COMMISSIONER OF INCOME TAX

capital gains” and “income from other sources”. Then comes Section 14A, which we will be examining later on. Chapter IV consists of Sections 14 to 59 and deals with computation/quantification under separate heads of income mentioned in Section 14. Chapter V of the Act deals with income of other persons, which are to be included in the assessee‟s total

ACIT(OSD), RANGE-10, NEW DELHI, C.R. BUILDING, ITO NEW DELHI vs. GYAN ENTERPRISES PVT. LTD. , PUNJABI BHAWAN, DELHI

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

capital gains have been earned on shares sold from this portfolio which is managed by the PMS provider M/s Guardian Advisors. Accordingly, I am in agreement with the A.O that the payment of Rs 44.23 lakhs made on account of Portfolio management charges is directly related to the 3 | P a g e ITA Nos.94, 93 & 92/Del/2024 & 109 & 176/Del/2024 exempted

GYAN ENTERPRISES PRIVATE LIMITED,NEW DELHI vs. ACIT CIRCLE 10(2), NEW DELHI

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

capital gains have been earned on shares sold from this portfolio which is managed by the PMS provider M/s Guardian Advisors. Accordingly, I am in agreement with the A.O that the payment of Rs 44.23 lakhs made on account of Portfolio management charges is directly related to the 3 | P a g e ITA Nos.94, 93 & 92/Del/2024 & 109 & 176/Del/2024 exempted

GYAN ENTERPRISES PRIVATE LIMITED ,DELHI vs. DCIT CIRCLE 10(2), NEW DELHI

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

capital gains have been earned on shares sold from this portfolio which is managed by the PMS provider M/s Guardian Advisors. Accordingly, I am in agreement with the A.O that the payment of Rs 44.23 lakhs made on account of Portfolio management charges is directly related to the 3 | P a g e ITA Nos.94, 93 & 92/Del/2024 & 109 & 176/Del/2024 exempted

ACIT(OSD), RANGE-10, NEW DELHI, C.R. BUILDING ITO vs. GYAN ENTERPRISES PVT. LTD. , ROUSE AVENUE, NEW DELHI

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

capital gains have been earned on shares sold from this portfolio which is managed by the PMS provider M/s Guardian Advisors. Accordingly, I am in agreement with the A.O that the payment of Rs 44.23 lakhs made on account of Portfolio management charges is directly related to the 3 | P a g e ITA Nos.94, 93 & 92/Del/2024 & 109 & 176/Del/2024 exempted

GYAN ENTERPRISES PVT LTD,NEW DELHI vs. DCIT CIRCLE 10(2), NEW DELHI

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

capital gains have been earned on shares sold from this portfolio which is managed by the PMS provider M/s Guardian Advisors. Accordingly, I am in agreement with the A.O that the payment of Rs 44.23 lakhs made on account of Portfolio management charges is directly related to the 3 | P a g e ITA Nos.94, 93 & 92/Del/2024 & 109 & 176/Del/2024 exempted

LIFESTYLE AND MEDIA HOLDING LTD,NEW DELHI vs. ACIT, CIRCLE-18(1), NEW DELHI

In the result, this appeal of the assessee is allowed

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.3714/Del/2024 (Assessment Year 2015-16) Dy. Commissioner Of Lifestyle & Media Holding Income Tax, Limited (Formerly Known As Ndtv Vs. C.R. Building, Lifestyle Holdings Limited) New Delhi. Plot No.09, Unit No. 055, Ground Floor Capia, Corporate Suites, Jasola, New Delhi-110025. Pan-Aadcn3076F (Appellant) (Respondent) Shri R.P. Mall, Adv. Assessee By Department By Ms. Ankush Kalra, Sr. Dr Date Of Hearing 29/10/2025 Date Of Pronouncement 31/12/2025 O R D E R [ Per Bench: All The Captioned Appeals Filed By The Assessee Against The Separate Orders Passed By Learned Commissioner Of Income Tax (Appeals)-6, Delhi [Ld. Cit(A)] For Ay 2014-15 To 1016017 & Having Common Issues, Therefore, They Are Dispose- Off By A Common Order. First, We Taken Assessee Appeal For Ay 2014-15 In Ita No. 64/Del/2019. Ita No.3714/Del/2024 & Lifestyle & Media Holdings Limited Vs. Dci

