Shri Challa Nagendra Prasad & Shri Pradip Kumar Kediaआ.अ.सं/.I.T.A Nos.1994 & 1995/Del/2020 िनधा"रणवष"/Assessment Years:2011-12 & 2012-13 बनाम Tcns Clothing Co. Limited, Acit (Tds), 119, W-House, New Vs. Circle-76(1), Manglapuri, Aaykar Bhawan, Mandi Road, Sultanpur, District Centre, Mehrauli, New Delhi. Laxmi Nagar, Delhi. Pan No. Aaact4432E अपीलाथ" Appellant ""यथ"/Respondent

u/s 133A(2A) of the Act was carried out in the case of the Ambience Group by the ACIT(TDS)-73(1), New Delhi on 12.02.2018 for the purpose of verification of compliances of TDS provisions. Survey

M/S. GREEN LINE EARTH LTD.,NEW DELHI vs. ITO (TDS), NEW DELHI

In the result, the appeal of the assessee in Green Line Earth Ltd

Bench: Shri Saktijit Dey & Shri M. Balaganeshassessment Year: 2002-03 Green Line (Punjab), Vs Ito (Tds), I-25, Lajpat Nagar-Iii, Ward-50(5), New Delhi. New Delhi. Pan: Aadfg5282H Assessment Year: 2002-03 Green Line (Delhi), Vs. Ito (Tds), I-25, Lajpat Nagar-Iii, Ward-50(5), New Delhi. New Delhi. Pan: Aaaps6803P Assessment Year: 2003-04 Green Line Earth Ltd., Vs. Ito (Tds), I-25, Lajpat Nagar-Iii, Ward-50(5), New Delhi. New Delhi. Pan: Aaacg6500C (Applicant) (Respondent) Assessee By : Shri K.R. Manjani, Advocate & Shri Tarun Aswani, Advocate Revenue By : Shri J.S. Minhas, Cit-Dr Date Of Hearing : 02.05.2023 Date Of Pronouncement : 10.05.2023

TDS Officer in the case of different assessees are barred by limitation. 5. Let us take up the appeal of the assessee in the case of Green Line (Punjab) in ITA No.1102/Del/2016 for AY 2002-03. 6. We have heard the rival submissions and perused the material available on record. A survey operation u/s 133A

M/S. GREEN LINE (DELHI),NEW DELHI vs. ITO (TDS), NEW DELHI

In the result, the appeal of the assessee in Green Line Earth Ltd

Bench: Shri Saktijit Dey & Shri M. Balaganeshassessment Year: 2002-03 Green Line (Punjab), Vs Ito (Tds), I-25, Lajpat Nagar-Iii, Ward-50(5), New Delhi. New Delhi. Pan: Aadfg5282H Assessment Year: 2002-03 Green Line (Delhi), Vs. Ito (Tds), I-25, Lajpat Nagar-Iii, Ward-50(5), New Delhi. New Delhi. Pan: Aaaps6803P Assessment Year: 2003-04 Green Line Earth Ltd., Vs. Ito (Tds), I-25, Lajpat Nagar-Iii, Ward-50(5), New Delhi. New Delhi. Pan: Aaacg6500C (Applicant) (Respondent) Assessee By : Shri K.R. Manjani, Advocate & Shri Tarun Aswani, Advocate Revenue By : Shri J.S. Minhas, Cit-Dr Date Of Hearing : 02.05.2023 Date Of Pronouncement : 10.05.2023

TDS Officer in the case of different assessees are barred by limitation. 5. Let us take up the appeal of the assessee in the case of Green Line (Punjab) in ITA No.1102/Del/2016 for AY 2002-03. 6. We have heard the rival submissions and perused the material available on record. A survey operation u/s 133A

M/S. GREEN LINE (PUNJAB),NEW DELHI vs. ITO (TDS), NEW DELHI

In the result, the appeal of the assessee in Green Line Earth Ltd

Bench: Shri Saktijit Dey & Shri M. Balaganeshassessment Year: 2002-03 Green Line (Punjab), Vs Ito (Tds), I-25, Lajpat Nagar-Iii, Ward-50(5), New Delhi. New Delhi. Pan: Aadfg5282H Assessment Year: 2002-03 Green Line (Delhi), Vs. Ito (Tds), I-25, Lajpat Nagar-Iii, Ward-50(5), New Delhi. New Delhi. Pan: Aaaps6803P Assessment Year: 2003-04 Green Line Earth Ltd., Vs. Ito (Tds), I-25, Lajpat Nagar-Iii, Ward-50(5), New Delhi. New Delhi. Pan: Aaacg6500C (Applicant) (Respondent) Assessee By : Shri K.R. Manjani, Advocate & Shri Tarun Aswani, Advocate Revenue By : Shri J.S. Minhas, Cit-Dr Date Of Hearing : 02.05.2023 Date Of Pronouncement : 10.05.2023

