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

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

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

Section 18 and explained its significance in the following words: ―22. The significance of Section 18 of the Act can be understood in the light of the above provisions. Section 18 provides for provisional assessment of duty in cases specified in sub-section (1) of the section. Clause (c) of sub-section (1) deals with cases where the importer

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

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

Section 18 and explained its significance in the following words: ―22. The significance of Section 18 of the Act can be understood in the light of the above provisions. Section 18 provides for provisional assessment of duty in cases specified in sub-section (1) of the section. Clause (c) of sub-section (1) deals with cases where the importer

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

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

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

KARAN MOTORS PRIVATE LIMITED ,JANAKPURI, NEW DELHI vs. DCIT CENTRAL CIRCLE 27, , DELHI

In the result, the appeal of the assessee is allowed

Bench: Shri M. Balaganesh & Shri Sudhir Kumarkaran Motors Pvt. Ltd, Vs. Dcit, A3-44, Third Floor, Central Circle-27, Janakpuri, New Delhi New Delhi (Appellant) (Respondent) Pan: Aaack0039L Assessee By : Shri Ajay Wadhwa, Adv Ms. Ragini Handa, Adv Revenue By: Shri Ajay Kumar Arora, Sr. Dr Date Of Hearing 31/07/2025 Date Of Pronouncement 29/08/2025

condone the delay in filing the appeal of the assessee and dismissed the appeal. Aggrieved by the order of the First Appellate Authority, the 2nd appeal was filed by the Karan Motors Pvt. Ltd assessee on 19.06.2025 before the Central Information Commission (CIC), New Delhi. 5. A letter dated 07.05.2025 was addressed by Assistant CIT, Central Circle-27, Delhi

VINOD KUMAR KHATRI vs. DCIT

5) of the Act, the Assessee retracted from his earlier admission of unaccounted income declared under Section 132 (4) made by him on 26th and 27th February 1992. The Assessee now claimed that the said amount of Rs. 12.91 crores, which have been received from Russia through official banking channels represented 100 % advance money for supplying, by way of export

VINOD KUMAR KHATRI vs. DEPUTY COMMISSIONER OF INCOME TAX

5) of the Act, the Assessee retracted from his earlier admission of unaccounted income declared under Section 132 (4) made by him on 26th and 27th February 1992. The Assessee now claimed that the said amount of Rs. 12.91 crores, which have been received from Russia through official banking channels represented 100 % advance money for supplying, by way of export

DIRECTOR OF INCOME TAX vs. VISHWA JAGRITI MISSION

Bench: HON'BLE MR. JUSTICE S. RAVINDRA BHAT,HON'BLE MR. JUSTICE R.V.EASWAR

condonation of the delay cantrot be acceptcd IZ In fine, the DIT (Exemptions) concluded that registratiou under section l2A cannot be granted and the delay in filing the applicatron cattnot be ct-ttrcloltccl Consequently the claim for certificate of exenption under sectton BOG rvas alstr reiected. This order was passed on24 9 2008 13. It rvas against the aforesaid order

DIRECTOR OF INCOME TAX vs. VISHWA JAGRITI MISSION

Bench: HON'BLE MR. JUSTICE S. RAVINDRA BHAT,HON'BLE MR. JUSTICE R.V.EASWAR

condonation of the delay cantrot be acceptcd IZ In fine, the DIT (Exemptions) concluded that registratiou under section l2A cannot be granted and the delay in filing the applicatron cattnot be ct-ttrcloltccl Consequently the claim for certificate of exenption under sectton BOG rvas alstr reiected. This order was passed on24 9 2008 13. It rvas against the aforesaid order

DIRECTOR OF INCOME TAX vs. VISHWA JAGRITI MISSION

Bench: HON'BLE MR. JUSTICE S. RAVINDRA BHAT,HON'BLE MR. JUSTICE R.V.EASWAR

condonation of the delay cantrot be acceptcd IZ In fine, the DIT (Exemptions) concluded that registratiou under section l2A cannot be granted and the delay in filing the applicatron cattnot be ct-ttrcloltccl Consequently the claim for certificate of exenption under sectton BOG rvas alstr reiected. This order was passed on24 9 2008 13. It rvas against the aforesaid order

DIRECTOR OF INCOME TAX vs. VISHWA JAGRITI MISSION

condonation of the delay cantrot be acceptcd IZ In fine, the DIT (Exemptions) concluded that registratiou under section l2A cannot be granted and the delay in filing the applicatron cattnot be ct-ttrcloltccl Consequently the claim for certificate of exenption under sectton BOG rvas alstr reiected. This order was passed on24 9 2008 13. It rvas against the aforesaid order

DIRECTOR OF INCOME TAX vs. VISHWA JAGRITI MISSION

condonation of the delay cantrot be acceptcd IZ In fine, the DIT (Exemptions) concluded that registratiou under section l2A cannot be granted and the delay in filing the applicatron cattnot be ct-ttrcloltccl Consequently the claim for certificate of exenption under sectton BOG rvas alstr reiected. This order was passed on24 9 2008 13. It rvas against the aforesaid order

DIRECTOR OF INCOME TAX vs. VISHWA JAGRITI MISSION

condonation of the delay cantrot be acceptcd IZ In fine, the DIT (Exemptions) concluded that registratiou under section l2A cannot be granted and the delay in filing the applicatron cattnot be ct-ttrcloltccl Consequently the claim for certificate of exenption under sectton BOG rvas alstr reiected. This order was passed on24 9 2008 13. It rvas against the aforesaid order

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