VAIDYA MANGAT RAI FOUNDATION,CHANDIGARH vs. CIT(EXEMPTION), CHANDIGARH

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

Bench: Shri G. S. Pannu & Shri Anubhav Sharmavaidya Mangat Rai The Commissioner Of Foundation Vs. Income Tax (Exemptions) Friends Colony Chandigarh Gali No.2, Hansi Road Bhiwani. Pan-Aadtv 6078Q (Appellant) (Respondent) Assessee By Shri Tej Mohan Singh, Adv. Department By Ms. Sapna Bhattia, Cit-Dr Date Of Hearing 25/01/2024 Date Of Pronouncement 18/04/2024

Section 80G(5) of the Act. This will be the harmonious interpretation. 11. If we agree with the interpretation of the ld.CIT(E), then say a trust which was formed in the year 2000, performed charitable activities since 2000, but did not applied for registration u/s.80G, the said trust will never be able to apply for registration now. This

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

GENPACT SERVICES LLC,GURGAON vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE - INT TAX 1(3)(1), DELHI

In the result, appeal of the assessee is partly allowed

Bench: Shri Prakash Chand Yadav\Nand\Nshri Brajesh Kumar Singh\N\Nita No. 4477/Del/2024\N[Assessment Year: 2020-21]\N\N| Genpact Services Llc,\Nplot 22A & B, Sector 18,\Nudyog Vihar,\Ngurgaon, Haryana-122002\Npan-Aaccg3353P\Nappellant\N|\Nassistant Commissioner Of Income\Ntax, Circle-International Tax-1(3)(1),\Nvs Delhi-110002\Nrespondent\N\N| Appellant By\Nshri Vishal Kalra, Adv.,\Nms. Reema Malik, Adv.& Ms.\Nsnigdha Gautam, Adv.\Nrespondent By\Nshri S.K. Jadhav, Cit Dr\N\Ndate Of Hearing\N30.07.2025\Ndate Of Pronouncement\N31.07.2025\N\Norder\N\Nper Brajesh Kumar Singh, Am,\Nthis Appeal By The Assessee Is Directed Against The Order Of The\Nassessing Officer Dated 29.07.2024 Passed U/S 143(3) R.W.S.144C(13) Of\Nthe Income Tax Act, 1961 (Hereinafter ‘The Act') In Pursuance To The\Ndirections Of Dispute Resolution Panel Dated 25.06.2024 Pertaining To\N Assessment Year 2020-21.\N2. The Relevant Facts Are That The Assessee Is An Indian Branch Office Of\Ngenpact Llc, A Usa Company. The Assessee Is A Service Provider\Nrendering Off-Shore Support Services Akin To Bpo Services, Including\Ncollections/Analytics Call Centre Services & Other Back-Office Support\Nservices To Its Aes. The Assessee Is Responsible For Rendering The\Ndesignated Bpo / Collections Services From Its Facility / Infrastructure In\Nindia. As For Assessment Year 2020-21, The Assessee Filed Its Return Of\Nincome (Roi') Declaring An Income Of Inr 20,57,10,540/- On 07.01.2021.\Nduring The Course Of Scrutiny, The Assessing Officer Made A Reference U/S\N92Ca Of The Act To The Transfer Pricing Officer (Tpo') To Determine The\Narm'S Length Price (‘Alp') In Respect Of International Transaction Entered\Ninto By The Assessee.\N2.

gains of business or profession'. Therefore, such\nexplanation is not applicable for determining allowability of\ndeduction under section 80G of the Act.\nd) On perusal of section 80G of the Act it is clear that restrictions\non deductibility of a donation made pursuant to CSR\nobligations is expressly provided under section 80G(2)(a)\n(ilihk)/(ilihl

JAGAT PAL GUPTA,DELHI vs. ACIT, NEW DELHI

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

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.

section 80G of the Act. The application for rectification has been disposed off vide order u/s 154/143(3) of the Act, on 03.09.2013, after the filing of appeal, and the demand created was reduced to Rs. 36,310/-.The Assessee preferred an Appeal challenging the assessment order dated 22/03/2013 before the CIT(A) which came to be dismissed vide impugned

JAGATPAL GUPTA,DELHI vs. ACIT, NEW DELHI

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

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.

section 80G of the Act. The application for rectification has been disposed off vide order u/s 154/143(3) of the Act, on 03.09.2013, after the filing of appeal, and the demand created was reduced to Rs. 36,310/-.The Assessee preferred an Appeal challenging the assessment order dated 22/03/2013 before the CIT(A) which came to be dismissed vide impugned