TDS Officer in the case of different assessees are barred by limitation. 5. Let us take up the appeal of the assessee in the case of Green Line (Punjab) in ITA No.1102/Del/2016 for AY 2002-03. 6. We have heard the rival submissions and perused the material available on record. A survey operation u/s 133A

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

133A of the Income Tax Act, 1961 was conducted on 29.03.2017 at the educational premises of the deductor. 2.1. During the course of such TDS survey, it was found that the assessee had remitted abroad amounts under various heads viz. Consultancy Fees on Student Recruitment, Commission on Student Recruitment, Participation Fee for Education Tour, Advertisement/ 3 ITA.No.3377 to 3383/Del

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

133A of the Income Tax Act, 1961 was conducted on 29.03.2017 at the educational premises of the deductor. 2.1. During the course of such TDS survey, it was found that the assessee had remitted abroad amounts under various heads viz. Consultancy Fees on Student Recruitment, Commission on Student Recruitment, Participation Fee for Education Tour, Advertisement/ 3 ITA.No.3377 to 3383/Del

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

133A of the Income Tax Act, 1961 was conducted on 29.03.2017 at the educational premises of the deductor. 2.1. During the course of such TDS survey, it was found that the assessee had remitted abroad amounts under various heads viz. Consultancy Fees on Student Recruitment, Commission on Student Recruitment, Participation Fee for Education Tour, Advertisement/ 3 ITA.No.3377 to 3383/Del

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

133A of the Income Tax Act, 1961 was conducted on 29.03.2017 at the educational premises of the deductor. 2.1. During the course of such TDS survey, it was found that the assessee had remitted abroad amounts under various heads viz. Consultancy Fees on Student Recruitment, Commission on Student Recruitment, Participation Fee for Education Tour, Advertisement/ 3 ITA.No.3377 to 3383/Del

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

133A of the Income Tax Act, 1961 was conducted on 29.03.2017 at the educational premises of the deductor. 2.1. During the course of such TDS survey, it was found that the assessee had remitted abroad amounts under various heads viz. Consultancy Fees on Student Recruitment, Commission on Student Recruitment, Participation Fee for Education Tour, Advertisement/ 3 ITA.No.3377 to 3383/Del

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

133A of the Income Tax Act, 1961 was conducted on 29.03.2017 at the educational premises of the deductor. 2.1. During the course of such TDS survey, it was found that the assessee had remitted abroad amounts under various heads viz. Consultancy Fees on Student Recruitment, Commission on Student Recruitment, Participation Fee for Education Tour, Advertisement/ 3 ITA.No.3377 to 3383/Del

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

133A of the Income Tax Act, 1961 was conducted on 29.03.2017 at the educational premises of the deductor. 2.1. During the course of such TDS survey, it was found that the assessee had remitted abroad amounts under various heads viz. Consultancy Fees on Student Recruitment, Commission on Student Recruitment, Participation Fee for Education Tour, Advertisement/ 3 ITA.No.3377 to 3383/Del

M/S. U.K. PAINTS INDIA PVT. LTD.,NEW DELHI vs. ACIT, NEW DELHI

In the result, the appeals of the assessee are allowed, the COs of the assessee are allowed for statistical purpose and the appeals of the Revenue are dismissed

Bench: Sh. Saktijit Deydr. B. R. R. Kumar

survey executed u/s 133A and the seized/impounded material pertaining to U.K. Paints/Dhingra group, Shahi Group, Span Group and Vatika group and others. The ld. CIT(A) referred to the seized material, loan agreements, the extension of loan agreements, agreements with the guarantors, loan-cum-purchase agreements and material pertaining to buy-back agreements. 30. Before

M/S. U.K. PAINTS INDIA PVT. LTD.,NEW DELHI vs. ACIT, NEW DELHI

In the result, the appeals of the assessee are allowed, the COs of the assessee are allowed for statistical purpose and the appeals of the Revenue are dismissed

Bench: Sh. Saktijit Deydr. B. R. R. Kumar

survey executed u/s 133A and the seized/impounded material pertaining to U.K. Paints/Dhingra group, Shahi Group, Span Group and Vatika group and others. The ld. CIT(A) referred to the seized material, loan agreements, the extension of loan agreements, agreements with the guarantors, loan-cum-purchase agreements and material pertaining to buy-back agreements. 30. Before