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. 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

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

SUPER BRANDS LTD (UK),NEW DELHI vs. ADIT, NEW DELHI

In the result, the appeals of the Revenue are disposed of as

Bench: Shri Saktijit Dey & Shri N.K. Billaiya

delay is condoned. 6. Except for appeal for Assessment Year 2005-06 in ITA No. 3115/DEL/2009, the assessee has raised additional ground which is common in all the Assessment Years and reads as under: “That on the facts and circumstances of the case and in law, the impugned order passed by the Assessing Officer is barred by limitation and void

M/S. SUPERBRANDS LIMITED (UK),NEW DELHI vs. DDIT, NEW DELHI

In the result, the appeals of the Revenue are disposed of as

Bench: Shri Saktijit Dey & Shri N.K. Billaiya

delay is condoned. 6. Except for appeal for Assessment Year 2005-06 in ITA No. 3115/DEL/2009, the assessee has raised additional ground which is common in all the Assessment Years and reads as under: “That on the facts and circumstances of the case and in law, the impugned order passed by the Assessing Officer is barred by limitation and void

MUFG BANK, LTD.,NEW DELHI vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE 2(2)(1), INTL. TAXATION , NEW DELHI

delay is hereby condoned. 1.1 The present adjudication involves a batch of five appeals pertaining to the same assessee for AYs 2016-17, 2017-18 & 2018- 19, 2019-20 and 2020-21. In all these appeals the assessee has challenged the validity of the assessment order on the ground of limitation considering the provisions of section 144C

MUFG BANK LTD. (EARLIER KNOWN AS THE BANK OF TOKYO MITSUBISHI UFJ, LTD. ),DELHI vs. ACIT CIRCLE-2(2)(1), INTERNATIONAL TAXATION, NEW DELHI

delay is hereby condoned. 1.1 The present adjudication involves a batch of five appeals pertaining to the same assessee for AYs 2016-17, 2017-18 & 2018- 19, 2019-20 and 2020-21. In all these appeals the assessee has challenged the validity of the assessment order on the ground of limitation considering the provisions of section 144C

MUFG BANK LTD,NEW DELHI vs. ACIT, CIRCLE 2(2)(1), INTERNATIONAL TAXATION, NEW DELHI

Bench: Shri Vikas Awasthy & Shri Sanjay Awasthi

delay is hereby condoned. 1.1 The present adjudication involves a batch of five appeals pertaining to the same assessee for AYs 2016-17, 2017-18 & 2018-19, 2019-20 and 2020-21. In all these appeals the assessee has challenged the validity of the assessment order on the ground of limitation considering the provisions of section 144C

THE COMMISSIONER OF INCOME TAX - INTERNATIONAL TAXATION -3 vs. TRAVELPORT LP

Bench: The Itat Was Preferred By The Respondent/Assessee Against Order Dated 21.06.2019 Framed Under Sections 144C(13) Read With Section 147, 143(3) Of The Act. 3. The Tribunal Allowed The Appeal Of The Respondent By Stating In Paragraphs 19, 20, 21, 22, 23 & 24 As Under: “19. Facts Of The Case In Hand Show That No Order Has Been' Signed By:Pradeep Sharma Signing Date:16.09.2025 11:42:21 Signature Not Verified

section 144C of the Act, we have no hesitation in holding that the assessment order is void ab initio. Ground No. 2 with its sub-grounds is allowed. 22. Even on merits of the case, the assessee has to succeed in as much as the findings given by the Assessing Officer is totally based upon the findings given in earlier

MUFG BANK LTD. (EARLIER KNOWN AS THE BANK OF TOKYO MITSUBISHI UFJ, LTD. ),NEW DELHI vs. ACIT CIRCLE-2(2)(1), INTERNATIONAL TAXATION, DELHI

