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10 results for “capital gains”+ Section 44Cclear

Sorted by relevance

Mumbai14Delhi10Kolkata2

Key Topics

Section 35D7Section 40a6Section 576Section 80I6Business Income6Set Off of Losses6Section 44C3Double Taxation/DTAA3Disallowance3

DCIT, INTL. TAXATION, CIRCLE, GURGAON vs. CAIRN ENERGY HYDROCARBON LTD. , GURGAON

In the result, the appeals of the assessee are partly allowed and the appeals of the revenue are dismissed

ITA 5989/DEL/2018[2014-15]Status: DisposedITAT Delhi31 Jan 2023AY 2014-15

Bench: Sh. Saktijit Deydr. B. R. R. Kumarita No. 6357/Del/2013: Asstt. Year : 2010-11 Dcit, Vs Cairn Energy Hydrocarbon Ltd., C/O. Cairn India Ltd., 3Rd & 4Th Circle-3(2), International Taxation, Floor, Vipul Plaza, Suncity, Sector- New Delhi 54, Gurgaon (Appellant) (Respondent) Pan No. Aaccc3279J

For Appellant: Sh. Ajay Vohra, Sr. AdvFor Respondent: Sh. Gangadhar Panda, CIT-DR
Section 40aSection 57Section 80I

Capital gains. F.- Income from other sources. A.- Salaries.” 22. Further, Section 56 of the Income Tax Act reads as under: “Income of every kind which is not to be excluded from the total income under this Act shall be chargeable to income-tax under the head “Income from other sources”, if it is not chargeable to income- tax under

DDIT, NEW DELHI vs. M/S. CAIRN ENERGY HYDROCARBONS LTD., GURGAON

In the result, the appeals of the assessee are partly allowed and the appeals of the revenue are dismissed

ITA 6357/DEL/2013[2010-11]Status: DisposedITAT Delhi31 Jan 2023AY 2010-11

Bench: Sh. Saktijit Deydr. B. R. R. Kumarita No. 6357/Del/2013: Asstt. Year : 2010-11 Dcit, Vs Cairn Energy Hydrocarbon Ltd., C/O. Cairn India Ltd., 3Rd & 4Th Circle-3(2), International Taxation, Floor, Vipul Plaza, Suncity, Sector- New Delhi 54, Gurgaon (Appellant) (Respondent) Pan No. Aaccc3279J

For Appellant: Sh. Ajay Vohra, Sr. AdvFor Respondent: Sh. Gangadhar Panda, CIT-DR
Section 40aSection 57Section 80I

Capital gains. F.- Income from other sources. A.- Salaries.” 22. Further, Section 56 of the Income Tax Act reads as under: “Income of every kind which is not to be excluded from the total income under this Act shall be chargeable to income-tax under the head “Income from other sources”, if it is not chargeable to income- tax under

DCIT, INTL. TAXATION, CIRCLE, GURGAON vs. CAIRN ENERGY HYDROCARBON LTD. , GURGAON

In the result, the appeals of the assessee are partly allowed and the appeals of the revenue are dismissed

ITA 5988/DEL/2018[2013-14]Status: DisposedITAT Delhi31 Jan 2023AY 2013-14

Bench: Sh. Saktijit Deydr. B. R. R. Kumarita No. 6357/Del/2013: Asstt. Year : 2010-11 Dcit, Vs Cairn Energy Hydrocarbon Ltd., C/O. Cairn India Ltd., 3Rd & 4Th Circle-3(2), International Taxation, Floor, Vipul Plaza, Suncity, Sector- New Delhi 54, Gurgaon (Appellant) (Respondent) Pan No. Aaccc3279J

For Appellant: Sh. Ajay Vohra, Sr. AdvFor Respondent: Sh. Gangadhar Panda, CIT-DR
Section 40aSection 57Section 80I

Capital gains. F.- Income from other sources. A.- Salaries.” 22. Further, Section 56 of the Income Tax Act reads as under: “Income of every kind which is not to be excluded from the total income under this Act shall be chargeable to income-tax under the head “Income from other sources”, if it is not chargeable to income- tax under

