(Now known as Sony India Limited)

36 of 142 valuation of the contract price and computation of the arm‘s length price, consequent assessments etc. are without jurisdiction and authority of law. 43. This argument on behalf of the assessees would have been weighty and perhaps justified, if the Legislature by the Finance Act, 2012 had not inserted sub-section (2B). The said Sub-Section

THE COMMISSIONER OF INCOME TAX vs. HCL INFOSYSTEMS LTD

1) of Section 49, shall be taken to be nil.” 34. While the words "or a right to manufacture" was inserted in clause (a) of sub-section (2) with effect from 1st April 1998, the words ‘or a trade mark or brand name associated with a business’ was inserted by the Finance Act, 2002 with effect from 1st April

GREEN INFRA WIND FARM ASSET LTD.,GURUGRAM vs. ACIT, CIRCLE 10(2), NEW DELHI

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

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Assessment Year : 2016-17] Green Infra Wind Farm Asset Ltd., Vs Acit, 5Th Floor, Tower C, Building No.8, Circle-10(2), Dlf Cyber City, Gurugram, New Delhi. Haryana-122002. Pan-Aaecg4080H Appellant Respondent Appellant By Shri Vartik Chokshi, Ca & Shri Biren Shah, Ca Respondent By Shri Rajesh Kumar Dhanesta, Sr.Dr Date Of Hearing 23.04.2025 Date Of Pronouncement 04.07.2025 Order

36. A provision can be validly made, provided it be in line with the prescriptions set out in AS-29. That accounting standard is not concerned with events of certainty or an ascertained liability as the AO and the Tribunal understood. In our considered view, the stand taken by the respondents firstly proceeds on the incorrect premise of the liability

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:-

36 months and, therefore, 2 the Capital Gain shall be treated as Short Term Capital Gain. However, in computation, the assessee has taken it as long term capital Asset. The above facts according to her clearly show that the AO has not made proper inquiry and verification. She, therefore, was of the opinion that the assessment order passed

SANJEEV AGRAWAL,NEW DELHI vs. ACIT, CC-15, NEW DELHI

In the result, both the appeals of the assessee areallowed

Bench: Shri Saktijit Dey, Vice-& Shri Girish Agrawal

1 Action Financial Services 511706 ACTIVE X (India) Ltd. 2 Associated Finileasing 531192 ACTIVE XT (Midas Infra Trade Ltd.) 3 Florence Investech Ltd. 532518 DELISTED X 4 Gini Silk Mills Ltd. 531744 ACTIVE X 5 Global Capital Markets 530263 ASM STAGE I X Limited 6 Innovative Tech Pack Ltd. 523840 ACTIVE X 7 JRI Industries and 506016 Suspended Z Infrastructure

SANJEEV AGRAWAL,NEW DELHI vs. ACIT, CC-15, NEW DELHI

In the result, both the appeals of the assessee areallowed

Bench: Shri Saktijit Dey, Vice-& Shri Girish Agrawal

1 Action Financial Services 511706 ACTIVE X (India) Ltd. 2 Associated Finileasing 531192 ACTIVE XT (Midas Infra Trade Ltd.) 3 Florence Investech Ltd. 532518 DELISTED X 4 Gini Silk Mills Ltd. 531744 ACTIVE X 5 Global Capital Markets 530263 ASM STAGE I X Limited 6 Innovative Tech Pack Ltd. 523840 ACTIVE X 7 JRI Industries and 506016 Suspended Z Infrastructure

BSC C&C JOINT VENTURE,NEW DELHI vs. DCIT CIRCLE-61(1),, NEW DELHI

In the result, appeal of the assessee is partly allowed for statistical purposes

Bench: Shri M Balaganesh & Ms. Astha Chandraasstt. Year: 2017-18

gains derived from an undertaking shall not be admissible unless the accounts of the undertaking for the previous year relevant to the assessment year for which the deduction is claimed have been audited by an accountant, as defined in the Explanation below sub- section (2) of section 288, and the assessee furnishes, along with his return of income, the report