Bench: Shri Vikas Awasthy & Shri Sanjay Awasthimufg Bank Ltd., आ.अ.सं/.I.T.A No. 134/Del/2023 निर्धारणवर्ष/Assessment Year: 2019-20 5Th Floor, Worldmark-2, Asset 8, Aerocity, Nh-8, New Delhi. बनाम Vs. Acit, Circle 2(2)(1), International Taxation, Pan No.Aabct3880D E-2 Block, Civic Centre, Minto Road, New Delhi. अपीलार्थी Appellant Assessee By प्रत्यर्थी/Respondent Shri Kshitij Bansal, Ca Revenue By Shri Dharm Veer Singh, Cit Dr Mufg Bank Ltd., आ.अ.सं/.I.T.A No.3929/Del/2024 निर्धारणवर्ष/Assessment Year: 2020-21 5Th Floor, Worldmark-2, Asset 8, Aerocity, Nh-8, New Delhi. Pan No.Aabct3880D बनाम Vs. Acit, Circle 2(2)(1), International Taxation, E-2 Block, Civic Centre, Minto Road, New Delhi. अपीलार्थी Appellant प्रत्यर्थी/Respondent Assessee By Revenue By Shri Hiten Thakkar, Advocate (Virtual) Shri Dharm Veer Singh, Cit Dr Mufg Bank Ltd., बनाम 5Th Floor, Worldmark-2, Asset 8, Vs. आ.अ.सं/.I.T.A No.844/Del/2021 निर्धारणवर्ष/Assessment Year: 2016-17 Acit, Circle 2(2)(1), International Taxation, Aerocity, Nh-8, New Delhi. E-2 Block, Civic Centre, Pan No.Aabct3880D Minto Road, New Delhi. अपीलार्थी Appellant प्रत्यर्थी/Respondent Assessee By Revenue By Shri Kshitij Bansal, Ca Shri Dharm Veer Singh, Cit Dr आ.अ.सं/.I.T.A No.1476/Del/2022 निर्धारणवर्ष/Assessment Year: 2017-18 1

delay is hereby condoned. 1.1 The present adjudication involves a batch of five appeals pertaining to the same assessee for AYs 2016-17, 2017-18 & 2018- 19, 2019-20 and 2020-21. In all these appeals the assessee has 2 ITA NOS. 134/D/23, 3929/D/24, 844/D/21,1476/D/22 & 1477/D/2022 MUFG BANK LIMITED challenged the validity of the assessment order on the ground

MUFG BANK LTD,NEW DELHI vs. ACIT, CIRCLE-2(2)(1) (INTERNATIONAL TAXATION), NEW DELHI

Bench: Shri Vikas Awasthy & Shri Sanjay Awasthiआ.अ.सं/.I.T.A No. 134/Del/2023 निर्धारणवर्ष/Assessment Year: 2019-20 Mufg Bank Ltd., 5Th Floor, Worldmark-2, Asset 8, Aerocity, Nh-8, New Delhi. बनाम Vs. Acit, Circle 2(2)(1), International Taxation, E-2 Block, Civic Centre, Minto Road, New Delhi. Pan No.Aabct3880D अपीलार्थी Appellant प्रत्यर्थी/Respondent Assessee By Shri Kshitij Bansal, Ca Revenue By Shri Dharm Veer Singh, Cit Dr आ.अ.सं/.I.T.A No.3929/Del/2024 निर्धारणवर्ष/Assessment Year: 2020-21 Mufg Bank Ltd., 5Th Floor, Worldmark-2, Asset 8, Aerocity, Nh-8, New Delhi. Pan No.Aabct3880D बनाम Vs. Acit, Circle 2(2)(1), International Taxation, E-2 Block, Civic Centre, Minto Road, New Delhi. अपीलार्थी Appellant प्रत्यर्थी/Respondent Assessee By Shri Hiten Thakkar, Advocate (Virtual) Revenue By Shri Dharm Veer Singh, Cit Dr Mufg Bank Ltd., 5Th Floor, Worldmark-2, Asset 8, Aerocity, Nh-8, New Delhi. Pan No.Aabct3880D बनाम Vs. आ.अ.सं/.I.T.A No.844/Del/2021 निर्धारणवर्ष/Assessment Year: 2016-17 Acit, Circle 2(2)(1),International Taxation, E-2 Block, Civic Centre, Minto Road, New Delhi. अपीलार्थी Appellant प्रत्यर्थी/Respondent Assessee By Shri Kshitij Bansal, Ca Revenue By Shri Dharm Veer Singh, Cit Dr आ.अ.सं/.I.T.A No.1476/Del/2022 निर्धारणवर्ष/Assessment Year: 2017-18 1

delay is hereby condoned. 1.1 The present adjudication involves a batch of five appeals pertaining to the same assessee for AYs 2016-17, 2017-18 & 2018- 19, 2019-20 and 2020-21. In all these appeals the assessee has 2 ITA NOS. 134/D/23, 3929/D/24, 844/D/21,1476/D/22 & 1477/D/2022 MUFG BANK LIMITED challenged the validity of the assessment order on the ground

