KREUZ CHALLENGER PTE LTD,SINGAPURE vs. ACIT, INTERNATIONAL TAXATION CIRCLE2(1)(2), NEW DELHI

The appeal of the assessee is allowed

Bench: Shri M. Balaganesh & Shri Anubhav Sharmaassessment Year: 2019-20 Kreuz Challenger Pte Ltd., Vs Acit, 2, Venture Drive, International Taxation #24-01 Vision Exchange, Circle 2(1)(2), Singapore , 999999 New Delhi. Pan : Aahck3082A

270A of the Act without appreciating that the Appellant has neither under- reported nor misreported its income for the relevant AY. All the above grounds are without prejudice to each other. The Appellant craves leave to add, alter, vary, omit, substitute or amend the above grounds of appeal, at any time before or at the time of hearing

SAC FINANCE COMANY LTD,HONG KONG vs. ACIT, CIRCLE INTERNATIONAL TAXATION 3(1)(2), NEW DELHI

In the result appeal of the assessee in ITA no

Bench: Shri Shamim Yahya & Shri Kul Bharatassessment Year: 2017-18

capital gains income in accordance with the provisions of section 48 of the Act and c) allowing reasonable opportunity of being heard to the Appellant. 5. On the facts and circumstances of the case and in law, the Ld. AO grossly erred in rejecting the financials of Wormhole for the period ended March 31, 2018, suo-moto submitted

RENU SINGH,DELHI vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-3, DELHI, DELHI

In the result, the appeal of the assessee is allowed

Bench: Shri Pradip Kumar Kedia & Shri Pradip Kumar Kedia & Shri Pradip Kumar Kedia & Shri Vimal Kumarshri Vimal Kumar

9. That the penalty proceedings initiated under Section 270A and 271D That the penalty proceedings initiated under Section 270A and 271D That the penalty proceedings initiated under Section 270A and 271D of the Act is incorrect, illegal and bad in law; of the Act is incorrect, illegal and bad in law; All of the above grounds of appeal are without

BHS INDIA HOLDINGS, INC.,NEW JERSEY, USA vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE INTERNATIONAL TAXATION 1(1)(2), DELHI

The appeal is allowed and the stay application which is tagged along is dismissed being infructous

Bench: Shri Gs Pannu & Shri Anubhav Sharma

9. Ld. Sr. Counsel, then has submitted that the AO despite acknowledging the fact that the Appellant was able to prove the tax residency and its claim regarding acquisition, possession and transfer of the shares under consideration in the final assessment order, has not followed the directions of the DRP while passing the final assessment order dated 27 October

THR INFRASTRUCTURE PTE LTD,GURGAON vs. DCIT, CIR.-3(1)(1), INTL TAX, NEW DELHI

In the result, the appeal of the assessee is allowed

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

capital gains arising from sale of CCD as annexed to final assessment order by applying the tax rate of 20% (instead of 10%) as stipulated in section 115 read with section 48 of the Income tax Act (Act) without appreciating that both sale consideration and purchase consideration of CCD are denominated in Indian currency (INR) and the case

THE GOLDEN STATE CAPITAL PTE LTD,SINGAPORE vs. DCIT CIRCLE 3(1)(1), INTERNATIONAL TAXATION, DELHI

Bench: Shri Kul Bharat & Shri M. Balaganeshthe Golden State Capital Pte Ltd, Vs. Dcit, 31, Tanglin Road, #03,-04, St. Circle-3(1)(1), Regis Residences, Singapore, International Taxation, Singapore, Singapore, 247912 Delhi (Appellant) (Respondent) Pan: Aagct8026Q Assessee By : Shri Deepak Chopra, Adv Shri Anmol, Adv Shri Priya, Adv Revenue By: Shri Vizay B. Vasanta, Cit Dr Date Of Hearing 31/05/2023 Date Of Pronouncement 23/08/2023

capital gains of INR 61,71,789/- and taxing the same in the hands of the Appellant in India. 18. That the AO has grossly erred in disregarding the premium paid for calculating cost of acquisition, in complete contradiction to the DRP Directions, thereby violating the mandate of section 144C(13) of the ITA. 19. That the conclusions

GE ENGINE SERVICES LLC,UNITED STATES OF AMERICA vs. ASSISTANT COMMISSIONER OF INCOME TAX, NEW DELHI

Bench: Shri Vikas Awasthy & Shri Brajesh Kumar Singh

Section 9(1)(vii) of the Act. the ITAT's findings on this point are, therefore, erroneous, this question is accordingly answered in favour of the revenue. On the basis of submission of assessee as well as discussion in the foregoing paras the services provided by the assessee are in the nature of fees for technical services u/s 9

INDIA PROPERTY (MAURITIUS) COMPANY II,MAURITIUS vs. ACIT, CIRCLE INT. TAXATION 2(1)(1), NEW DELHI

Bench: Shri G.S. Pannu, Hon’Ble & Shri Anubhav Sharma

section 270A(8) of the Act. 5. We have heard and perused the record. Learned Sr. counsel has primarily relied on Circular No. 789 of the CBDT 6. and landmark judgment of the Hon’ble Supreme Court In the case of UOI v. Azadi Bachao Andolan (2003) 263 ITR 706 (SC) and judgment of the Hon’ble Delhi High Court

