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:

x) Long Term Capital gains as per A.O. = G) - (E) = Rs. 49,40,64,8001- (-) Rs. 11,20,12,407/- = Rs.38,20,52,393/- 12. Thus, the main issue for consideration is adoption of cost of acquisition of shares in computing the capital gains on sale thereof. The assessee has adopted indexed cost of acquisition with reference to the period

SUPERB MIND HOLDING LTD. ,NEW DELHI vs. ACIT CIRCLE INT TAX 3(1)(2), NEW DELHI

In the result, appeal of the assessee is allowed

Bench: Shri G.S. Pannu, Hon’Ble & Shri Challa Nagendra Prasadआ.अ.सं/.I.T.A No.1568/Del/2022 िनधा"रणवष"/Assessment Year: 2018-19

section 9(1)(i) of the Act, capital gain arising through or from the transfer of a capital asset situated in India would be deemed to accrue or arise in India in all cases irrespective of whether the capital asset is movable or immovable, tangible or intangible; the place of registration of the document of transfer etc. is in India

ESSAR COMMUNICATIONS LIMITED,MAURITIUS vs. ACIT, CIRCLE-1 (2)(2), NEW DELHI

Bench: SHRI SATBEER SINGH GODARA (Judicial Member), SHRI S. RIFAUR RAHMAN (Accountant Member)

24. The Assessee further submits that the LOB clause was inserted as Article 27A in the India-Mauritius DTAA only w.e.f. 1 April 2017 which provided for restriction on the benefits available under Article 13 of the DTAA that a company shall not be entitled to the benefits of Article 13 if the primary purpose was to take advantage

SANGEETA DEVI JHUNJHUNWALA,NEW DELHI vs. ITO, WARD-70(1), NEW DELHI

In the result, the appeal of the assessee is partly allowed

Bench: Dr. Brr Kumar & Ms. Astha Chandraasstt. Year: 2015-16

X to convert unaccounted cash under the guise of long term capital gain. 16.1.1 When the matter was taken by the Revenue before the Hon’ble Calcutta High Court it held that it has been established by the Revenue that the rise of prices of the shares was artificially done by adopting manipulative practices. Consequently, whatever resultant profit accrued from

SUDHAKAR ARORA,DELHI vs. ADIT, CPC, BENGALURU

In the result, the appeal of the assessee is dismissed

Bench: Shri Sunil Kumar Singh & Shri Brajesh Kumar Singh[Assessment Year: 2018-19]

2(24)(x) of the Act. Further the said amount is allowable as a 'deduction' under section 36 of the Act wherein section 36(1) provides 'The deductions provided for in the following clauses shall be allowed in respect of the matters dealt with therein, in computing the income referred to in section 28'. 11. Section

OC SWEATERS LLP,NEW DELHI vs. DCIT CPC, BANGALORE

In the result, the appeal of the assessee is allowed

Bench: Shri Challa Nagendra Prasadआ.अ.सं/.I.T.A No.1711/Del/2020 िनधा"रणवष"/Assessment Year: 2017-18 बनाम Oc Sweaters Llp, Dcit Cpc F-8, Okhla South East Delhi, Vs. Bangalore. New Delhi. Pan No. Aaefo8261B अपीलाथ" Appellant ""यथ"/Respondent

2(24)(x), Section 36(1)(va), Section 43B, Section 139(1) of the Income Tax Act, 1961, provisions of Finance Act 2021, Memorandum explaining the provisions in Finance Bill, 2021 and the specific amendments which will take effect from 01.04.2021, we hereby hold that no disallowance is called for belated payment of the employee’s contribution to the respective

HERO FINCORP LIMITED,NEW DELHI vs. ACIT, CIRCLE 11(1), DELHI, C.R. BUILDING

In the result, the appeal of the assessee is partly allowed

section 56(2)(viib). It is evidenced, during the appellate proceedings, by the\nfact that M/s. Otter Ltd has immediately sold certain no of shares to an India\nbased Indian resident entity. M/s. Link Investment Trust. It is clearly evident\nthat if M/s. Link Investment Trust had bought the shares of the appellant-\ncompany at such a huge premium

