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

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

VOITH HYDRO P.LTD,NEW DELHI vs. DCIT, CIRCLE-25(1), NEW DELHI

In the result, appeal of the assessee is allowed

delay was condoned. The core issue revolves around the interplay of Section 144C and Section 153 of the Income Tax Act, 1961, concerning the time limits for passing the final assessment order.", "held": "The Tribunal held that the provisions of Section 144C and Section 153 are mutually inclusive and that the period of limitation must be determined with reference

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 hereby condoned.\n1.1 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

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

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

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

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

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

3. The common grievance on merits in the captioned appeals relates to the alleged constitution of dependent agent PE and taxability of royalty income under Article 7 of India – UK DTAA. 4. In ITA No. 2609/DEL/2020, 654/DEL/2020 and 869/DEL/2020 pertaining to Assessment Years 2007-08, 2010-11 and 203-14 respectively, there is a delay in filing the appeals

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

3. The common grievance on merits in the captioned appeals relates to the alleged constitution of dependent agent PE and taxability of royalty income under Article 7 of India – UK DTAA. 4. In ITA No. 2609/DEL/2020, 654/DEL/2020 and 869/DEL/2020 pertaining to Assessment Years 2007-08, 2010-11 and 203-14 respectively, there is a delay in filing the appeals

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

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

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

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

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