MADHURITTU PURI,UNITED KINGDOM vs. DCIT, CIRCLE INTERNATIONAL TAXATION 2(2)(2) , NEW DELHI

In the result, the appeal of the assessee is allowed

Bench: Shri G.S. Pannu, Hon’Ble & Ms. Astha Chandraasstt. Year: 2019-20

270A(2) as initiated for alleged under-reporting of income is not applicable on the facts and under the law in Appellant’s case.” 3. Ground Nos. 1 to 5 relate to addition of Rs. 2,23,23,116/- towards long term capital gains on sale of residential property. The facts in brief are that the assessee a non resident

FIRESTONE INDUSTRIAL PRODUCTS INC,UNITED STATES vs. ACIT, CIRCLE 1(3)(1), NEW DELHI

The appeal is allowed and the impugned addition is deleted

Bench: the Ld. CIT(A), assessee had taken a plea that the company is a separate entity from its share holders/members and, with transfer of shares, assets of the company are not transferred, and the same continues to be held by the company. It was also explained that since the assessee did not have PAN at the time of sale of shares, buyer M/s Sundaram Industries Pvt. Ltd. deducted @20% plus surcharge and cess on such Long Term Capital Gain earned by the assessee, which is reflected in From 26AS an

capital gain in the hands of the assessee. 4 9. On the facts and circumstances of the case, the learned CIT(A) has grossly erred both on facts and in law in confirming the action of the AO initiating the penalty proceedings under section 270A

LM WIND POWER AS ,DENMARK vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE INTERNATIONAL TAX 2(2)(1), DELHI

In the result, ground raised by the assessee is allowed

Bench: Shris.Rifaur Rahman & Shri Yogesh Kumar U.S.Lm Wind Power As, Vs, Acit, Circle Juptervej 6, 6000 Kolding, International Tax 2(2)(1), Denmark – 999999. Delhi (Pan :Aabcl8590Q) (Appellant) (Respondent) Assessee By : Shri Ajay Vohra, Sr. Advocate Shri Aditya Vohra, Advocate Shri Arpitgoyal, Ca Revenue By : Shri Saroj Kumar Dubey, Cit Dr Date Of Hearing : 27.08.2025 Date Of Order : 21.11.2025 Order Per S. Rifaur Rahman: 1. This Appealpreferred By The Assessee Is Directed Against The Assessment Order Dated 27.01.2025 Passed By The Acit, Circle Int. Tax 2(2)(1), Delhi Under Section 143(3) R.W.S. 144C(13) Of The Income-Tax Act, 1961 (For Short ‘The Act”) For Assessment Year 2020-21 Pursuant To The Directions Of The Dispute Resolution Panel U/S 144C(5) Of The Act Raising Following Grounds Of Appeal :- “1. That On The Facts & Circumstances Of The Case & In Law, The Assessment Order Dated 29.07.2024 Passed Under Section 143(3) Read With Section 144C(13) Of The Income-Tax Act, 1961 (He Act") For Assessment Year 2020-21 Assessing The Total Income Of The Assessee At Rs.81,14, 14,893 Is Bad In Law, Void- Ab-Initio & Therefore, Liable To Be Quashed And/ Or Set Aside.

capital intensive in nature, it is dominated by few large global customers who have operations in major territories around the world (e.g., Siemens Gamesa, GE, etc.). He submitted that the buyers of the rotor blades mainly operate globally and have the same technical and business requirements in all locations, they strongly prefer to deal with global suppliers and have

ITO, WARD-1(1), FARIDABAD, FARIDABAD vs. CHAMAN, FARIDABAD

In the result, appeal of the assessee is allowed

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahmanassessment Year: 2017-18 Vs. Chaman, Income Tax Officer, Ward-1(1), H. No. 437, Sector-9, Faridabad Faridabad Pan: Bfapd6698P (Appellant) (Respondent) With C.O. No.103/Del/2024 [Arising Out Of Ita No.2774/Del/2024] Assessment Year: 2017-18 Vs. Income Tax Officer, Chaman, H. No. 437, Sector-9, Ward-1(1), Faridabad, Haryana Faridabad Pan: Bfapd6698P (Appellant) (Respondent) Assessee By Sh. Gaurav, Adv. Department By Sh. Rajesh Kumar Dhanesta, Sr. Dr Date Of Hearing 25.06.2025 Date Of Pronouncement 25.06.2025 Order Per Satbeer Singh Godara, Jm This Revenue’S Appeal Ita No. 2774/Del/2024 & Assessee’S Cross Objection C.O. No. 103/Del/2024 For Assessment Year 2017- 18, Arises Against The Commissioner Of Income Tax (Appeals)/National Faceless Appeal Centre [In Short, The

capital gain. In the case of Hari Singh (supra) while dealing with the similar question under identical set of facts while setting aside the matter to the file of the AO to examine the facts of the case and to apply the law as contained in the Income-tax Act, Hon'ble Supreme Court specifically directs that in case

