PR. COMMISSIONER OF INCOME TAX, DELHI-1 vs. M/S BURDA DRUCK INDIA PVT. LTD.

delay is condoned. 3. Accordingly, the application is disposed of. Digitally Signed By:ATUL JAIN Signing Date:11.12.2023 11:50:53 Signature Not Verified ITA No.660/2023 Page 2 of 6 ITA 660/2023 4. This appeal concerns Assessment Year (AY) 2014-15. 5. Via the instant appeal, the appellant/revenue seeks to assail the order dated 05.12.2022 [stamped on 04.01.2023] passed

PR. COMMISSIONER OF INCOME TAX, DELHI-1 vs. M/S BURDA DRUCK INDIA PVT. LTD.

Bench: HON'BLE MR. JUSTICE RAJIV SHAKDHER,HON'BLE MR. JUSTICE GIRISH KATHPALIA

delay is condoned. 3. Accordingly, the application is disposed of. Digitally Signed By:ATUL JAIN Signing Date:11.12.2023 11:50:53 Signature Not Verified ITA No.660/2023 Page 2 of 6 ITA 660/2023 4. This appeal concerns Assessment Year (AY) 2014-15. 5. Via the instant appeal, the appellant/revenue seeks to assail the order dated 05.12.2022 [stamped on 04.01.2023] passed

MS CAMBRIDGE CONSTRUCTION DELHI PRIVATE LTD. (FORMERLY MS CAMBRIDGE CONSTRUCTION DELHI LTD.) vs. INCOME TAX OFFICER, WARD 5(3)

delay of 28 days in filing the appeal is condoned. Application is disposed of. This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 27/03/2026 at 13:11:33 ITA 62/2024

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

In the result, both the appeals of the assessee are allowed

Bench: Shri M. Balaganesh & Shri Sudhir Kumar

delay in filing of appeals for both the years are hereby condoned and taken up for adjudication. 4. The only identical issue to be decided in this appeal is as to whether the ld CIT(A) was justified in confirming the action of the ld AO in not allowing the carry forward of Long Term Capital Loss

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

In the result, both the appeals of the assessee are allowed

Bench: Shri M. Balaganesh & Shri Sudhir Kumar

delay in filing of appeals for both the years are hereby condoned and taken up for adjudication. 4. The only identical issue to be decided in this appeal is as to whether the ld CIT(A) was justified in confirming the action of the ld AO in not allowing the carry forward of Long Term Capital Loss

ACIT, NEW DELHI vs. M/S. K.E.I. INDUSTRIES LTD., NEW DELHI

In the result, Ground No.3

Bench: Shri Bhavnesh Saini, J.M. & Shri Anil Chaturvedi, A.M.

carried forward of the loss. Learned Counsel for the Assessee, therefore, submitted that issue is covered by Order of ITAT for the A.Y. 2008-2009 in the case of same assessee and ultimately decided by the Hon’ble Supreme Court in the case of CIT vs., Yokogawa India Ltd., (supra), in which in para-18 held as under

M/S. KEI INDUSTRIES LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result, Ground No.3

Bench: Shri Bhavnesh Saini, J.M. & Shri Anil Chaturvedi, A.M.

carried forward of the loss. Learned Counsel for the Assessee, therefore, submitted that issue is covered by Order of ITAT for the A.Y. 2008-2009 in the case of same assessee and ultimately decided by the Hon’ble Supreme Court in the case of CIT vs., Yokogawa India Ltd., (supra), in which in para-18 held as under

DALMIA CEMENT (BHARAT) LTD.,NEW DELHI vs. ACIT, CENTRAL CIRCLE- 26, NEW DELHI

Bench: Ms. Madhumita Roy & Shri Amitabh Shukla, Accountnat Member [Assessment Year: 2013-14] The Assistant Commissioner Of M/S Dalmia Cement Bharat Ltd. Income Tax, Circle-1, Dalmiapuram, Williams Road, Vs Tamilnadu, 621651 Cantonment, Trichy, Tamil Nadu-620001 Pan-Aadca9414C Assessee Revenue Cross Objection No.63/Chny/2018 (Arising Out Of Ita No.3157/Chny2017) [Assessment Year: 2013-14] M/S Dalmia Cement Bharat Ltd. The Assistant Commissioner Of Dalmiapuram, Income Tax, Circle-1, Tamilnadu-621651 Vs Williams Road, Cantonment, Trichy, Tamil Nadu-620001 Pan- Aadca9414C Assessee Revenue [Assessment Year: 2014-15] The Assistant Commissioner Of M/S Dalmia Cement Bharat Ltd. Income Tax, Circle-1, Dalmiapuram, Williams Road, Vs Tamilnadu, 621651 Cantonment, Trichy, Tamil Nadu-620001 Pan-Aadca9414C Assessee Revenue

condone the delay in the appeals of the Revenue and proceed to adjudicate the same. 3. Both the contesting parties have informed that the appeals and the Cross objections in relevant years being AY 2013-14 and 2014-15, hover around common issues and hence for the purposes of convenience were heard and are being adjudicated by this common order

