PR. COMMISSIONER OF INCOME TAX -7 vs. SUMITOMO CORPORATION INDIA (P) LTD.

Bench: HON'BLE MR. JUSTICE YASHWANT VARMA,HON'BLE MR. JUSTICE RAVINDER DUDEJA

120 was selected for scrutiny and notice was issued under section 143(2) of the Act.  Assessing Officer (AO) passed draft assessment order (DAO) dated 21.03.2014 under section 143(3) read with section 144C, making addition of Rs.4,70,99,145, which included transfer pricing adjustment of Rs.1,91,52,594 and disallowance of deduction under section

THE PR. COMMISSIONER OF INCOME TAX -6 vs. MARUTI SUZUKI INDIA LTD.

Bench: HON'BLE MR. JUSTICE VIPIN SANGHI,HON'BLE MR. JUSTICE SANJEEV NARULA

120 was selected for scrutiny and notice was issued under section 143(2) of the Act.  Assessing Officer (AO) passed draft assessment order (DAO) dated 21.03.2014 under section 143(3) read with section 144C, making addition of Rs.4,70,99,145, which included transfer pricing adjustment of Rs.1,91,52,594 and disallowance of deduction under section

THE PR. COMMISSIONER OF INCOME TAX -6 vs. MICROSOFT INDIA ( R & D) PVT. LTD.

Bench: HON'BLE MR. JUSTICE VIPIN SANGHI,HON'BLE MR. JUSTICE SANJEEV NARULA

120 was selected for scrutiny and notice was issued under section 143(2) of the Act.  Assessing Officer (AO) passed draft assessment order (DAO) dated 21.03.2014 under section 143(3) read with section 144C, making addition of Rs.4,70,99,145, which included transfer pricing adjustment of Rs.1,91,52,594 and disallowance of deduction under section

VINOD KUMAR KHATRI vs. DCIT

b), Section 139 (4) and Section 139 (5) of the Act. As already noted the return originally filed was found to be defective. A notice was issued under Section 139 (9) of the Act asking the Assessee to rectify the defects. Section 139 (9) itself states that if the defects are not rectified within the time allowed, then notwithstanding anything

VINOD KUMAR KHATRI vs. DEPUTY COMMISSIONER OF INCOME TAX

b), Section 139 (4) and Section 139 (5) of the Act. As already noted the return originally filed was found to be defective. A notice was issued under Section 139 (9) of the Act asking the Assessee to rectify the defects. Section 139 (9) itself states that if the defects are not rectified within the time allowed, then notwithstanding anything

COMMISSIONER OF INCOME TAX (EXEMPTIONS) DELHI vs. SERVANTS OF PEOPLE SOCIETY

Bench: HON'BLE MR. JUSTICE MANMOHAN,HON'BLE MR. JUSTICE NAVIN CHAWLA

4 to 9 of the 2007 Rules. 16.6. The proper officer can raise doubts as to the truth or accuracy Digitally Signed By:KAMLESH KUMAR Signing Date:27.11.2024 18:20:25 Signature Not Verified CUSAA 26/2022 & connected matters Page 50 of 137 of the declared value on ―certain reasons‖ which could include the grounds specified in sub-clauses

COMMISSIONER OF INCOME TAX (EXEMPTIONS) DELHI vs. SERVANTS OF PEOPLE SOCIETY

Bench: HON'BLE MR. JUSTICE MANMOHAN,HON'BLE MR. JUSTICE NAVIN CHAWLA

4 to 9 of the 2007 Rules. 16.6. The proper officer can raise doubts as to the truth or accuracy Digitally Signed By:KAMLESH KUMAR Signing Date:27.11.2024 18:20:25 Signature Not Verified CUSAA 26/2022 & connected matters Page 50 of 137 of the declared value on ―certain reasons‖ which could include the grounds specified in sub-clauses

DIRECTOR OF INCOME TAX (EXEMPTION) vs. NATIONAL ASSOCIATION OF SOFTWARE AND SERVICE COMPANIES (NASSCOM)