INDUS TOWERS LIMITED (FORMERLY KNOWN AS BHARTI INFRATEL LTD AND AS SUCCESSOR IN INTEREST OF ERSTWHILE INDUS TOWER LTD) ,GURUGRAM, HARYANA vs. DCIT, CIRCLE 12(1), NEW DELHI

In the result, the appeal of the revenue is dismissed

Bench: Shri M. Balaganesh & Shri Vimal Kumarindus Towers Ltd (Formerly Vs. Dcit, Known As Bharti Infratel Ltd), Circle-12(1), 4Th Floor, Dlf Cybercity, New Delhi Building No. 10, Tower A, Dlf Qe, So Gurgaon, Haryana (Appellant) (Respondent) Pan: Aadcv0274F Acit, Vs. Indus Towers Ltd, 4Th Floor, Dlf Cybercity, Central Circle-10, New Delhi Gurgaon, Haryana (Appellant) (Respondent) Pan: Aadcv0274F Indus Towers Ltd (Formerly Vs. Dcit, Known As Bharti Infratel Ltd), Circle-12(1), 4Th Floor, Dlf Cybercity, New Delhi Building No. 10, Tower A, Dlf Qe, So Gurgaon, Haryana (Appellant) (Respondent) Pan: Aadcv0274F Assessee By : Shri Ajay Vohra, Sr. Adv Shri Rohit Jain, Adv Shri Deepesh Jain, Adv Ms. Shaurya Jain, Ca Revenue By: Shri Mukesh Kumar Jain, Cit Dr Date Of Hearing 12/09/2024 Date Of Pronouncement 10/12/2024

xii) of erstwhile Gift Tax Act, 1958, 'gift' was defined to mean 'transfer by one person to another of any existing movable or immovable property made voluntarily and without consideration in money or money's worth...". Thus, impugned transfer qualifies as 'gift' as per ascribed statutory meanings. AO/ CIT(A) treated two As regards the observations that the two steps

ACIT , CIRCLE 10, NEW DELHI vs. INDUS TOWER LIMITED, GURGAON

In the result, the appeal of the revenue is dismissed

Bench: Shri M. Balaganesh & Shri Vimal Kumarindus Towers Ltd (Formerly Vs. Dcit, Known As Bharti Infratel Ltd), Circle-12(1), 4Th Floor, Dlf Cybercity, New Delhi Building No. 10, Tower A, Dlf Qe, So Gurgaon, Haryana (Appellant) (Respondent) Pan: Aadcv0274F Acit, Vs. Indus Towers Ltd, 4Th Floor, Dlf Cybercity, Central Circle-10, New Delhi Gurgaon, Haryana (Appellant) (Respondent) Pan: Aadcv0274F Indus Towers Ltd (Formerly Vs. Dcit, Known As Bharti Infratel Ltd), Circle-12(1), 4Th Floor, Dlf Cybercity, New Delhi Building No. 10, Tower A, Dlf Qe, So Gurgaon, Haryana (Appellant) (Respondent) Pan: Aadcv0274F Assessee By : Shri Ajay Vohra, Sr. Adv Shri Rohit Jain, Adv Shri Deepesh Jain, Adv Ms. Shaurya Jain, Ca Revenue By: Shri Mukesh Kumar Jain, Cit Dr Date Of Hearing 12/09/2024 Date Of Pronouncement 10/12/2024

xii) of erstwhile Gift Tax Act, 1958, 'gift' was defined to mean 'transfer by one person to another of any existing movable or immovable property made voluntarily and without consideration in money or money's worth...". Thus, impugned transfer qualifies as 'gift' as per ascribed statutory meanings. AO/ CIT(A) treated two As regards the observations that the two steps