TERADATA INDIA PVT LTD,GRUGRAM vs. DCIT CIRCLE-3(1), GURUGRAM

Appeal of the revenue is allowed for AY 2018-19

Bench: Shri M. Balaganesh & Shri Yogesh Kumar Us

5. That once working capital adjustment is granted no separate adjustment on account of outstanding receivables is maintainable. Part II-Corporate Tax Grounds 6. Denial of deduction under Section 80G. 6.1. That on the facts and circumstances of the case and in law, the Learned AO has erred in disallowing the deduction of INR 21,47.646/- claimed under section 80G

TERADATA INDIA P.LTD,GURUGRAM vs. DCIT,CIRCLE-3(1), GURUGRAM

Appeal of the revenue is allowed for AY 2018-19

Bench: Shri M. Balaganesh & Shri Yogesh Kumar Us

5. That once working capital adjustment is granted no separate adjustment on account of outstanding receivables is maintainable. Part II-Corporate Tax Grounds 6. Denial of deduction under Section 80G. 6.1. That on the facts and circumstances of the case and in law, the Learned AO has erred in disallowing the deduction of INR 21,47.646/- claimed under section 80G

ACIT-CIRCLE-3(1), GURGAON vs. TERADATA INDIA PRIVATE LIMITED, GURGAON

Appeal of the revenue is allowed for AY 2018-19

Bench: Shri M. Balaganesh & Shri Yogesh Kumar Us

5. That once working capital adjustment is granted no separate adjustment on account of outstanding receivables is maintainable. Part II-Corporate Tax Grounds 6. Denial of deduction under Section 80G. 6.1. That on the facts and circumstances of the case and in law, the Learned AO has erred in disallowing the deduction of INR 21,47.646/- claimed under section 80G

REC LIMITED,NEW DELHI vs. ACIT-10 (OSD), DELHI, NEW DELHI

gains of business or profession\" (before making any\ndeduction under this clause) carried to such reserve account\"\n2.4 That the Income Tax Department has drawn any adverse inference on\nthe said issue in the preceding years but has drawn favourable\ninference in the subsequent years. The details are as under:\nAY\n2015-16\n2\n5\n2016-17\nT\nh\n2017

JCIT(OSD), RANGE-10, NEW DELHI , ITO C.R. BUILDING vs. RURAL ELECTRIFICATION CORPORATION LTD. , KASTURBA NAGAR

In the result, appeals filed by the revenue in the AY 2020-21 and AY\n2021-22 are dismissed

gains of business or profession\" (before making any\ndeduction under this clause) carried to such reserve account\"\n2.4 That the Income Tax Department has drawn any adverse inference on\nthe said issue in the preceding years but has drawn favourable\ninference in the subsequent years. The details are as under:\nAY\nAmount of\nupfront fees,\nprocessing etc\n(Rs.)\nAmount

REC LIMITED,NEW DELHI vs. ACIT-10 (OSD), DELHI, NEW DELHI

gains of business or profession\" (before making any\ndeduction under this clause) carried to such reserve account\"\n2.4 That the Income Tax Department has drawn any adverse inference on\nthe said issue in the preceding years but has drawn favourable\ninference in the subsequent years. The details are as under:\nAmount of\nAmount of\nAY\nupfront fees,\nprocessing

JCIT(OSD), RANGE-10, NEW DELHI , CR BUILDING ITO vs. RURAL ELECTRIFICATION CORPORATION LTD. , KASTURBA NAGAR

gains of business or profession\" (before making any\ndeduction under this clause) carried to such reserve account\"\n2.4 That the Income Tax Department has drawn any adverse inference on\nthe said issue in the preceding years but has drawn favourable\ninference in the subsequent years. The details are as under:\nAY\nAmount of\nupfront fees,\nprocessing etc\n(Rs.)\nAmount

JCIT(OSD), RANGE-10, NEW DELHI , C.R. BUILDING ITO vs. RURAL ELECTRIFICATION CORPORATION LTD., KASTURBA NAGAR

gains of business or profession\" (before making any\ndeduction under this clause) carried to such reserve account\"\n2.4 That the Income Tax Department has drawn any adverse inference on\nthe said issue in the preceding years but has drawn favourable\ninference in the subsequent years. The details are as under:\nAY\nAmount of\nupfront fees,\nprocessing etc\n(Rs.)\nAmount