In the result the appeals are disposed of as above with no order as to

120 (Mad.) c) Province of Bihar v. Rai Shambhu Lal Bose, 15 ITR 176 (Pat.) d) Bharat Commerce & Industries Ltd. v. CIT, (1998) 230 ITR 733 (SC). 11. The question before us, however, is not a simple question as to whether taxes on income are deductible in computing the taxable income of the assessee. The question before us is whether

DIRECTOR OF INCOME TAX (EXEMPTION) vs. SERVICES COMPANIES

In the result the appeals are disposed of as above with no order as to

120 (Mad.) c) Province of Bihar v. Rai Shambhu Lal Bose, 15 ITR 176 (Pat.) d) Bharat Commerce & Industries Ltd. v. CIT, (1998) 230 ITR 733 (SC). 11. The question before us, however, is not a simple question as to whether taxes on income are deductible in computing the taxable income of the assessee. The question before us is whether

PROVIDENT INV. & INDUSTRIES (P) LTD.,NEW DELHI vs. ITO, NEW DELHI

In the result ground No. 5 of the appeal of the assessee is dismissed

Bench: Shri H.S.Sidhu & Shri Prashant Maharishiprovident Inv & Industries P Ltd, Vs. Ito, Ward-14(2), 4Th Floor, Ito, A-49, Mohan Cooperative Industrial Estate, Mathura Road, New Delhi Cr Building, New Delhi Pan:Aabcj4816P (Appellant) (Respondent)

condoned the delay in filing the appeal. 4. The assessee is a private limited company who filed its return of income declaring loss of Rs. 129603/- on 30.09.2008. Subsequently, on 16.12.2010 the ld Assessing Officer, during the course of assessment proceedings, found that there are complexity in the accounts of the assessee and in the interest of revenue its books

COMMISSIONER OF INCOME TAX INTERNATIONAL TAXATION- 2, NEW DELHI vs. HYUNDAI ROTEM COMPANY

The appeal is dismissed

Bench: HON'BLE MR. JUSTICE V. KAMESWAR RAO,HON'BLE MR. JUSTICE VINOD KUMAR

delay of 103 days in filing the appeal stands condoned. 2. The application stands disposed of. Signed By:PRADEEP SHARMA Signing Date:29.10.2025 18:22:45 Signature Not Verified ITA No.304/2025 Page 2 of 46 ITA 304/2025 3. The present appeal has been filed by the appellant who is the Commissioner of Income Tax (International Taxation)-2, New Delhi under

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)

condone the delay admitting the appeal of the assessee and proceed to decide the issue on merits. 08. Facts of case in a narrow compass shows that assessee filed his return of income on 31 August 2012 declaring total income of Rs. 167,09,146 which was subsequently revised on 25th of March 2014 declaring same

ZTE CORPORATION,CHINA vs. JCIT (OSD) INTERNATIONAL TAXATION, GURGAON

condoned the delay in filing of appeal for AY 2016- 17, to avoid duplication, the cross-objection filed by the Assessee in Department's appeal on identical grounds is treated as academic and disposed off accordingly. SA No.364/Del/2020 & CO No.07/Del/2021 ZTE Corporation vs. DCIT & Ors. 11. Having held the above, we now embark on the merits of the matter

ZTE CORPORATION,GURGAON vs. DCIT (INTERNATIONAL TAXATION), GURGAON

condoned the delay in filing of appeal for AY 2016- 17, to avoid duplication, the cross-objection filed by the Assessee in Department's appeal on identical grounds is treated as academic and disposed off accordingly. SA No.364/Del/2020 & CO No.07/Del/2021 ZTE Corporation vs. DCIT & Ors. 11. Having held the above, we now embark on the merits of the matter

DCIT, INT. TAX.,.CIRCLE GURGAON, GURGAON vs. ZTE CORPORATION , CHINA

condoned the delay in filing of appeal for AY 2016- 17, to avoid duplication, the cross-objection filed by the Assessee in Department's appeal on identical grounds is treated as academic and disposed off accordingly. SA No.364/Del/2020 & CO No.07/Del/2021 ZTE Corporation vs. DCIT & Ors. 11. Having held the above, we now embark on the merits of the matter