CAIRN ENERGY HYDROCARBONS LTD.,GURGAON vs. DDIT, NEW DELHI

In the result, the appeals of the assessee are partly allowed and the appeals of the revenue are dismissed

ITA 6346/DEL/2013[2010-11]Status: DisposedITAT Delhi31 Jan 2023AY 2010-11

Bench: Sh. Saktijit Deydr. B. R. R. Kumarita No. 6357/Del/2013: Asstt. Year : 2010-11 Dcit, Vs Cairn Energy Hydrocarbon Ltd., C/O. Cairn India Ltd., 3Rd & 4Th Circle-3(2), International Taxation, Floor, Vipul Plaza, Suncity, Sector- New Delhi 54, Gurgaon (Appellant) (Respondent) Pan No. Aaccc3279J

For Appellant: Sh. Ajay Vohra, Sr. AdvFor Respondent: Sh. Gangadhar Panda, CIT-DR
Section 40aSection 57Section 80I

Capital gains. F.- Income from other sources. A.- Salaries.” 22. Further, Section 56 of the Income Tax Act reads as under: “Income of every kind which is not to be excluded from the total income under this Act shall be chargeable to income-tax under the head “Income from other sources”, if it is not chargeable to income- tax under

CAIRN ENERGY HYDROCARBON LTD. ,GURGAON vs. DCIT, INTL. TAXATION, CIRCLE, GURGAON

In the result, the appeals of the assessee are partly allowed and the appeals of the revenue are dismissed

ITA 6277/DEL/2018[2013-14]Status: DisposedITAT Delhi31 Jan 2023AY 2013-14

Bench: Sh. Saktijit Deydr. B. R. R. Kumarita No. 6357/Del/2013: Asstt. Year : 2010-11 Dcit, Vs Cairn Energy Hydrocarbon Ltd., C/O. Cairn India Ltd., 3Rd & 4Th Circle-3(2), International Taxation, Floor, Vipul Plaza, Suncity, Sector- New Delhi 54, Gurgaon (Appellant) (Respondent) Pan No. Aaccc3279J

For Appellant: Sh. Ajay Vohra, Sr. AdvFor Respondent: Sh. Gangadhar Panda, CIT-DR
Section 40aSection 57Section 80I

Capital gains. F.- Income from other sources. A.- Salaries.” 22. Further, Section 56 of the Income Tax Act reads as under: “Income of every kind which is not to be excluded from the total income under this Act shall be chargeable to income-tax under the head “Income from other sources”, if it is not chargeable to income- tax under

CAIRN ENERGY HYDROCARBON LTD. ,GURGAON vs. DCIT, INTL. TAXATION, CIRCLE, GURGAON

In the result, the appeals of the assessee are partly allowed and the appeals of the revenue are dismissed

ITA 6278/DEL/2018[2014-15]Status: DisposedITAT Delhi31 Jan 2023AY 2014-15

Bench: Sh. Saktijit Deydr. B. R. R. Kumarita No. 6357/Del/2013: Asstt. Year : 2010-11 Dcit, Vs Cairn Energy Hydrocarbon Ltd., C/O. Cairn India Ltd., 3Rd & 4Th Circle-3(2), International Taxation, Floor, Vipul Plaza, Suncity, Sector- New Delhi 54, Gurgaon (Appellant) (Respondent) Pan No. Aaccc3279J

For Appellant: Sh. Ajay Vohra, Sr. AdvFor Respondent: Sh. Gangadhar Panda, CIT-DR
Section 40aSection 57Section 80I

Capital gains. F.- Income from other sources. A.- Salaries.” 22. Further, Section 56 of the Income Tax Act reads as under: “Income of every kind which is not to be excluded from the total income under this Act shall be chargeable to income-tax under the head “Income from other sources”, if it is not chargeable to income- tax under

