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

In the result, all five appeals of the assessee are allowed

delay is\nhereby condoned.\n1.1 The present adjudication involves a batch of five appeals\npertaining to the same assessee for AYs 2016-17, 2017-18 & 2018-\n19, 2019-20 and 2020-21. In all these appeals the assessee has\nchallenged the validity of the assessment order on the ground of\nlimitation considering the provisions of section 144C(13

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

In the result, all five appeals of the assessee are allowed

delay is\nhereby condoned.\n1.1 The present adjudication involves a batch of five appeals\npertaining to the same assessee for AYs 2016-17, 2017-18 & 2018-\n19, 2019-20 and 2020-21. In all these appeals the assessee has\n2\nITA NOS. 134/D/23, 3929/D/24, 844/D/21,1476/D/22 & 1477/D/2022\nMUFG BANK LIMITED\nchallenged the validity of the assessment order on the ground

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

In the result, all five appeals of the assessee are allowed

delay is\nhereby condoned.\n1.1 The present adjudication involves a batch of five appeals\npertaining to the same assessee for AYs 2016-17, 2017-18 & 2018-\n19, 2019-20 and 2020-21. In all these appeals the assessee has\nchallenged the validity of the assessment order on the ground of\nlimitation considering the provisions of section 144C(13

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

In the result, all five appeals of the assessee are allowed

delay is\nhereby condoned.\n1.1 The present adjudication involves a batch of five appeals\npertaining to the same assessee for AYs 2016-17, 2017-18 & 2018-\n19, 2019-20 and 2020-21. In all these appeals the assessee has\n2\nITA NOS. 134/D/23, 3929/D/24, 844/D/21,1476/D/22 & 1477/D/2022\nMUFG BANK LIMITED\nchallenged the validity of the assessment order on the ground

SUPERBRANDS LTD (UK),GURGAON vs. DCIT, CIRCLE- 3(1)(2), INTERNATIONAL TAXATION , NEW DELHI

In the result, the appeal is allowed, as indicated above

Bench: Shri G.S. Pannu, Hon’Ble & Shri Saktijit Deyआ.अ.सं/.I.T.A No.332/Del/2021 िनधा"रणवष"/Assessment Year: 2016-17 बनाम Superbrands Ltd. (Uk) Dcit C/O Bdo India Llp 1501-1508, Vs. Circle 3(1)(2), Palm Spring Plaza, Sector-54, International Taxation, Golf Course Road, Gurgaon, New Delhi. Haryana. Pan No. Aaics6497G अपीलाथ" Appellant ""यथ"/Respondent

condone the delay and admit the appeal for adjudication on merits. In addition to the grounds raised in the memorandum of appeal, the assessee has raised the following additional grounds: Ground No. 3 “Without prejudice to ground no. 1 & 2, on the facts and circumstances of the case, and in law, the learned assessing officer erred in passing a draft

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

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

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

The appeal of the Revenue is hereby dismissed\nas time barred

section 9(1)\n(vii) (b) of the Act.\n\n8. At the outset, it is noticed that this appeal filed, after\ninordinate delay of 1021 days i.e. on 08-12-2017with endorsement\nat the bottom of appeal that the limitation expires on 21-02-2015\nand the copy of the order was communicated

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

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

COMMISSIONER OF INCOME TAX, INTERNATIONAL TAXATION-1, NEW DELHI vs. COURSERA INC.

Appeal is allowed

section 144C(13) of the Act. 14. Be that as it may, Assessing Officer’s findings/observations on the role of assessee are self- contradictory. While on one hand, the Assessing Officer has acknowledged the fact that the assessee is an aggregation service provider and not a content creator, in the same breath, he says that assessee’s contention that

ANIL BHARDWAJ,ZAMBIA vs. DCIT-ACIT-INT-TAX GURGAON, GURGAON

In the result, the Appeal filed by the Assessee is allowed

Bench: Dr. B. R. R. Kumar & Shri Yogesh Kumar U.S.I.T.A. No. 1250/Del/2024 (A.Y 2020-21) Anil Bhardwaj Dcit/Acit 5994, Benakale Road, P. O Vs. International Tax, Box No. 31776, Northmead, Office Of Acit-Dcit Int- Near Rhodes Park School, Tax, Gurgaon Lusaka-10101, Zambia, Ny (Respondent) Pan No. Anlpb2321F (Appellant)