DY. COMMISSIONER OF INCOME TAX, NOIDA vs. M/S ACE MEGA STRUCTURE PRIVATE LIMITED, NOIDA

In the result, appeal of the assessee is allowed

Bench: Shri Anubhav Sharma & Shri Manish Agarwalsl. Ita No(S) Asst. Appeal(S) By No Year(S) Appellant Vs. Respondent Appellant Respondent 1. 4067/Del/2025 2019-20 M/S. Ace Mega Dcit/Acit Structures Pvt. Ltd., Central Circle I-B, 7Th Floor, Ace Studio, Noida Sector-126, Noida, Sector- 37, S.O. Gautam Budh Nagar-201303 Pan-Aakca8694D M/S. Ace Mega 2. 4115/Del/2025 2019-20 Dcit, Structures Pvt. Ltd. Central Circle-1, A.R.T.O Complex, Sector-33, I-B, 7Th Floor, Ace Studio, Noida-201301. Sector-126, Noida, Sector- 37, S.O. Gautam Budh Nagar-201303 Pan-Aakca8694D Appellant By Shri Rohit Kapoor, Adv. & Shri Virsain Aggarwal, Itp Respondent By Shri Mahesh Kumar, Cit Dr Date Of Hearing 17.09.2025 Date Of Pronouncement 27.11.2025

condonation of delay scheme for filing the returns. In view of the above, it was felt necessary to make enquiries both with Hallow Securities Pvt. Ltd. and SFIO (the Nodal Authority maintaining the database) to know, if any, proceedings were pending with respect to Hallow Securities Pyt Ltd. with SFIO and whether M/s. Hallow Securities Pvt. Ltd. had been regular

ACE MEGA STRUCTURES PRIVATE LIMITED,UTTAR PRADESH vs. DCIT/ACIT CEN CIR, NOIDA, NOIDA

In the result, appeal of the assessee is allowed

Bench: Shri Anubhav Sharma & Shri Manish Agarwalsl. Ita No(S) Asst. Appeal(S) By No Year(S) Appellant Vs. Respondent Appellant Respondent 1. 4067/Del/2025 2019-20 M/S. Ace Mega Dcit/Acit Structures Pvt. Ltd., Central Circle I-B, 7Th Floor, Ace Studio, Noida Sector-126, Noida, Sector- 37, S.O. Gautam Budh Nagar-201303 Pan-Aakca8694D M/S. Ace Mega 2. 4115/Del/2025 2019-20 Dcit, Structures Pvt. Ltd. Central Circle-1, A.R.T.O Complex, Sector-33, I-B, 7Th Floor, Ace Studio, Noida-201301. Sector-126, Noida, Sector- 37, S.O. Gautam Budh Nagar-201303 Pan-Aakca8694D Appellant By Shri Rohit Kapoor, Adv. & Shri Virsain Aggarwal, Itp Respondent By Shri Mahesh Kumar, Cit Dr Date Of Hearing 17.09.2025 Date Of Pronouncement 27.11.2025

condonation of delay scheme for filing the returns. In view of the above, it was felt necessary to make enquiries both with Hallow Securities Pvt. Ltd. and SFIO (the Nodal Authority maintaining the database) to know, if any, proceedings were pending with respect to Hallow Securities Pyt Ltd. with SFIO and whether M/s. Hallow Securities Pvt. Ltd. had been regular

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

In the result, appeal of the assessee is dismissed

Bench: Shri M. Balaganesh & Shri Vimal Kumarmr. Nikhil Sawhney, Vs. Dcit, 17, Sunder Nagar, Central Circle, New Delhi-11003 Noida (Appellant) (Respondent) Pan: Aaups0222Q

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 (LTCL) arising

COMMISSIONER OF INCOME TAX DELHI-XI vs. INDIAN NATIONAL CONGRESS/ALL INDIA CONGRESS COMMITTEE

Bench: HON'BLE DR. JUSTICE S.MURALIDHAR,HON'BLE MR. JUSTICE VIBHU BAKHRU

b) and 46A(1)(c) of the Rules. The decision of the CIT(A) as affirmed by the ITAT, is upheld. The accounts do not give a true and fair picture 99. Admittedly, in the present case, the accounts for AY 1994-95 were audited only on 1st July 1997. This was more than two years after