DCIT, CENTRAL CIRCLE-25, NEW DELHI vs. MAHAVEER TRANSMISSION LTD., NEW DELHI

In the result, the all appeals of the assessee are allowed and all the appeals of the Revenue are dismissed

Bench: Dr. B. R. R. Kumar, Sh. Sudhir Kumar

24, section 34AA, section 35 and section 37 of the Wealth-tax Act, 1957 (27 of 1957), shall, with necessary modifications, ITA Nos. 2844 to 2846/Del/2022 Mahavir Transmission Ltd. apply in relation to such reference as they apply in relation to a reference made by the Assessing Officer under sub-section (1) of section 16A of that Act. Explanation

MAHAVIR TRANSMISSION LTD,NEW DELHI vs. DCIT, CENTRAL CORCLE-25, NEW DELHI

In the result, the all appeals of the assessee are allowed and all the appeals of the Revenue are dismissed

Bench: Dr. B. R. R. Kumar, Sh. Sudhir Kumar

24, section 34AA, section 35 and section 37 of the Wealth-tax Act, 1957 (27 of 1957), shall, with necessary modifications, ITA Nos. 2844 to 2846/Del/2022 Mahavir Transmission Ltd. apply in relation to such reference as they apply in relation to a reference made by the Assessing Officer under sub-section (1) of section 16A of that Act. Explanation

MAHAVIR TRANSMISSION LTD,NEW DELHI vs. DCIT, CENTRAL CIRCLE-25, NEW DELHI

In the result, the all appeals of the assessee are allowed and all the appeals of the Revenue are dismissed

Bench: Dr. B. R. R. Kumar, Sh. Sudhir Kumar

24, section 34AA, section 35 and section 37 of the Wealth-tax Act, 1957 (27 of 1957), shall, with necessary modifications, ITA Nos. 2844 to 2846/Del/2022 Mahavir Transmission Ltd. apply in relation to such reference as they apply in relation to a reference made by the Assessing Officer under sub-section (1) of section 16A of that Act. Explanation

DCIT, CENTRAL CIRCLE-25, NEW DELHI vs. MAHAVEER TRANSMISSION LTD, NEW DELHI

In the result, the all appeals of the assessee are allowed and all the appeals of the Revenue are dismissed

Bench: Dr. B. R. R. Kumar, Sh. Sudhir Kumar

24, section 34AA, section 35 and section 37 of the Wealth-tax Act, 1957 (27 of 1957), shall, with necessary modifications, ITA Nos. 2844 to 2846/Del/2022 Mahavir Transmission Ltd. apply in relation to such reference as they apply in relation to a reference made by the Assessing Officer under sub-section (1) of section 16A of that Act. Explanation

DCIT, CENTRAL CIRCLE-25, NEW DELHI vs. MAHAVEER TRANSMISSION LTD, NEW DELHI

In the result, the all appeals of the assessee are allowed and all the appeals of the Revenue are dismissed

Bench: Dr. B. R. R. Kumar, Sh. Sudhir Kumar

24, section 34AA, section 35 and section 37 of the Wealth-tax Act, 1957 (27 of 1957), shall, with necessary modifications, ITA Nos. 2844 to 2846/Del/2022 Mahavir Transmission Ltd. apply in relation to such reference as they apply in relation to a reference made by the Assessing Officer under sub-section (1) of section 16A of that Act. Explanation

MAHAVIR TRANSMISSIN LTD ,NEW DELHI vs. DCIT, CENTRAL CIRCLE-25 , NEW DELHI

In the result, the all appeals of the assessee are allowed and all the appeals of the Revenue are dismissed

Bench: Dr. B. R. R. Kumar, Sh. Sudhir Kumar

24, section 34AA, section 35 and section 37 of the Wealth-tax Act, 1957 (27 of 1957), shall, with necessary modifications, ITA Nos. 2844 to 2846/Del/2022 Mahavir Transmission Ltd. apply in relation to such reference as they apply in relation to a reference made by the Assessing Officer under sub-section (1) of section 16A of that Act. Explanation

MAHAVIR TRANSMISSION LTD,NEW DELHI vs. DCIT, CENTRAL CIRCLE-25, NEW DELHI

In the result, the all appeals of the assessee are allowed and all the appeals of the Revenue are dismissed