STANDARD CHARTERED GRINDLAYS LTD.,NEW DELHI vs. ACIT(INTERNATIONAL TAXATION), CIRCLE-3, NEW DELHI

In the result, the appeal of the assessee is allowed

ITA 21/DEL/2019[2003-04]Status: DisposedITAT Delhi01 Aug 2022AY 2003-04

Bench: Sh. Saktijit Deydr. B. R. R. Kumarita No. 21/Del/2019 : Asstt. Year : 2003-04 Standard Chartered Grindlays Ltd., Vs Acit(Intl. Taxation), 4, Todar Mal Lane, Bengali Market, Circle-3, New Delhi-110001 New Delhi (Appellant) (Respondent) Pan No. Aahcs3880Q Assessee By : Ms. Shashi M. Kapila, Adv. & Sh. Pravesh Sharma, Adv. Revenue By : Ms. Sapna Bhatia, Cit Dr Date Of Hearing: 29.06.2022 Date Of Pronouncement: 01.08.2022

For Appellant: Ms. Shashi M. Kapila, Adv. &For Respondent: Ms. Sapna Bhatia, CIT DR
Section 35DSection 44C

capital gains of Rs.232,21,57,920/-. Allowability of business expenditure incurred outside India which pertains only to the Indian Business: 4. The Assessing Officer disallowed the expenses which were incurred only for the Indian business outside India on the grounds that these are general head office & administrative expenses which fall under section 44C

M/S. BOMBARDIER TRANSPORTATION GMBH SCHONEBERGERUFER 1,NEW DELHI vs. DCIT (INTERNATIONAL TAXATION), NEW DELHI

In the result, both the appeals filed by the assessee are allowed

ITA 872/DEL/2016[2011-12]Status: DisposedITAT Delhi15 Nov 2023AY 2011-12

Bench: Shri Shamim Yahya & Shri Kul Bharat

For Appellant: Shri Anmol Anand, AdvocateFor Respondent: Shri Vizay B. Vasanta, CIT DR

44C (14,01,333) Net taxable profit 2,66,25,323 46. Therefore, in view of the above discussions, the income is proposed to be assessed as under :- Particulars Amount (in Rs.) Returned Income 25,19,77,876 Add : Net taxable profit to be taxed @ 40% plus 2,66,25,323 surcharge and cess (as computed above) Total

BOMBARDIER TRANSPORTATION GMBH,NEW DELHI vs. DCIT, CIRCLE- 1(1)(2), INTL. TAXATION, NEW DELHI

In the result, both the appeals filed by the assessee are allowed

ITA 5638/DEL/2018[2011-12]Status: DisposedITAT Delhi15 Nov 2023AY 2011-12

Bench: Shri Shamim Yahya & Shri Kul Bharat

For Appellant: Shri Anmol Anand, AdvocateFor Respondent: Shri Vizay B. Vasanta, CIT DR

44C (14,01,333) Net taxable profit 2,66,25,323 46. Therefore, in view of the above discussions, the income is proposed to be assessed as under :- Particulars Amount (in Rs.) Returned Income 25,19,77,876 Add : Net taxable profit to be taxed @ 40% plus 2,66,25,323 surcharge and cess (as computed above) Total

AMADEUS IT GROUP SA,SPAIN vs. ACIT, CIRCLE-1(1)(1) INT.TAXATION, NEW DELHI

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

ITA 1742/DEL/2023[2020-21]Status: DisposedITAT Delhi16 Oct 2023AY 2020-21

Bench: Shri G.S. Pannu, Hon’Ble & Ms. Astha Chandraasstt. Year: 2020-21

For Appellant: Sh. Neeraj Jain &For Respondent: Shri Vizay B. Vasanta, CIT-DR
Section 143(3)

44C of the Act. 14. That without prejudice the DRP/ assessing officer erred in facts and in law in erroneously computing the income of the alleged PE of the appellant. Re: CRS income- Royalty 15. That the DRP/ assessing officer erred on facts and in law in, alternatively, holding that booking fee of Euro 102,026,836/- received