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

M/S. SAMIKARAN LEARNING PVT. LTD.,DELHI vs. DCIT, DELHI

The appeals of the assessee are allowed

Bench: Shri N.K. Saini & Shri Joginder Singh

condoning the delay in filing the appeals was also filed as referred to by the learned Authorized Representative. Referring to the order passed by the CIT(A), the learned Authorized Representative for the assessee pointed out that the order of Assessing Officer was not passed under section 234E of the Act but was passed under section 200A

M/S. SAMIKARAN LEARNING PVT. LTD.,DELHI vs. DCIT, DELHI

The appeals of the assessee are allowed

Bench: Shri N.K. Saini & Shri Joginder Singh

condoning the delay in filing the appeals was also filed as referred to by the learned Authorized Representative. Referring to the order passed by the CIT(A), the learned Authorized Representative for the assessee pointed out that the order of Assessing Officer was not passed under section 234E of the Act but was passed under section 200A

W SERVE TECHNOLOGIES PRIVATE LIMITED,GURGAON vs. ACIT, CPC-TDS, GHAZIABAD

In the result, the appeals of the assessee are allowed

Bench: Dr. B. R. R. Kumarsh. Anubhav Sharma

condonation of delay, however, the ld. CIT(A) has judiciously adjudicated the issue on merits and held that since the AO has levied late fee u/s 234E only after 01.06.2015 vide intimation dated 03.04.2018, the claim of the assessee for the exemption from levy of late fee was liable to be dismissed. 3. Aggrieved the assessee filed appeal before

W SERVE TECHNOLOGIES PRIVATE LIMITED,GURGAON vs. ACIT, CPC-TDS, GHAZIABAD

In the result, the appeals of the assessee are allowed

Bench: Dr. B. R. R. Kumarsh. Anubhav Sharma

condonation of delay, however, the ld. CIT(A) has judiciously adjudicated the issue on merits and held that since the AO has levied late fee u/s 234E only after 01.06.2015 vide intimation dated 03.04.2018, the claim of the assessee for the exemption from levy of late fee was liable to be dismissed. 3. Aggrieved the assessee filed appeal before

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

Section 144C of the Act refers to the Dispute Resolution Panel. Sub-section (1) of section 144C provides that in case of an eligible assessee, the Assessing Officer shall notwithstanding anything to the contrary contained in the Act forward a draft of the proposed order of assessment to the assessee if he proposes to make on or after

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

Section 144C of the Act refers to the Dispute Resolution Panel. Sub-section (1) of section 144C provides that in case of an eligible assessee, the Assessing Officer shall notwithstanding anything to the contrary contained in the Act forward a draft of the proposed order of assessment to the assessee if he proposes to make on or after

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

Section 144C of the Act refers to the Dispute Resolution Panel. Sub-section (1) of section 144C provides that in case of an eligible assessee, the Assessing Officer shall notwithstanding anything to the contrary contained in the Act forward a draft of the proposed order of assessment to the assessee if he proposes to make on or after

PME POWER SOLUTIONS INDIA LTD,NEW DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, NEW DELHI

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

Bench: Shri M. Balaganesh & Shri Vimal Kumar

condone the delay in removing the defects by the assessee u/s 139(9) and consider such returns as valid. 3. In pending cases as on date, where the defect specified u/s 139(9) of the Act has not been rectified by the assessee, the AD would be required to immediately initiate proceedings under section 144 of the Act by issuing

PME POWER SOLUTIONS INDIA LTD,NEW DELHI vs. DY. COMMISSIONER OF INCOME TAX, NEW DELHI

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

Bench: Shri M. Balaganesh & Shri Vimal Kumar

condone the delay in removing the defects by the assessee u/s 139(9) and consider such returns as valid. 3. In pending cases as on date, where the defect specified u/s 139(9) of the Act has not been rectified by the assessee, the AD would be required to immediately initiate proceedings under section 144 of the Act by issuing

PR. COMMISSIONER OF INCOME TAX (CENTRAL)-2 vs. VERSATILE POLYTECH PVT. LTD.

