MARUTI SUZUKI INDIA LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result, all the three appeals of the assessee are allowed as indicated above and the appeal of Revenue is partly allowed

Bench: Shris.Rifaur Rahman & Shri Vimal Kumar

gain of Rs.6,90,68,982/- as business income. 9.3 That the assessing officer erred on facts and in law in holding that investment in units of mutual funds and shares were made as a systematic business activity, without appreciating that such investments were made on capital account and not as “stock-in-trade”. 9.4 That the assessing officer erred

DLF LIMITED,DELHI vs. NATIONAL FACELESS ASSESSMENT CENTRE, DELHI

In the result, appeal of the Revenue is dismissed

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

capitalize the entire cost of spares in consonance with the mandatory provisions of Accounting Standards (AS) 2 and (AS) 10. 16.6 It is not disputed that the assessee is maintaining the accounts based on a mercantile system. Under sub- section (1) of section 145 of the Act the assessee's income which is chargeable under the head "Profits and gains

DCIT, CIRCLE-7(1), DELHI vs. DLF LIMITED, DELHI

In the result, appeal of the Revenue is dismissed

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

capitalize the entire cost of spares in consonance with the mandatory provisions of Accounting Standards (AS) 2 and (AS) 10. 16.6 It is not disputed that the assessee is maintaining the accounts based on a mercantile system. Under sub- section (1) of section 145 of the Act the assessee's income which is chargeable under the head "Profits and gains

DCIT, CIRCLE-7(1), DELHI vs. DLF LIMITED, DELHI

In the result, appeal of the Revenue is dismissed

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

capitalize the entire cost of spares in consonance with the mandatory provisions of Accounting Standards (AS) 2 and (AS) 10. 16.6 It is not disputed that the assessee is maintaining the accounts based on a mercantile system. Under sub- section (1) of section 145 of the Act the assessee's income which is chargeable under the head "Profits and gains

DLF LIMITED,DELHI vs. NATIONAL FACELESS ASSESSMENT CENTRE, DELHI

In the result, appeal of the Revenue is dismissed

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

capitalize the entire cost of spares in consonance with the mandatory provisions of Accounting Standards (AS) 2 and (AS) 10. 16.6 It is not disputed that the assessee is maintaining the accounts based on a mercantile system. Under sub- section (1) of section 145 of the Act the assessee's income which is chargeable under the head "Profits and gains

DCIT, CIRCLE-7(1), DELHI vs. DLF LIMITED, DELHI

In the result, appeal of the Revenue is dismissed

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

capitalize the entire cost of spares in consonance with the mandatory provisions of Accounting Standards (AS) 2 and (AS) 10. 16.6 It is not disputed that the assessee is maintaining the accounts based on a mercantile system. Under sub- section (1) of section 145 of the Act the assessee's income which is chargeable under the head "Profits and gains

M/S MARUTI SUZUKI INDIA LTD.,,NEW DELHI vs. DCIT, NEW DELHI

145 taxmann.com 136 (Ahd ITAT) – AY\n2011-12\nFurther, para 3 of the letter dated 02.05.2016 carves out the situation in which\nthe said Circular would not be applicable. None of the situations mentioned in\n\n35\npara 3 of the aforesaid Circular are applicable in the present facts in as much\nas –\n(i) the assessing officer

ACIT, NEW DELHI vs. M/S. KCT PAPERS LTD., NEW DELHI

In the result, grounds raised by the revenue are dismissed

Bench: Shri S.Rifaur Rahman & Shri Anubhav Sharmaacit, Circle 5 (1) Vs. M/S. Kct Papers Limited, New Delhi. Thapar House, 124, Janpath, New Delhi – 110 001. (Pan : Aacck4937D) (Appellant) (Respondent) Assessee By : Shri Rohit Jain, Advocate Shri Deepesh Jain, Advocate Shri Tavish Verma, Advocate Revenue By : Shri Kailash Dan Ratnoo, Cit Dr Date Of Hearing : 10.09.2025 Date Of Order : 05.12.2025 O R D E R Per S.Rifaur Rahman: 1. This Appeal Is Filed By The Assessee Against The Order Of Ld. Commissioner Of Income-Tax (Appeals)-Viii, New Delhi [Hereinafter Referred To As ‘Ld. Cit (A)] Dated 21.03.2014For Assessment Year 2008-09. 2. Brief Facts Of The Case Are, The Assessee Company Belongs To The Thapar Group Established By Late Lala Karam Chand Thapar. There Was A Family Settlement Between The Various Constituents Of The Karam Chand Thapar Family As A Result Of Which Revenue-Organization/Restructuring Of The Group Dated 27Th April, 2001. The Re April, 2001. The Re-Organization Of The Group Companies & Trusts Organization Of The Group Companies & Trusts Was Made Into Four Groups, As Under, Each Headed By The Sons Of Late Lala Was Made Into Four Groups, As Under, Each Headed By The Sons Of Late Lala Was Made Into Four Groups, As Under, Each Headed By The Sons Of Late Lala K.C. Thapar. The Family Tree Of Karam Chand T K.C. Thapar. The Family Tree Of Karam Chand Thapar Family Is Explained As Hapar Family Is Explained As Under In The Form Of A Diagrammatic Chart: Under In The Form Of A Diagrammatic Chart:

