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

5. 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

5. 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

5. In view of the aforesaid, we 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

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

5. The contents of the application for condonation of delay have been duly considered and since the ld. DR has not raised any strong objection against the condonation of delay and finding that the assessee was prevented by reasonable and sufficient cause in not filing the appeals on or before the due date, the delay is condoned. 6. Except

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

5. The contents of the application for condonation of delay have been duly considered and since the ld. DR has not raised any strong objection against the condonation of delay and finding that the assessee was prevented by reasonable and sufficient cause in not filing the appeals on or before the due date, the delay is condoned. 6. Except

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. 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.,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

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

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

Section 144C of the Act. 4. We do not find any merit in the submission. The Tribunal in the first round vide order dated 15.03.2012 while remanding the case to the Assessing Officer, had directed: “6. We have heard the parties and have perused the material on record. The DRP has rejected the objections raised by the assessee against

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

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

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

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

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

144C (5) of the income tax act wherein the total income of the assessee is determined at rupees loss of INR 246415671/– against the return of income filed by the assessee on 25/7/2008 at the loss of INR 7 55599323/–. The assessee has raised the following grounds of appeal in ITA No. 1064/Del/2013:- “1. That the assessing officer erred

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