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

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

CIT vs. GS PHARMBUTOR PVT LTD

The appeal is allowed to the aforesaid extent

Bench: HON'BLE MR. JUSTICE BADAR DURREZ AHMED,HON'BLE MR. JUSTICE R.V.EASWAR

condoned in respect of the bank, then the matter even in so far as the appellant is concerned would be over. 19. He further submitted that the order dated 03.03.2011 whereby the respondent No. 3 revoked the passport of the appellant was bad for another reason. The reason being that the said order dated 03.03.2011 refers to diversion of Foreign

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

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. 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(13) r.w.s

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(13) r.w.s

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(13) r.w.s

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

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

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

Bench: Shri Ramit Kochar & Shri Sudhir Pareek

2) That the Commissioner of Income Tax, Delhi -06, New Delhi has issued directions u/s 253(2A) of the Act for filing the accompanying appeal against the directions of the Dispute Resolutions Panel-II, New Delhi dated 17.12.2014 issued u/s 144C(5) of the Income Tax Act, 1961. 3) That as per the provisions of section

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