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) r.w.s

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) r.w.s

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

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

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

sections": [ "144C(5)", "40(a)(i)", "9(1)(vii)(b)", "143(2)", "142(1)", "144C", "253(2A)", "253(3A)", "253(5)", "14" ], "issues": "Whether the delay in filing the appeal by the Revenue was for a \"sufficient cause\" to warrant condonation

DCIT, CC-8, NEW DELHI vs. BJN HOLDINGS LTD. (DISSOLVED COMPANY THROUGH ITS SUCCESSOR BJN HOLDING (I) LTD.), DELHI

In the result, all the appeals of the Revenue are dismissed

Bench: Sh. Saktijit Deydr. B. R. R. Kumar

144C (15) (b) of the Act. Consequently, there was no requirement to pass a draft assessment order/reference to DRP etc.; and • Furthermore, the final assessment order dated 31 October 2016 is beyond limitation in terms of Section 153(1) read with Section 153 (4) of the Act. (v) The assessment framed in the name of the amalgamating Company is invalid

DCIT, CC-8, NEW DELHI vs. BJN HOLDINGS LTD. (DISSOLVED COMPANY THROUGH ITS SUCCESSOR BJN HOLDING (I) LTD.), DELHI

In the result, all the appeals of the Revenue are dismissed

Bench: Sh. Saktijit Deydr. B. R. R. Kumar

144C (15) (b) of the Act. Consequently, there was no requirement to pass a draft assessment order/reference to DRP etc.; and • Furthermore, the final assessment order dated 31 October 2016 is beyond limitation in terms of Section 153(1) read with Section 153 (4) of the Act. (v) The assessment framed in the name of the amalgamating Company is invalid

DCIT, CC-8, NEW DELHI vs. BJN HOLDINGS LTD. (DISSOLVED COMPANY THROUGH ITS SUCCESSOR BJN HOLDING (I) LTD.), DELHI

In the result, all the appeals of the Revenue are dismissed

Bench: Sh. Saktijit Deydr. B. R. R. Kumar

144C (15) (b) of the Act. Consequently, there was no requirement to pass a draft assessment order/reference to DRP etc.; and • Furthermore, the final assessment order dated 31 October 2016 is beyond limitation in terms of Section 153(1) read with Section 153 (4) of the Act. (v) The assessment framed in the name of the amalgamating Company is invalid

DCIT, CC-8, NEW DELHI vs. BJN HOLDINGS LTD. (DISSOLVED COMPANY THROUGH ITS SUCCESSOR BJN HOLDING (I) LTD.), DELHI

In the result, all the appeals of the Revenue are dismissed

Bench: Sh. Saktijit Deydr. B. R. R. Kumar

144C (15) (b) of the Act. Consequently, there was no requirement to pass a draft assessment order/reference to DRP etc.; and • Furthermore, the final assessment order dated 31 October 2016 is beyond limitation in terms of Section 153(1) read with Section 153 (4) of the Act. (v) The assessment framed in the name of the amalgamating Company is invalid

DCIT, CC-8, NEW DELHI vs. BJN HOLDINGS LTD. (DISSOLVED COMPANY THROUGH ITS SUCCESSOR BJN HOLDING (I) LTD.), DELHI

In the result, all the appeals of the Revenue are dismissed

Bench: Sh. Saktijit Deydr. B. R. R. Kumar

144C (15) (b) of the Act. Consequently, there was no requirement to pass a draft assessment order/reference to DRP etc.; and • Furthermore, the final assessment order dated 31 October 2016 is beyond limitation in terms of Section 153(1) read with Section 153 (4) of the Act. (v) The assessment framed in the name of the amalgamating Company is invalid

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

BTL INDUSTRIES LTD,NEW DELHI vs. DCIT, CENTRAL CIRCLE-II,, FARIDABAD

In the result, appeals of the assessee are partly allowed

Bench: Shri Challa Nagendra Prasad & Shri S Rifaur Rahmanassessment Year: 2008-09 बनाम Btl Industries Ltd., Dcit, (Merged With & Now Known As Vs. Central Circle-Ii, M/S Btl Holding Co. Ltd.), Faridabad, C/O Srs Mall, Third Floor, Haryana. Sector-12, Faridabad, Haryana. Pan No.Aaccb0573C अपीलाथ" Appellant ""यथ"/Respondent &

144C of the Act. 9. As noticed hereinabove, the respondent/assessee raised an additional ground before the Tribunal, concerning the absence of jurisdiction with regard to the framing of the order by the AO under Section 143(3) of the Act. 10. In particular, the ground articulated by the respondent/assessee was, that the assessment order had been framed

ESTER INDUSTRIES LTD.,,NEW DELHI vs. ACIT, DELHI

In the result, appeals of the assessee are partly allowed

Bench: Shri Challa Nagendra Prasad & Shri S Rifaur Rahmanassessment Year: 2008-09 बनाम Btl Industries Ltd., Dcit, (Merged With & Now Known As Vs. Central Circle-Ii, M/S Btl Holding Co. Ltd.), Faridabad, C/O Srs Mall, Third Floor, Haryana. Sector-12, Faridabad, Haryana. Pan No.Aaccb0573C अपीलाथ" Appellant ""यथ"/Respondent &

144C of the Act. 9. As noticed hereinabove, the respondent/assessee raised an additional ground before the Tribunal, concerning the absence of jurisdiction with regard to the framing of the order by the AO under Section 143(3) of the Act. 10. In particular, the ground articulated by the respondent/assessee was, that the assessment order had been framed

ADITYA SHARMA,NEW DELHI vs. ACIT CENTRAL CIRCLE-19, NEW DELHI

In the result, appeals of the assessee are partly allowed

Bench: Shri Challa Nagendra Prasad & Shri S Rifaur Rahmanassessment Year: 2008-09 बनाम Btl Industries Ltd., Dcit, (Merged With & Now Known As Vs. Central Circle-Ii, M/S Btl Holding Co. Ltd.), Faridabad, C/O Srs Mall, Third Floor, Haryana. Sector-12, Faridabad, Haryana. Pan No.Aaccb0573C अपीलाथ" Appellant ""यथ"/Respondent &

144C of the Act. 9. As noticed hereinabove, the respondent/assessee raised an additional ground before the Tribunal, concerning the absence of jurisdiction with regard to the framing of the order by the AO under Section 143(3) of the Act. 10. In particular, the ground articulated by the respondent/assessee was, that the assessment order had been framed