DALMIA CEMENT (BHARAT) LTD.,NEW DELHI vs. ACIT, CENTRAL CIRCLE- 26, NEW DELHI

Bench: Ms. Madhumita Roy & Shri Amitabh Shukla, Accountnat Member [Assessment Year: 2013-14] The Assistant Commissioner Of M/S Dalmia Cement Bharat Ltd. Income Tax, Circle-1, Dalmiapuram, Williams Road, Vs Tamilnadu, 621651 Cantonment, Trichy, Tamil Nadu-620001 Pan-Aadca9414C Assessee Revenue Cross Objection No.63/Chny/2018 (Arising Out Of Ita No.3157/Chny2017) [Assessment Year: 2013-14] M/S Dalmia Cement Bharat Ltd. The Assistant Commissioner Of Dalmiapuram, Income Tax, Circle-1, Tamilnadu-621651 Vs Williams Road, Cantonment, Trichy, Tamil Nadu-620001 Pan- Aadca9414C Assessee Revenue [Assessment Year: 2014-15] The Assistant Commissioner Of M/S Dalmia Cement Bharat Ltd. Income Tax, Circle-1, Dalmiapuram, Williams Road, Vs Tamilnadu, 621651 Cantonment, Trichy, Tamil Nadu-620001 Pan-Aadca9414C Assessee Revenue

condone the delay in the appeals of the Revenue and proceed to adjudicate the same. 3. Both the contesting parties have informed that the appeals and the Cross objections in relevant years being AY 2013-14 and 2014-15, hover around common issues and hence for the purposes of convenience were heard and are being adjudicated by this common order

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 4(2), DELHI, I.P.ESTATE vs. BUREAU VERITAS CONSUMER PRODUCTS SERVICES(INDIA) PVT. LTD., LAJPAT NAGAR

Bench: Ms. Madhumita Roy & Shri Amitabh Shukla, Accountnat Member [Assessment Year: 2013-14] The Assistant Commissioner Of M/S Dalmia Cement Bharat Ltd. Income Tax, Circle-1, Dalmiapuram, Williams Road, Vs Tamilnadu, 621651 Cantonment, Trichy, Tamil Nadu-620001 Pan-Aadca9414C Assessee Revenue Cross Objection No.63/Chny/2018 (Arising Out Of Ita No.3157/Chny2017) [Assessment Year: 2013-14] M/S Dalmia Cement Bharat Ltd. The Assistant Commissioner Of Dalmiapuram, Income Tax, Circle-1, Tamilnadu-621651 Vs Williams Road, Cantonment, Trichy, Tamil Nadu-620001 Pan- Aadca9414C Assessee Revenue [Assessment Year: 2014-15] The Assistant Commissioner Of M/S Dalmia Cement Bharat Ltd. Income Tax, Circle-1, Dalmiapuram, Williams Road, Vs Tamilnadu, 621651 Cantonment, Trichy, Tamil Nadu-620001 Pan-Aadca9414C Assessee Revenue

condone the delay in the appeals of the Revenue and proceed to adjudicate the same. 3. Both the contesting parties have informed that the appeals and the Cross objections in relevant years being AY 2013-14 and 2014-15, hover around common issues and hence for the purposes of convenience were heard and are being adjudicated by this common order

ACIT CIRCLE 16 (1) vs. TECHSPAN INDIA LTD,

Bench: Shri I.C. Sudhir & Shri Prashant Maharishi Assessment Year: 2000-01 Assistant Cit, Vs. M/S. Techspan India Ltd., Circle 16(1), 103- Ashoka Estate, New Delhi. 24-Barakhamba Road, New Delhi. (Pan: Aabct5650D) Cross-Obj. No. 157/Del/2008 ( In Ita No. 2655/Del/2007) Assessment Year: 2000-01 M/S. Techspan India Ltd., Vs. Assistant Cit, 103- Ashoka Estate, Circle 16(1), 24-Barakhamba Road, New Delhi. New Delhi. (Pan: Aabct5650D) (Appellant) (Respondent) Assessee By: Shri Cs Aggarwal, Sr. Adv. & R.P. Mall, Adv. Department By: Shri Anshu Prakash, Sr. Dr Date Of Hearing : 08 .12.2015 Date Of Pronouncement: 04 :03.2016 Order Per I.C. Sudhir:The Revenue Has Questioned First Appellate Order Basically On Two Grounds. Firstly, The Learned Cit(Appeals) Has Erred In Directing The Assessing Officer To Allow Deduction Under Section 10A Of The Income-Tax Act, 1961 & Secondly In Directing The Assessing Officer To Set Off The Loss Of Rs.1,18,99,508. 2 2. The Assessee On The Other Hand In Its Cross Objection Has Raised Several Objections Including The Action Of The Learned Cit(Appeals) In Upholding The Validity Of Initiation Of Proceedings Under Sec. 147 Of The Act (Objection Nos. 1 & 2). In Objection No.3, The Action Of The Learned Cit(Appeals) In Recording A Finding That Assessee Had Not Claimed Any Deduction Under Sec. 10A Of The Act Has Been Objected & In Objection No.4, It Has Been Pleaded That The Learned Cit(Appeals) Ought To Have Held That Loss Suffered By The Assessee Was Allowable Business Loss To Be Carried Forward By Recording A Further Finding That The Invoices Were Raised At Arm’S Length Price.