Appeals are dismissed as time barred

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

3 SCC 563 where the Court observed as under: “27) It is not in dispute that the person(s) concerned were well aware or conversant with the issues involved including the prescribed period of limitation for taking up the matter by way of filing a special leave petition in this Court. They cannot claim that they have a separate period

YAMUNA KHADAR SHIKSHA SAMITI,DELHI vs. ITO, TDS, MUZAFFARNAGAR

In the result, all the Eleven appeals filed by the Assessee stands allowed

Bench: Shri H. S. Sidhu & Before Shri A.N. Misshra

condoning the delay in filing the appeals was also filed as referred to by the learned Authorized Representative. Referring to the order passed by the CIT(A), the learned Authorized Representative for the assessee pointed out that the order of Assessing Officer was not passed under section 234E of the Act but was passed under section 200A

YAMUNA KHADAR SHIKSHA SAMITI,DELHI vs. ITO, TDS, MUZAFFARNAGAR

In the result, all the Eleven appeals filed by the Assessee stands allowed

Bench: Shri H. S. Sidhu & Before Shri A.N. Misshra

condoning the delay in filing the appeals was also filed as referred to by the learned Authorized Representative. Referring to the order passed by the CIT(A), the learned Authorized Representative for the assessee pointed out that the order of Assessing Officer was not passed under section 234E of the Act but was passed under section 200A

YAMUNA KHADAR SHIKSHA SAMITI,DELHI vs. ITO, TDS, MUZAFFARNAGAR

In the result, all the Eleven appeals filed by the Assessee stands allowed

Bench: Shri H. S. Sidhu & Before Shri A.N. Misshra

condoning the delay in filing the appeals was also filed as referred to by the learned Authorized Representative. Referring to the order passed by the CIT(A), the learned Authorized Representative for the assessee pointed out that the order of Assessing Officer was not passed under section 234E of the Act but was passed under section 200A

DCIT, NEW DELHI vs. M/S. MARUTI SUZUKI INDIA LTD., NEW DELHI

In the result, the appeals of the assessee are allowed and the appeals of the revenue are dismissed

Bench: Sh. Amit Shukladr. B. R. R. Kumar(E-Court Module) Ita No. 2553/Del/2013 : Asstt. Year : 1999-00 Maruti Suzuki India Ltd., Vs Commissioner Of Income Tax Plot No. 1, Nelson Mandela Road, (Appeals)-Ix, Income Tax Vasant Kunj, New Delhi-110070 Office, Laxmi Nagar, New Delhi (Appellant) (Respondent) Pan No. Aaacm0829Q Ita No. 2641/Del/2013 : Asstt. Year : 1999-00 Dcit, Vs Maruti Suzuki India Ltd., Circle-6(1), Plot No. 1, Nelson Mandela Road, New Delhi Vasant Kunj, New Delhi-110070 (Appellant) (Respondent) Pan No. Aaacm0829Q Ita No. 468/Del/2014 : Asstt. Year : 1994-95 Maruti Suzuki India Ltd., Vs Jcit(Osd), Plot No. 1, Nelson Mandela Road, Circle-6(1), Vasant Kunj, New Delhi-110070 New Delhi (Appellant) (Respondent) Pan No. Aaacm0829Q

13. Before us, the ld. AR explained at length, the provisions of Section 244A and the amendments inserted by Direct Tax Laws ITA Nos. 2553 & 2641/Del/2013 Maruti Suzuki India Ltd. amendment Act 1987. He also argued that based on the Circular of the CBDT No. 549 dated 31.10.1989, the assessee is eligible for the interest on the refund

DCIT, NEW DELHI vs. M/S MARUTI SUZUKI INDIA LTD.,, NEW DELHI

In the result, the appeals of the assessee are allowed and the appeals of the revenue are dismissed

Bench: Sh. Amit Shukladr. B. R. R. Kumar(E-Court Module) Ita No. 2553/Del/2013 : Asstt. Year : 1999-00 Maruti Suzuki India Ltd., Vs Commissioner Of Income Tax Plot No. 1, Nelson Mandela Road, (Appeals)-Ix, Income Tax Vasant Kunj, New Delhi-110070 Office, Laxmi Nagar, New Delhi (Appellant) (Respondent) Pan No. Aaacm0829Q Ita No. 2641/Del/2013 : Asstt. Year : 1999-00 Dcit, Vs Maruti Suzuki India Ltd., Circle-6(1), Plot No. 1, Nelson Mandela Road, New Delhi Vasant Kunj, New Delhi-110070 (Appellant) (Respondent) Pan No. Aaacm0829Q Ita No. 468/Del/2014 : Asstt. Year : 1994-95 Maruti Suzuki India Ltd., Vs Jcit(Osd), Plot No. 1, Nelson Mandela Road, Circle-6(1), Vasant Kunj, New Delhi-110070 New Delhi (Appellant) (Respondent) Pan No. Aaacm0829Q