Capital gains' in case there was a profit or loss on sale of shares or it would yield dividend income which would fall under the head 'Income from other sources'. In the case of the assessee it was noted that merely terming the activity of holding of investment as "business to act as a holding company" does not entitled

LIFESTYLE AND MEDIA HOLDINGS LIMITED,DELHI vs. DY. COMMISSIONER OF INCOME TAX, CIRCLE 18(1), NEW DELHI, NEW DELHI

In the result, this appeal of the assessee is allowed

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.3714/Del/2024 (Assessment Year 2015-16) Dy. Commissioner Of Lifestyle & Media Holding Income Tax, Limited (Formerly Known As Ndtv Vs. C.R. Building, Lifestyle Holdings Limited) New Delhi. Plot No.09, Unit No. 055, Ground Floor Capia, Corporate Suites, Jasola, New Delhi-110025. Pan-Aadcn3076F (Appellant) (Respondent) Shri R.P. Mall, Adv. Assessee By Department By Ms. Ankush Kalra, Sr. Dr Date Of Hearing 29/10/2025 Date Of Pronouncement 31/12/2025 O R D E R [ Per Bench: All The Captioned Appeals Filed By The Assessee Against The Separate Orders Passed By Learned Commissioner Of Income Tax (Appeals)-6, Delhi [Ld. Cit(A)] For Ay 2014-15 To 1016017 & Having Common Issues, Therefore, They Are Dispose- Off By A Common Order. First, We Taken Assessee Appeal For Ay 2014-15 In Ita No. 64/Del/2019. Ita No.3714/Del/2024 & Lifestyle & Media Holdings Limited Vs. Dci

Capital gains' in case there was a profit or loss on sale of shares or it would yield dividend income which would fall under the head 'Income from other sources'. In the case of the assessee it was noted that merely terming the activity of holding of investment as "business to act as a holding company" does not entitled

LIFESTYLE AND MEDIA HOLDING LTD,NEW DELHI vs. DCIT, CIRCLE-18(1), NEW DELHI

In the result, this appeal of the assessee is allowed

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.3714/Del/2024 (Assessment Year 2015-16) Dy. Commissioner Of Lifestyle & Media Holding Income Tax, Limited (Formerly Known As Ndtv Vs. C.R. Building, Lifestyle Holdings Limited) New Delhi. Plot No.09, Unit No. 055, Ground Floor Capia, Corporate Suites, Jasola, New Delhi-110025. Pan-Aadcn3076F (Appellant) (Respondent) Shri R.P. Mall, Adv. Assessee By Department By Ms. Ankush Kalra, Sr. Dr Date Of Hearing 29/10/2025 Date Of Pronouncement 31/12/2025 O R D E R [ Per Bench: All The Captioned Appeals Filed By The Assessee Against The Separate Orders Passed By Learned Commissioner Of Income Tax (Appeals)-6, Delhi [Ld. Cit(A)] For Ay 2014-15 To 1016017 & Having Common Issues, Therefore, They Are Dispose- Off By A Common Order. First, We Taken Assessee Appeal For Ay 2014-15 In Ita No. 64/Del/2019. Ita No.3714/Del/2024 & Lifestyle & Media Holdings Limited Vs. Dci

Capital gains' in case there was a profit or loss on sale of shares or it would yield dividend income which would fall under the head 'Income from other sources'. In the case of the assessee it was noted that merely terming the activity of holding of investment as "business to act as a holding company" does not entitled