INDUS TOWERS LTD.,GURGAON vs. DCIT CIRCLE 12(1), NEW DELHI

In the result, the appeal of the revenue is dismissed

Bench: Shri M. Balaganesh & Shri Vimal Kumarindus Towers Ltd (Formerly Vs. Dcit, Known As Bharti Infratel Ltd), Circle-12(1), 4Th Floor, Dlf Cybercity, New Delhi Building No. 10, Tower A, Dlf Qe, So Gurgaon, Haryana (Appellant) (Respondent) Pan: Aadcv0274F Acit, Vs. Indus Towers Ltd, 4Th Floor, Dlf Cybercity, Central Circle-10, New Delhi Gurgaon, Haryana (Appellant) (Respondent) Pan: Aadcv0274F Indus Towers Ltd (Formerly Vs. Dcit, Known As Bharti Infratel Ltd), Circle-12(1), 4Th Floor, Dlf Cybercity, New Delhi Building No. 10, Tower A, Dlf Qe, So Gurgaon, Haryana (Appellant) (Respondent) Pan: Aadcv0274F Assessee By : Shri Ajay Vohra, Sr. Adv Shri Rohit Jain, Adv Shri Deepesh Jain, Adv Ms. Shaurya Jain, Ca Revenue By: Shri Mukesh Kumar Jain, Cit Dr Date Of Hearing 12/09/2024 Date Of Pronouncement 10/12/2024

xii) of erstwhile Gift Tax Act, 1958, 'gift' was defined to mean 'transfer by one person to another of any existing movable or immovable property made voluntarily and without consideration in money or money's worth...". Thus, impugned transfer qualifies as 'gift' as per ascribed statutory meanings. AO/ CIT(A) treated two As regards the observations that the two steps

SONY INDIA PVT. LTD.,NEW DELHI vs. NATIOANAL E- ASSESMENT CENTRE, NEW DELHI

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

Bench: Shri Chandra Mohan Garg & Shri N.K. Billaiya

xii. Reimbursement Paid by SID to its TNMM OP/OR 8,941,313 AEs xiii. Provision of advisory services TNMM OP/OC 21,349,094 xiv. Reimbursement received by SID Other NA 162,176,641 from its AEs Method XV. Receipt of Call Centre Services TNMM OP/OR 45,586,198 xvi. Receipt of IT Tools TNMM OP/OR 17,374,689 xvii Purchase

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

36. The AO has quoted bank statement of the supplier with respect to the above observation. ITA Nos. 2844 to 2846/Del/2022 Mahavir Transmission Ltd. i. It is evident from the bank statement reproduced by the AO himself that the assessee has made purchases through banking channels only which have also been duly received by these suppliers. ii. There

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

36. The AO has quoted bank statement of the supplier with respect to the above observation. ITA Nos. 2844 to 2846/Del/2022 Mahavir Transmission Ltd. i. It is evident from the bank statement reproduced by the AO himself that the assessee has made purchases through banking channels only which have also been duly received by these suppliers. ii. There

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

36. The AO has quoted bank statement of the supplier with respect to the above observation. ITA Nos. 2844 to 2846/Del/2022 Mahavir Transmission Ltd. i. It is evident from the bank statement reproduced by the AO himself that the assessee has made purchases through banking channels only which have also been duly received by these suppliers. ii. There

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

36. The AO has quoted bank statement of the supplier with respect to the above observation. ITA Nos. 2844 to 2846/Del/2022 Mahavir Transmission Ltd. i. It is evident from the bank statement reproduced by the AO himself that the assessee has made purchases through banking channels only which have also been duly received by these suppliers. ii. There

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

36. The AO has quoted bank statement of the supplier with respect to the above observation. ITA Nos. 2844 to 2846/Del/2022 Mahavir Transmission Ltd. i. It is evident from the bank statement reproduced by the AO himself that the assessee has made purchases through banking channels only which have also been duly received by these suppliers. ii. There

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

36. The AO has quoted bank statement of the supplier with respect to the above observation. ITA Nos. 2844 to 2846/Del/2022 Mahavir Transmission Ltd. i. It is evident from the bank statement reproduced by the AO himself that the assessee has made purchases through banking channels only which have also been duly received by these suppliers. ii. There

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

36. The AO has quoted bank statement of the supplier with respect to the above observation. ITA Nos. 2844 to 2846/Del/2022 Mahavir Transmission Ltd. i. It is evident from the bank statement reproduced by the AO himself that the assessee has made purchases through banking channels only which have also been duly received by these suppliers. ii. There