MR. NIKHIL SAWHNEY,NEW DELHI vs. ACIT, NOIDA

In the result, appeal of the assessee is dismissed

Bench: Shri Bhavnesh Saini & Shri Prashant Maharishimr. Nikhil Sawhney Acit, 17 – Sunder Nagar, Central Circle, Vs. New Delhi – 110 003. Noida. Pan: Aaups0222Q (Appellant) (Respondent)

VII of the Finance (No.2) Act, 2004 comes into force; and (b) such transaction is chargeable to securities transaction tax under that Chapter: Provided that the income by way of long-term capital gain of a company shall be taken into account in computing the book profit and income-tax payable under section 115JB. 6 Explanation.-For the purposes

DCIT, NEW DELHI vs. DR. PRANNOY ROY, NEW DELHI

Bench: Shri Beena A Pillai & Shri Prashant Maharishi

9. In that report, it was further noted that Dr Roy & Radhika Roy have opened joint demat account. The first lots of 4835850 shares of NDTV limited were purchased on 26/12/2007 in open offer through/exchange at RS. 430/– per share resulting into cost of acquisition of Rs. 2,07,95,15,500/-. Thereafter, total 1250000 shares of NDTV limited were

DR. PRANNOY ROY,,NEW DELHI vs. DCIT, NEW DELHI

Bench: Shri Beena A Pillai & Shri Prashant Maharishi

9. In that report, it was further noted that Dr Roy & Radhika Roy have opened joint demat account. The first lots of 4835850 shares of NDTV limited were purchased on 26/12/2007 in open offer through/exchange at RS. 430/– per share resulting into cost of acquisition of Rs. 2,07,95,15,500/-. Thereafter, total 1250000 shares of NDTV limited were

SMT. RADHIKA ROY,,NEW DELHI vs. DCIT, NEW DELHI

Bench: Shri Beena A Pillai & Shri Prashant Maharishi

9. In that report, it was further noted that Dr Roy & Radhika Roy have opened joint demat account. The first lots of 4835850 shares of NDTV limited were purchased on 26/12/2007 in open offer through/exchange at RS. 430/– per share resulting into cost of acquisition of Rs. 2,07,95,15,500/-. Thereafter, total 1250000 shares of NDTV limited were

SMT. RADHIKA ROY,,NEW DELHI vs. DCIT, NEW DELHI

Bench: Shri Beena A Pillai & Shri Prashant Maharishi

9. In that report, it was further noted that Dr Roy & Radhika Roy have opened joint demat account. The first lots of 4835850 shares of NDTV limited were purchased on 26/12/2007 in open offer through/exchange at RS. 430/– per share resulting into cost of acquisition of Rs. 2,07,95,15,500/-. Thereafter, total 1250000 shares of NDTV limited were

DCIT, NEW DELHI vs. MRS. RADHIKA ROY, NEW DELHI

Bench: Shri Beena A Pillai & Shri Prashant Maharishi

9. In that report, it was further noted that Dr Roy & Radhika Roy have opened joint demat account. The first lots of 4835850 shares of NDTV limited were purchased on 26/12/2007 in open offer through/exchange at RS. 430/– per share resulting into cost of acquisition of Rs. 2,07,95,15,500/-. Thereafter, total 1250000 shares of NDTV limited were

DR. PRANNOY ROY,,NEW DELHI vs. DCIT, NEW DELHI

Bench: Shri Beena A Pillai & Shri Prashant Maharishi

9. In that report, it was further noted that Dr Roy & Radhika Roy have opened joint demat account. The first lots of 4835850 shares of NDTV limited were purchased on 26/12/2007 in open offer through/exchange at RS. 430/– per share resulting into cost of acquisition of Rs. 2,07,95,15,500/-. Thereafter, total 1250000 shares of NDTV limited were

MR. SANJEEV GUPTA,NEW DELHI vs. ADDL.CIT, NEW DELHI

In the result, ground No. 3 and 4 With respect to the disallowance of export commission of the appeal of the assessee are allowed

Bench: Shri Amit Shukla & Shri Prashant Maharishisanjeev Gupta, Vs. Addl. Cit, E-31, Kamla Nagar, Range-20, New Delhi New Delhi Pan:Ahcpg7326A (Appellant) (Respondent)

vii) of ) sub-section (1) of section 9: (ia) thirty per cent of any sum payable to a resident, on which tax is deductible at source under Chapter XVIIB and such tax has not been deducted or, after deduction, has not been paid on or before the due date specified in sub-section (1) of section 139. Provided that where

BHARTI AIRTEL LTD.,GURGAON vs. ITO (TDS), NEW DELHI

In the result, all the Appeals of the Assessee are allowed and all the Revenue’s Appeals are dismissed