3,36,25,904 40. In this regard, it is respectfully submitted that aforesaid long-term capital gains were computed by the assessee by taking cost to MAL & KCTBL as its cost of acquisition as per section 49(1)(e) of the Act and including the period of holding of MAL & KCTBL in its period of holding while calculating

DABUR INVEST CORP,NEW DELHI vs. JCIT, RANGE-46, NEW DELHI

In the result, appeals of the Revenue are dismissed and appeal

Bench: Shri Challa Nagendra Prasad & Shri Avdhesh Kumar Mishraिनधा"रणवष"/Assessment Year: 2017-18 बनाम Acit, Dabur Invest Corp., 4Th Floor, Punjab Bhawan, Circle-46(1), Room No.106, Vs. Drum Shape Building, I.P. Estate, New Delhi. New Delhi. Pan No.Aadfd2529D अपीलाथ" Appellant ""यथ"/Respondent िनधा"रणवष"/Assessment Year: 2018-19 बनाम Acit, Dabur Invest Corp., 4Th Floor, Punjab Bhawan, Circle-46(1), Room No.106, Vs. Drum Shape Building, I.P. Estate, New Delhi. New Delhi. Pan No.Aadfd2529D अपीलाथ" Appellant ""यथ"/Respondent िनधा"रणवष"/Assessment Year: 2017-18 बनाम Dabur Invest Corp., Jcit, 4Th Floor, Punjab Bhawan, Vs. Range-46, New Delhi. New Delhi. Pan No.Aadfd2529D अपीलाथ" Appellant ""यथ"/Respondent िनधा"रणवष"/Assessment Year: 2018-19 बनाम Dabur Invest Corp., Jcit, 4Th Floor, Punjab Bhawan, Vs. Range-46, New Delhi. New Delhi. Pan No.Aadfd2529D अपीलाथ" Appellant ""यथ"/Respondent

145 (2) of The Income Tax Act as well as the Accounting Standard AS -9 issued by ICAI on Revenue Recognition. In that particular case, the income was received by the assessee without any uncertainty involved about the quantification or refund of such sum. Further as mentioned in para number 4.4 of the decision where the relevant provisions of that

ACIT, CIRCLE-46(1), NEW DELHI vs. DABUR INVEST CORP., DELHI

In the result, appeals of the Revenue are dismissed and appeal

Bench: Shri Challa Nagendra Prasad & Shri Avdhesh Kumar Mishraिनधा"रणवष"/Assessment Year: 2017-18 बनाम Acit, Dabur Invest Corp., 4Th Floor, Punjab Bhawan, Circle-46(1), Room No.106, Vs. Drum Shape Building, I.P. Estate, New Delhi. New Delhi. Pan No.Aadfd2529D अपीलाथ" Appellant ""यथ"/Respondent िनधा"रणवष"/Assessment Year: 2018-19 बनाम Acit, Dabur Invest Corp., 4Th Floor, Punjab Bhawan, Circle-46(1), Room No.106, Vs. Drum Shape Building, I.P. Estate, New Delhi. New Delhi. Pan No.Aadfd2529D अपीलाथ" Appellant ""यथ"/Respondent िनधा"रणवष"/Assessment Year: 2017-18 बनाम Dabur Invest Corp., Jcit, 4Th Floor, Punjab Bhawan, Vs. Range-46, New Delhi. New Delhi. Pan No.Aadfd2529D अपीलाथ" Appellant ""यथ"/Respondent िनधा"रणवष"/Assessment Year: 2018-19 बनाम Dabur Invest Corp., Jcit, 4Th Floor, Punjab Bhawan, Vs. Range-46, New Delhi. New Delhi. Pan No.Aadfd2529D अपीलाथ" Appellant ""यथ"/Respondent

145 (2) of The Income Tax Act as well as the Accounting Standard AS -9 issued by ICAI on Revenue Recognition. In that particular case, the income was received by the assessee without any uncertainty involved about the quantification or refund of such sum. Further as mentioned in para number 4.4 of the decision where the relevant provisions of that

DEVIDAYAL ALUMINIUM INDUSTRIES (P) LTD.,NEW DELHI vs. DCIT, GHAZIABAD

Bench: Shri Satbeer Singh Godara & Shri M. Balaganesh

section 145(3) of the Act. The factors enumerated by the A.O. in his orders under appeal and to clarify the issue in particular it is submitted that: (a) The stock in trade in respect of the three projects is no longer a capital asset. In any event capital gain