ADDL. CIT, SPECIAL RANGE- 6, NEW DELHI vs. NEC TECHNOLOGIES INDIA PVT. LTD., NEW DELHI

Bench: Shri Ramit Kochar & Shri Sudhir Pareek

144C(5) of the Income Tax Act, 1961. 3) That as per the provisions of section 253(3A) of the Act, the limitation for filing appeal before this Hon'ble Tribunal expire on 21.02.2015 and therefore, the present accompanying appeal is delayed by 1021 days. 4) The matter regarding filing of appeal in the impugned case

DCIT, CIRCLE-1(1), DELHI vs. ADM AGRO INDUSTRIES KOT & AKOLA PVT. LTD., GURGAON

In the result, appeal of the Revenue is dismissed

Bench: SHRI VIKAS AWASTHY (Judicial Member), SHRI PRADIP KUMAR KEDIA (Accountant Member)

delay of 16 days in filing of appeal is condoned and appeal is admitted for hearing on merits. 3. The Department in appeal has assailed the order of CIT(A) by raising following grounds:- 1. Whether in the facts and circumstances of the case and in law, the Ld. CIT(A) erred in cancelling the assessment order on the basis

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

PRINCIPAL COMMISSIONER OF INCOME TAX 1 vs. M/S FIBERHOME INDIA PRIVATE LIMITED

delay in filing and re- filing the appeal is condoned. The application shall stand disposed of. ITA 91/2024 1. The appellant seeks to question the validity of the order of the Income Tax Appellate Tribunal [“ITAT”] dated 13 March 2023. The ITAT has essentially upheld the view taken by the Authority below i.e., Dispute Resolution Panel [“DRP”] which found that

PRINCIPAL COMMISSIONER OF INCOME TAX 1 vs. M/S FIBERHOME INDIA PRIVATE LIMITED

Bench: HON'BLE MR. JUSTICE PURUSHAINDRA KUMAR KAURAV,HON'BLE MR. JUSTICE YASHWANT VARMA

delay in filing and re- filing the appeal is condoned. The application shall stand disposed of. ITA 91/2024 1. The appellant seeks to question the validity of the order of the Income Tax Appellate Tribunal [“ITAT”] dated 13 March 2023. The ITAT has essentially upheld the view taken by the Authority below i.e., Dispute Resolution Panel [“DRP”] which found that

M/S. NOKIA SOLUTIONS AND NETWORKS INDIA PVT. LTD.,GURGAON vs. DCIT, NEW DELHI

Bench: Shri R.K. Panda & Shri Sudhanshu Srivastavaassessment Year: 2006-07 Nokia Solutions & Networks India Pvt. Ltd., Vs Dcit, (Formerly Known As Nokia Siemens Circle-18(2), Networks Pvt. Ltd.), 7Th Floor, Room No. 406, Building No. 9A, Dlf Cyber City, C.R. Building, Sector 25A, I.P. Estate, Gurgaon-122002 New Delhi. (Pan: Aaccn3871F) (Appellant) (Respondent) Appellant By: Shri Deepak Chopra, Adv. Respondent By: Shri T.M. Shiva Kumar, Cit Dr

144C(8) of the Act issued by the DRP, Delhi, in the name of Nokia Siemens Networks India Private Limited (,NSNIPL') wherein DRP held that assessment February 12 made on amalgamating company is a curable defect and therefore directed AO and TPO to issue notice in 26, 2016 the name of amalgamated company and frame the assessment b) givinq

PR. COMMISSIONER OF INCOME TAX-6, DELHI vs. NT BACK OFFICE SERVICES PVT. LTD (EARLIER KNOWN AS GLOBERIAN INDIA PVT. LTD.)

The appeal is dismissed

Bench: HON'BLE MR. JUSTICE SANJIV KHANNA,HON'BLE MR. JUSTICE ANUP JAIRAM BHAMBHANI

delay in re-filing of 34 days and 25 days respectively are condoned as the applications are not opposed by the counsel for the respondent. Applications are allowed. ITA 1307/2018 This appeal by the Revenue under Section 260A of the Income Tax Act, 1961 in the case of NT Back Office Services Pvt. Ltd (earlier known as ITA 1307/2018 Page