Section 144C(13) of the Act dated 27/04/2023 by making 4 Anil Bhardwaj Zambia addition of Rs. 20,10,008/- as short term capital gain and further disallowed Rs. 80,14,041/- u/s 54 of the Act being 50% wife’s shares in the new house property. 4. Aggrieved by the assessment order passed u/s 143(3) r.w.s 144C(13

THE COMMISSIONER OF INCOME TAX - INTERNATIONAL TAXATION -3 vs. SILVER BELLA HOLDING LTD.

condonation of delay in re-filing the appeal. 2. According to the appellant/revenue, there is a delay of 300 days. 3. Issue notice to the non-applicant/respondent/assessee via all permissible modes, including email. 4. List the application on 25.08.2023. ITA 275/2023 5. This appeal concerns Assessment Year (AY) 2014-15. ITA 275/2023 1/3 This is a digitally signed order

THE COMMISSIONER OF INCOME TAX - INTERNATIONAL TAXATION -3 vs. TURNER BROADCASTING SYSTEM ASIA PACIFIC INC.

Appeals are dismissed

delay of eighteen days in filing the above captioned appeals stand condoned. 2. The applications stand disposed of. ITA 76/2025 and ITA 77/2025 3. The Revenue has filed the present appeals under Section 260A of the Income Tax Act, 1961 [the Act] impugning a common order passed by the learned Income Tax Appellate Tribunal [ITAT] in ITA No.2432/DEL/2023 This

THE COMMISSIONER OF INCOME TAX - INTERNATIONAL TAXATION -3 vs. TRAVELPORT L.P. USA

Delay of 146 days is condoned. 2. Learned Additional Solicitor General appearing for the petitioner has submitted that the issues which arise in this petition have been considered and held against the Revenue in [Civil Appeal Nos. 6511- 6518/2010] DIT v. Travelport Inc. [2023] 149 taxmann.com 470/454 ITR 289 (SC) by affirming the judgment of the High Court. His submission

THE COMMISSIONER OF INCOME TAX - INTERNATIONAL TAXATION -3 vs. TRAVELPORT L.P. USA

Delay of 146 days is condoned. 2. Learned Additional Solicitor General appearing for the petitioner has submitted that the issues which arise in this petition have been considered and held against the Revenue in [Civil Appeal Nos. 6511- 6518/2010] DIT v. Travelport Inc. [2023] 149 taxmann.com 470/454 ITR 289 (SC) by affirming the judgment of the High Court. His submission

VEG 'N' TABLE,NOIDA vs. DCIT, CIRCLE- INT. TAX 3(1)(1), DELHI

In the result, the appeal is allowed, as indicated above

Bench: Shri Saktijit Dey, Vice- & Dr. B.R.R. Kumarassessment Year: 2018-19 . Veg ‘N’ Table, Vs. Dcit, 801, Tower-A 1, Circle- International Tax - Ansal Corporate Park, 3(1)(1), Sector-142, Delhi Noida Pan :Aagcv2131A (Appellant) (Respondent)

section 144C(13) of the Income-tax Act, 1961 (in short ‘the Act’) pertaining to assessment year 2018-19, in pursuance to the directions of learned Dispute Resolution Panel (DRP). AY: 2018-19 2. At the outset, Registry has reported delay of 27 days in filing the appeal. The assessee has filed the application for condonation

PANALPINA WORLD TRANSPORT INDIA PVT. LTD.,GURGAON vs. ADDL.CIT, SPECIAL RANGE-7, NEW DELHI

The appeals are dismissed

Bench: Shri G.S. Pannu, Hon’Ble & Shri Saktijit Deyassessment Year: 2010-11 M/S. Panalpine World Vs. Addl. Cit, Transport India Pvt. Ltd., Special Range-7, 5Th Floor, Orchid Business New Delhi Park, Sector-48, Sohna Road, Gurgaon Pan :Aaacp7676A (Appellant) (Respondent) With Assessment Year: 2010-11 Addl. Cit, Vs. M/S. Panalpine World Special Range-7, Transport (India) Pvt. Ltd., New Delhi Plot No. 227/2, Dhulsiras, Dwarka, Sector-24, New Delhi Pan :Aaacp7676A (Appellant) (Respondent)

13) of the Act dated 29.05.2014 was passed by the Deputy Commissioner of Income Tax -10, Mumbai. As per Rule 4 of the Income Tax (Appellate Tribunal) Rules, 1963 read with paragraph 4 of Notification No. F.No.63-AD(AT/97), dated 16th September 1997 as amended from time to time, the ordinary jurisdiction of the Bench of the Tribunal