Bench: Dr. B. R. R. Kumar, Sh. Sudhir Kumar

24, section 34AA, section 35 and section 37 of the Wealth-tax Act, 1957 (27 of 1957), shall, with necessary modifications, ITA Nos. 2844 to 2846/Del/2022 Mahavir Transmission Ltd. apply in relation to such reference as they apply in relation to a reference made by the Assessing Officer under sub-section (1) of section 16A of that Act. Explanation

MANKIND PHARMA LIMITED,DELHI vs. DCIT, CIRCLE-1(1)(1), MEERUT

In the result, the additional Ground No

Bench: Shri Challa Nagendra Prasad & Shri Pradip Kumar Kedia

gains of such eligible business for the purposes of the deduction under this section, take the amount of profits as may be reasonably deemed to have been derived therefrom: Provided that in case the aforesaid arrangement involves a specified domestic transaction referred to in section 92BA, the amount of profits from such transaction shall be determined having regard

GURBAKSHISH SINGH BATRA,NEW DELHI vs. PR. CIT - 12, NEW DELHI

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

Bench: Shri R.K. Panda & Shri N.K. Choudhryassessment Year: 2016-17 Gurbakshish Singh Batra, Vs Pr.Cit-12, E-1511, Wazir Nagr, New Delhi. Kotla Mubarakpur, New Delhi. Pan: Adspb2480J (Appellant) (Respondent) Assessee By : Shri R.S. Singhvi, Ca Revenue By : Shri Shashi Bhushan Sukla, Cit, Dr Date Of Hearing : 15.02.2022 Date Of Pronouncement : 31.03.2022 Order Per R.K. Panda, Am: This Appeal Filed By The Assessee Is Directed Against The Order Dated 22Nd March, 2021 Of The Pcit, Delhi-12, Passed U/S 263 Of The It Act For The Assessment Year 2016-17. 2. Facts Of The Case, In Brief, Are That The Assessee Is An Individual & Filed His Return Of Income On 6Th October, 2016 Declaring The Total Income At Rs.44,86,160/-. The Return Was Processed U/S 143(1) Of The It Act. Subsequently, The Case Of The Assessee Was Selected For ‘Limited Scrutiny’ Based On The Following Reasons:-

2 of section 50C is for the benefit of the Assessee to safeguard its interest and not to apply stamp duty value on a mechanical basis. 9. Referring to the decision of the coordinate Bench of the Tribunal in the case of M/s Charm Investment Private Limited vs Pr. CIT (ITA No. 3505/DEI/2019) (Dt. 1/05/2020) he submitted that the Tribunal

ACIT, CIRCLE-24(1), NEW DELHI vs. SPRING INFRADEV LTD., NEW DELHI

Bench: Shri Yogesh Kumar Us & Shri Brajesh Kumar Singh[Assessment Year:2016-17]

24 taxmann.com 343 (Mum. Trib.) v. Navdeep Investment (P.) Ltd. vs ITO [1994] 50 ITD 342(AHD Trib.) 8. The AO submitted a report vide letter dated 17/20.01.2025 on the grounds of Cross Objection of the filed by the assessee in which he agreed with the contention of the assessee that in view of the section

BIGSTAR HOTELS RESORTS PVT. LTD.,NEW DELHI vs. ITO WARD 5(1), NEW DELHI

In the result, the appeal of the assessee is partly allowed

24,931/- and short term capital gain was computed at INR 16,00,250/-.\n3. Against the said order, an appeal was filed before Ld. CIT(A) who vide impugned order dated 09.07.2024, upheld the action of the AO and confirmed the additions made.\n4. Aggrieved by the said order of Ld. CIT(A), the assessee preferred the present appeal

ADDL. CIT, NEW DELHI vs. M/S. METRO INSTITUTE OF MEDICAL SCIENCE PVT. LTD., NEW DELHI

In the result, the appeal of the Revenue in ITA No

Bench: Shri N.K. Billaiya & Shri Kul Bharat

capital limits vary in direct proportion to the net current assets. Similarly term loans granted are tied up for specific purposes and the Banker insists on bills etc. to monitor utilization. The presumption in such cases should be that the Banker have monitored the disbursements and that the loans granted by the banker have been utilized only for the purpose