BITO-LAGERTECHNIK BITTMANN GMBH,GARMANY vs. ACIT CIRCLE 1(1)(2), INTL. TAXATION, NEW DELHI

In the result, the appeal of the assessee is allowed

Bench: Sh. C. N. Prasaddr. B. R. R. Kumar

Section 270A of the Act, citing a case of ‘under-reporting of income in consequence of misreporting’, ignoring the fact that the entire income has been duly reported while furnishing the return of income; there is no income addition in the assessment order (only reclassification of nature of income and tax rate).” 3. The assessee is a company incorporated

GE PRECISION HEALTHCARE LLC,USA vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE 1(3)(1), MINTO ROAD, NEW DELHI

In the result, the appeal of the assessee is allowed

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

270A of the Act.” 3. Heard the arguments of both the parties and perused the material available on record. 3 GE Precision Healthcare LLC 4. GE Precision Healthcare LLC, is a company incorporated in the state of Delaware, USA. It carries on healthcare business for the General Electric group, and is a global medical device provider that designs, develops, manufactures

RAJEEV VASUDEVA,DELHI vs. DCIT CIRCLE INTERNATIONAL TAXATION 3(1) , DELHI

In the result, appeal of the assessee is partly allowed

Bench: us, the only effective issue to be decided in this appeal is as to whether the learned CIT(A) was justified in confirming the action of the learned AO in denying the claim of exemption under section 54F of the Act in the facts and circumstances of the instant case.

gains and details of property owned/held by him as under:- Sl. No. Particulars Remarks of assessee for Whether claiming exemption u/s 54F purchase deed provided 1. Flat AR 515A in A residential flat owned by the Yes the Aralias, DLF assessee and rented for the City, Gurgaon- year @ Rs.30 Lacs p.a. 122009 2. Unit in Emaar Deposit with builder since

SICPA INDIA PRIVATE LIMITED,DELHI vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE 22(2), DELHI

In the result, the appeal of the assessee is allowed

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal[ Sicpa India Private Limited, Asst. Cit, 308-312, Mercantile House, Circle -22(2), 15 K.G. Marg, Vs. Delhi. Delhi-110001. Pan-Aadcs6121L (Appellant) (Respondent) Assessee By Shri Akash Singhal, Ca Department By Shri Rajesh Kumar Dhanesta, Sr. Dr Date Of Hearing 22/07/2025 Date Of Pronouncement 17/10/2025 O R D E R Per Manish Agarwal, Am: This Appeal Is Filed By The Assessee Against The Order Of Ld. Commissioner Of Income Tax (Appeals)-24, New Delhi [Cit(A), In Short] Dated 28.11.2024 In Appeal No. Nfac/2019-20/10183865 Arising Out Of Order Passed U/S 143(3) Of The Income Tax Act, 1961 (Hereinafter Referred As ‘The Act’) Dated 30.09.2022 For Assessment Year 2020-21. 2. Brief Facts Of The Case Are That Assessee Is A Company Engaged In The Business Of Manufacturing & Distribution Of Security Inks. The Return Of Income For The Year Under Appeal Was E-Filed On 15.02.2021 Declaring Total Income At Rs.6,74,74,000/-. The Case Of The Assessee Was Taken Up For Scrutiny & The Order Was Passed U/S 143(3) On 30.09.2022 Wherein Disallowance Of Rs.23,09,391/- Was Made On Account Of Dividend Distributions Tax & Educational Cess Claimed By The Assessee As Sicpa India Private Limited Vs. Acit Expenses & Further Disallowance U/S 14A Of Rs.25,56,078/- Was Made & The Total Income Of The Assessee Was Assessed At Rs.7,71,05,940/-.

capital gain from debt oriented mutual funds cannot be placed in the category of exempt income u/s 14A of the Act and in these circumstances, Rule 8D(2) cannot be invoked. 28. Moreover, AO himself has excluded the investment from which non-exempt income has been earned by the assessee company in AY 2011-12 for purpose of computing average

WE ARE VOICES ENTERTAINMENT INC,GURGAON vs. DCIT INTERNATIONAL TAXATION 3(1)(1), DELHI

In the result, the appeal of the assessee is allowed

Bench: Shri G.S. Pannu, Hon’Ble & Ms. Astha Chandraasstt. Year: 2019-20

270A of the Act mechanically and without recording any adequate satisfaction for such initiation.” 3. Briefly stated, the assessee is a non-resident company incorporated under the laws of USA and is a tax resident of USA. The assessee is engaged in the business of branding and talent book agency services and inter alia acts as a mediator

HOUSING & URBAN DEVELOPMENT CORPORATION LTD.,NEW DELHI vs. DCIT, NEW DELHI

Appeals of the assessee stands allowed

Bench: Shri R.K. Panda & Shri Sudhanshu Srivastava

capital gains to tax in the return of income. During the course of assessment proceedings when these incomes were picked up by the tax officer, the taxpayer admitted earning of the incomes and filed a revised computation of income. Based on this finding, the tax officer mentioned in the assessment order that penalty proceedings under Section