DEVIDAYAL ALUMINIUM INDUSTRIES (P) LTD.,NEW DELHI vs. DCIT, GHAZIABAD

Bench: Shri Satbeer Singh Godara & Shri M. Balaganesh

section 145(3) of the Act. The factors enumerated by the A.O. in his orders under appeal and to clarify the issue in particular it is submitted that: (a) The stock in trade in respect of the three projects is no longer a capital asset. In any event capital gain

ACIT, CIRCLE-46(1), NEW DELHI vs. DABUR INVEST CORP , DELHI

In the result, appeals of the Revenue are dismissed and appeal\nof the assessee for the AY 2017-18 is partly allowed as indicated\nabove and appeal of the assessee for the AY 2018-19 is dismissed

145 (2)\nof The Income Tax Act as well as the Accounting Standard\nAS -9 issued by ICAI on Revenue Recognition. In that\nparticular case, the income was received by the assessee\nwithout any uncertainty involved about the quantification\nor refund of such sum. Further as mentioned in para\nnumber 4.4 of the decision where the relevant provisions of\nthat

DABUR INVEST CORP,NEW DELHI vs. JCIT, RANGE-46, NEW DELHI

In the result, appeals of the Revenue are dismissed and appeal\nof the assessee for the AY 2017-18 is partly allowed as indicated\nabove and appeal of the assessee for the AY 2018-19 is dismissed

145 (2)\nof The Income Tax Act as well as the Accounting Standard\nAS -9 issued by ICAI on Revenue Recognition. In that\nparticular case, the income was received by the assessee\nwithout any uncertainty involved about the quantification\nor refund of such sum. Further as mentioned in para\nnumber 4.4 of the decision where the relevant provisions of\nthat

SAHARA INDIA POWER CORPORATION LTD.,,PUNE vs. ASSISTANT COMMISSIONER OF INCOME-TAX,,

In the result, the appeal filed by the revenue for the AY 2005-06 in I

Bench: Dr. B.R.R. Kumar & Shri Yogesh Kumar Us

gains "arose" from the transfer of a capital asset so as to attract Sections 45 and 48 of the Income Tax Act. We are, therefore, of the view that the High Court was correct in its conclusion, but for the ret ons stated by us hereinabove. The appeals are dismissed with no order as to costs." (emphasis supplied

SAHARA INDIA POWER CORPORATION LTD,PUNE vs. DCIT, NEW DELHI

In the result, the appeal filed by the revenue for the AY 2005-06 in I

Bench: Dr. B.R.R. Kumar & Shri Yogesh Kumar Us

gains "arose" from the transfer of a capital asset so as to attract Sections 45 and 48 of the Income Tax Act. We are, therefore, of the view that the High Court was correct in its conclusion, but for the ret ons stated by us hereinabove. The appeals are dismissed with no order as to costs." (emphasis supplied

DCIT, NEW DELHI vs. M/S. SAHARA INDIA POWER CORPORATION LTD., PUNE

In the result, the appeal filed by the revenue for the AY 2005-06 in I

Bench: Dr. B.R.R. Kumar & Shri Yogesh Kumar Us

gains "arose" from the transfer of a capital asset so as to attract Sections 45 and 48 of the Income Tax Act. We are, therefore, of the view that the High Court was correct in its conclusion, but for the ret ons stated by us hereinabove. The appeals are dismissed with no order as to costs." (emphasis supplied

BEST CITY REALTORS INDIA PVT. LTD,NEW DELHI vs. DEPUTY COMMISSIONER OF INCOME-TAX, NEW DELHI

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

Bench: Shri Saktijit Dey, Hon’Ble & Shri S.Rifaur Rahmanbest City Realtors India Pvt. Ltd., Vs. Dcit, Cc – 06, Plot No.H-8, 1St Floor, New Delhi. Netaji Subhash Place, Pitampura, New Delhi. (Pan : Aaccb7687B) (Appellant) (Respondent) Assessee By : Shri Salil Kapoor, Advocate Shri Shivam Yadav, Advocate Revenue By : Ms. Nimisha Singh, Cit Dr Date Of Hearing : 24.07.2024 Date Of Order : 04.10.2024 Order Per S.Rifaur Rahman,Am: This Appeal Has Been Filed By The Assessee Against The Order Of Ld. Commissioner Of Income Tax (Appeals)-24, New Delhi [“Ld. Cit(A)”, For Short] Dated 22.12.2014 For The Assessment Year 2011-12. 2. The Grounds Of Appeal Taken By The Assessee Read As Under :- “1. That In Making Addition, The Ld/- Cit(A) Has Erred In Recording Adverse Findings Which Were Not Only Based On Misappreciation Of Evidence But Are Also Based On Non Existent Facts & Such Findings As Recorded Are Factually Incorrect To State That The Assessee Company Has Manipulated The Transactions With C. R. Sons Builders & Developers

capital gain on sale of land located in village Banohar, Hasanpur, Ludhiana. The addition thus confirmed by the Ld. CIT(A) is unjustified and uncalled for. 2. That the Ld/- CIT(A) has further erred both on facts and in law while disposing of the case in completely brushing aside the detailed written submissions. Thus the order