JCIT(OSD), RANGE-10, NEW DELHI , C.R. BUILDING ITO vs. RURAL ELECTRIFICATION CORPORATION LTD. , KASTURBA NAGAR

In the result, appeals filed by the revenue in the AY 2020-21 and AY\n2021-22 are dismissed

gains of business or profession\" (before making any\ndeduction under this clause) carried to such reserve account\"\n2.4 That the Income Tax Department has drawn any adverse inference on\nthe said issue in the preceding years but has drawn favourable\ninference in the subsequent years. The details are as under:\nAmount of\nAmount of\nAY\nprocessing fee\ndisallowed

DIRECTOR OF INCOME TAX-(EXEMPTION) vs. THE AJAY G. PIRAMAL FOUNDATION

The appeal is dismissed

80G was also accorded vide order dated 31.01.2006. 3. Return, declaring income „Nil‟ income, for the assessment year 2006-07 was filed on 30.10.2006. On 10.01.2007, the respondent assessee filed a revised return declaring income of Rs.13,95,711/-. We shall be referring to the note appended by the assessee, as to why the revised return was filed, subsequently. During

MUKUT BEHARI LAL BHARGAVA,GURGAON vs. ACIT, CIRCLE(2)1, GURGAON

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

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalmukut Behari Lal Bhargava, Acit, Lcg 05, 04B Laburnum Complex, Circle-2(1), 1 4Th Floor, Sushant Lok 1, Vs. Gurgaon. Block-A, Sector-28 Haryana-122009. Pan-Adipb9356P (Appellant) (Respondent) Assessee By None Department By Shri Pradumna Kumar Singh, Sr. Dr Date Of Hearing 03.09.2025 Date Of Pronouncement 26.11.2025 O R D E R Per Manish Agarwal, Am: This Appeal Is Filed By The Assessee Against The Order Of The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Cit(A) In Short] In Appeal No. Cit(A), Gurugaon-1/10738/2018-19 Dated 05.02.2025 Passed U/S 250 Of The Income Tax Act, 1961 (The Act, In Short) For Assessment Year 2016-17. 2. Brief Facts Of The Case Are That The Assessee Is An Individual & Filed Its Return Of Income Declaring Total Income Of Rs.1,20,41,040/-. The Case Of The Assessee Was Selected For Limited Scrutiny & During The Course Of Assessment Proceedings, The Assessing Officer Has Issued Various Notices Which Were Replied By The Assessee. Mukut Behari Lal Bhargava Vs. Acit 3. Thereafter, The Assessment Order Was Passed At A Total Income Of Rs.1,79,36,182/- By Making Disallowance On Account Of Expenses Claimed On Costs Of Improvement Of Capital Asset, Disallowance Of Carry Forward Of Short Term Capital Gains & Long Term Capital Loss & Also Denied The Deduction Claimed U/S 80G Of The Act.

5. Heard both the parties and perused the material available on record. 6. In Ground of appeal No. 1 assessee has challenged the denial of deduction claimed towards indexed cost of improvement from the computation of long terms capital gains arising out of the sale of house property. From the perusal of appellate order, it is seen that

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

80G of the Act; (ix) Non-allowance of amount paid as education cess, though this ground has not been pressed. Therefore, the same is dismissed as not pressed. 3. The above concise grounds shall take care of grounds of appeal from Sl. No. 40 till 63 of the appeal memo. Grounds raised vide Ground Nos. 1 to 39 are related

SICPA INDIA P.LTD,NEW DELHI vs. ACIT, CIRCLE-23(2), NEW DELHI

In the result, the Ground No

Bench: SHRI SHAMIM YAHYA (Accountant Member), SHRI YOGESH KUMAR U.S. (Judicial Member)

80G as per return :Rs.92,91,475/- u/s 80IC as discussed above :Rs.38,50,64,733/- :Rs.39,43,56,208/- Total Income as assessed :Rs.20,15,03,270/- Book Profit u/s 115JB: Book profit as per return : Rs.56,41,92,385/- Add: Claim of provision for FBT disallowed as discussed : Rs. 8,00,00/- Book profit u/s 115JB as assessed

RAJ KUMAR KARANWAL,MUZAFFARNAGAR vs. PR.CIT, DEHRADUN

In the result, the appeal of the assessee is allowed

Bench: Shri Shamim Yahya & Ms. Astha Chandraasstt. Year 2010-11

capital gain of half of Rs. 50,220/- i.e. Rs. 25,110/- which he declared in his return. 5. The assessee also explained that the property sold on 21.08.2009 of Rs. 50,00,000/- is doubly reported. Therefore, AIR information regarding 3 sale of property of Rs. 1,35,00,000/- is incorrect. It should