loss to be carried forward by recording a further finding that the invoices were raised at arm’s length price. 2.1 Along with the cross objection, the assessee has also moved an application for condonation of delay

PRAMOD MITTAL

delay is condoned. Application is disposed of. 2012:DHC:895-DB ITA 66/2012 Page 2 of 7 ITA 66/2012 This appeal by Pramod Mittal impugns order dated 15.7.2011 passed by the Income Tax Appellate Tribunal (tribunal, for short). The appeal pertains to the assessment year 2005-06. 2. Ld. counsel for the appellant submits that the appellant-assessee

DCIT (E), NEW DELHI vs. M/S THE DELHI PUBLIC SCHOOL SOCIETY,, NEW DELHI

In the result, the issue raised by the Revenue stands dismissed

Bench: Shri R.S. Syal & Smt. Beena A Pillaia.Y. 2010-11

carry forward of losses. 2.4. Ld.Assessing officer passed assessment order making an addition of Rs. 9,75,31,625/-. 2.5. Aggrieved by the assessment order, assessee preferred appeal before Ld. CIT (A), who deleted the additions. 2.6. Aggrieved by the order passed by Ld. CIT (A) revenue is in appeal before us now. 3. At the outset it has been

PR. COMMISSIONER OF INCOME TAX-7 vs. M/S STERLING AGRO INDUSTRIES LTD

The appeal is disposed of in the aforesaid terms

delay is condoned. 4. The application is disposed of. ITA 105/2023 5. We have heard Mr Puneet Rai, learned senior standing counsel, who appears on behalf of the appellant/revenue. Digitally Signed By:ATUL JAIN Signing Date:03.04.2023 16:55:23 Signature Not Verified NEUTRAL CITATION NO : 2023:DHC:2330-DB ITA No.105/2023 Page 2 of 10 5.1 Mr Rai says

ACIT, CIRCLE-26(1), NEW DELHI vs. VAVASI TELEGANCE P.LTD, NEW DELHI

Bench: Hon’Ble N.K. Billaiya & Shri Kuldip Singh(Through Video Conference)

forward from the earlier year vehemently challenge the conclusion drawn by the Assessing officer that the assets were not put to use. 6.5. The assessee's appeal against the quantum addition was dismissed by me vide order dated 18.01.17 because I did not find sufficient reasons to condone a delay of 519 days in filing the appeal. Consequently

PR. COMMISSIONER OF INCOME TAX - 2 vs. BRITISH MOTOR CAR CO.(1934) LTD

Bench: HON'BLE MR. JUSTICE S. RAVINDRA BHAT,HON'BLE MR. JUSTICE A. K. CHAWLA

delay in re- filing the present appeal is hereby condoned. CM stands disposed of. ITA 1031/2017 2. The question of law urged by the Revenue in the appeal is whether the interpretation of Section 32(2) of the Income Tax Act, ITA 1031/2017 Page 2 of 10 1961 (‘the Act’) as amended by Finance Act, 2001, could be given effect

THE COMMISSIONER OF INCOME TAX - INTERNATIONAL TAXATION -3 vs. TGE GAS ENGINEERING GMBH

delay of 72 days in filing and 88 days in re-filing are condoned. 2. Applications stand disposed of. ITA 125/2024 3. The instant appeal has been preferred seeking to question the correctness of the view taken by the Income Tax Appellate Tribunal [“ITAT”] in the impugned order dated 09 March 2023. The appellant has proposed for our consideration

M/S. SAMSUNG HEAVY INDUSTRIES CO. LTD.,GURGAON vs. ADIT, NEW DELHI

The appeal of the assessee is partly allowed with above direction

Bench: Shri H.S.Sidhu & Shri Prashant Maharishi

condone the delay in filing the appeal. 10. Ground number 1 of the appeal is general in nature and no spectator arguments were advanced before us and hence same is dismissed. 11. Ground number 2 and 3 of the appeal of the assessee is against the existence of permanent establishment. On the issue of taxability of offshore supply and disallowance