Bench: Shri H.S. Sidhu & Shri J. Sudhakar Reddy

Capital gains") for- (i) the transfer of all or any rights (including the granting of a licence) in respect of a patent, invention, model, design, secret formula or process or trade mark or similar property; (ii) the imparting of any information concerning the working of, or the use of, a patent, invention, model, design, secret formula or process or trade

ITO (TDS), NEW DELHI vs. BHARTI AIRTEL LTD., GURGAON

In the result, all the Appeals of the Assessee are allowed and all the Revenue’s Appeals are dismissed

Bench: Shri H.S. Sidhu & Shri J. Sudhakar Reddy

Capital gains") for- (i) the transfer of all or any rights (including the granting of a licence) in respect of a patent, invention, model, design, secret formula or process or trade mark or similar property; (ii) the imparting of any information concerning the working of, or the use of, a patent, invention, model, design, secret formula or process or trade

BHARTI AIRTEL LTD.,GURGAON vs. ITO (TDS), NEW DELHI

In the result, all the Appeals of the Assessee are allowed and all the Revenue’s Appeals are dismissed

Bench: Shri H.S. Sidhu & Shri J. Sudhakar Reddy

Capital gains") for- (i) the transfer of all or any rights (including the granting of a licence) in respect of a patent, invention, model, design, secret formula or process or trade mark or similar property; (ii) the imparting of any information concerning the working of, or the use of, a patent, invention, model, design, secret formula or process or trade

BHARTI AIRTEL LTD.,GURGAON vs. ITO (TDS), NEW DELHI

In the result, all the Appeals of the Assessee are allowed and all the Revenue’s Appeals are dismissed

Bench: Shri H.S. Sidhu & Shri J. Sudhakar Reddy

Capital gains") for- (i) the transfer of all or any rights (including the granting of a licence) in respect of a patent, invention, model, design, secret formula or process or trade mark or similar property; (ii) the imparting of any information concerning the working of, or the use of, a patent, invention, model, design, secret formula or process or trade

BHARTI AIRTEL LTD.,GURGAON vs. ITO (TDS), NEW DELHI

In the result, all the Appeals of the Assessee are allowed and all the Revenue’s Appeals are dismissed

Bench: Shri H.S. Sidhu & Shri J. Sudhakar Reddy

Capital gains") for- (i) the transfer of all or any rights (including the granting of a licence) in respect of a patent, invention, model, design, secret formula or process or trade mark or similar property; (ii) the imparting of any information concerning the working of, or the use of, a patent, invention, model, design, secret formula or process or trade

ITO (TDS), NEW DELHI vs. BHARTI AIRTEL LTD., GURGAON

In the result, all the Appeals of the Assessee are allowed and all the Revenue’s Appeals are dismissed

Bench: Shri H.S. Sidhu & Shri J. Sudhakar Reddy

Capital gains") for- (i) the transfer of all or any rights (including the granting of a licence) in respect of a patent, invention, model, design, secret formula or process or trade mark or similar property; (ii) the imparting of any information concerning the working of, or the use of, a patent, invention, model, design, secret formula or process or trade

ASIA SATELLITE TELECOMMUNICATIONS CO. LTD. vs. DIRECTOR OF INCOME TAX

The appeal of the Revenue is dismissed

capital asset situated in India. It, however, held that the appellant could be said to have a business connection in India because according to the Tribunal, in order to constitute a business connection, the test to be applied was that there must be an activity of the non-resident in India having an intimate relationship of a business character with

ACIT, NEW DELHI vs. M/S. EXPEDITORS INTERNATIONAL OF WASHINGTON,

In the result, the appeal of the revenue is dismissed

Bench: Ms. Sushma Chowladr. B. R. R. Kumar(E-Court Module) Ita No. 1740/Del/2015 : Asstt. Year : 2010-11 Asstt. Commissioner Of Income Vs M/S Expeditors International Of Washington, 1015, 3Rd Avenue, Tax, Circle-1(2)(2), International 12Th Floor, Seattle Washington Taxation, New Delhi (Appellant) (Respondent) Pan No. Aacce4315R Assessee By : Sh. Deepak Chopra, Adv. Revenue By : Sh. Satpal Gulati, Cit Dr Date Of Hearing: 25.08.2020 Date Of Pronouncement: 30.09.2020

vii) are as under: “9. (1) The following incomes shall be deemed45 to accrue or arise in India :— (i) all income accruing or arising, whether directly or indirectly, through or from any business connection in India, or through or from any property in India, or through or from any asset or source of income in India, [***] or through the transfer

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

DCIT, NEW DELHI vs. M/S. PURAN ASSOCIATES PVT. LTD., NEW DELHI

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

Bench: Shri Amit Shukla & Shri O.P. Kant

section 14A read with Rule 8D, takes into account only the interest component which can be attributed towards the income and not forming part of total income. It has nothing to do with the earning of interest income. 4. The Appellant craves to the allowed to amend, delete or add any other grounds of appeal during the course of hearing