13. Before us, the ld. AR explained at length, the provisions of Section 244A and the amendments inserted by Direct Tax Laws ITA Nos. 2553 & 2641/Del/2013 Maruti Suzuki India Ltd. amendment Act 1987. He also argued that based on the Circular of the CBDT No. 549 dated 31.10.1989, the assessee is eligible for the interest on the refund

MARUTI SUZUKI INDIA LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result, the appeals of the assessee are allowed and the appeals of the revenue are dismissed

Bench: Sh. Amit Shukladr. B. R. R. Kumar(E-Court Module) Ita No. 2553/Del/2013 : Asstt. Year : 1999-00 Maruti Suzuki India Ltd., Vs Commissioner Of Income Tax Plot No. 1, Nelson Mandela Road, (Appeals)-Ix, Income Tax Vasant Kunj, New Delhi-110070 Office, Laxmi Nagar, New Delhi (Appellant) (Respondent) Pan No. Aaacm0829Q Ita No. 2641/Del/2013 : Asstt. Year : 1999-00 Dcit, Vs Maruti Suzuki India Ltd., Circle-6(1), Plot No. 1, Nelson Mandela Road, New Delhi Vasant Kunj, New Delhi-110070 (Appellant) (Respondent) Pan No. Aaacm0829Q Ita No. 468/Del/2014 : Asstt. Year : 1994-95 Maruti Suzuki India Ltd., Vs Jcit(Osd), Plot No. 1, Nelson Mandela Road, Circle-6(1), Vasant Kunj, New Delhi-110070 New Delhi (Appellant) (Respondent) Pan No. Aaacm0829Q

13. Before us, the ld. AR explained at length, the provisions of Section 244A and the amendments inserted by Direct Tax Laws ITA Nos. 2553 & 2641/Del/2013 Maruti Suzuki India Ltd. amendment Act 1987. He also argued that based on the Circular of the CBDT No. 549 dated 31.10.1989, the assessee is eligible for the interest on the refund

MARUTI SUZUKI INDIA LTD.,NEW DELHI vs. JCIT (OSD), NEW DELHI

In the result, the appeals of the assessee are allowed and the appeals of the revenue are dismissed

Bench: Sh. Amit Shukladr. B. R. R. Kumar(E-Court Module) Ita No. 2553/Del/2013 : Asstt. Year : 1999-00 Maruti Suzuki India Ltd., Vs Commissioner Of Income Tax Plot No. 1, Nelson Mandela Road, (Appeals)-Ix, Income Tax Vasant Kunj, New Delhi-110070 Office, Laxmi Nagar, New Delhi (Appellant) (Respondent) Pan No. Aaacm0829Q Ita No. 2641/Del/2013 : Asstt. Year : 1999-00 Dcit, Vs Maruti Suzuki India Ltd., Circle-6(1), Plot No. 1, Nelson Mandela Road, New Delhi Vasant Kunj, New Delhi-110070 (Appellant) (Respondent) Pan No. Aaacm0829Q Ita No. 468/Del/2014 : Asstt. Year : 1994-95 Maruti Suzuki India Ltd., Vs Jcit(Osd), Plot No. 1, Nelson Mandela Road, Circle-6(1), Vasant Kunj, New Delhi-110070 New Delhi (Appellant) (Respondent) Pan No. Aaacm0829Q

13. Before us, the ld. AR explained at length, the provisions of Section 244A and the amendments inserted by Direct Tax Laws ITA Nos. 2553 & 2641/Del/2013 Maruti Suzuki India Ltd. amendment Act 1987. He also argued that based on the Circular of the CBDT No. 549 dated 31.10.1989, the assessee is eligible for the interest on the refund