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

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

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

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

VISHAL GULATI,HARYANA vs. ACIT, CIRCLE INTERNATIONAL TAXATION1(3)(1) , NEW DELHI

In the result, the appeals of the assessee are allowed

Bench: Shri Challa Nagendra Prasad & Dr. B. R. R. Kumar

Delay Condoned: 2. The present appeal has been filed by the assessee against the order of Assessing Officer dated 30.06.2022 for the A.Y. 2018-19. 3. The assessee has raised the following grounds of appeal:- “1. That on the facts and circumstances of the case & in law, the impugned assessment order passed under section 143(3) r.w.s. 144C

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

Appeal is allowed

5. Directions under section 144C of the Income Tax Act: The Assessing Officer is directed to complete the assessment as per the above directions of the Dispute Resolution Panel. The Assessing Officer shall place a copy of these directions as annexure to the final order, to be read as a part of the order. While passing the final order

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

5. The applications are disposed of. ITA 708/2023 ITA 709/2023 6. These appeals concern Assessment Year (AY) 2010-11 [ITA 708/2023] and AY 2008-09 [ITA 709/2023]. 7. Via the instant appeals, the appellant/revenue seeks to assail the order dated 09.11.2020 passed by the Income Tax Appellate Tribunal [in short, “Tribunal”]. 8. Mr Ruchir Bhatia, learned senior standing counsel

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

5. The applications are disposed of. ITA 708/2023 ITA 709/2023 6. These appeals concern Assessment Year (AY) 2010-11 [ITA 708/2023] and AY 2008-09 [ITA 709/2023]. 7. Via the instant appeals, the appellant/revenue seeks to assail the order dated 09.11.2020 passed by the Income Tax Appellate Tribunal [in short, “Tribunal”]. 8. Mr Ruchir Bhatia, learned senior standing counsel

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

BERGER BECKER COATINGS PVT LTD,DELHI vs. DCIT,CIRCLE-4(2), DELHI

In the result, the Appeal of the Assessee is partly allowed for

Bench: Yogesh Kumar U.S. & Shri Manish Agarwalberger Becker Coatings Private Vs Income Tax Department Limited, 19 Dda, Commercial Dcit Circle 4(2), C. R. Complex, Kailsah Colony Building, New Delhi Extension, Zamrudpur, New Delhi Pan: Aabcb8159K Appellant Respondent Assessee By Sh. Nitin Sharma, Ca Revenue By Sh. S. K. Jadhav, Cit(Dr) Date Of Hearing 05/01/2026 Date Of Pronouncement 07/01/2026 Order Per Yogesh Kumar, U.S. Jm: The Present Appeal Is Filed By The Assessee Against The Order Of Ld. Commissioner Of Income Tax (Appeals)/National Faceless Appeal

delay of 73 days in filing the present appeal is condoned. 5. Brief facts of the case are that, an assessment order came to be passed on 30/10/2023 under Section 143(3) read with Section 144C

ESM GROUP INC,DELHI vs. DCIT, CIRCLE- 1(2)(2), INTERNATIONAL TAXATION, DELHI

In the result, the appeal of the assessee in ITA No

Bench: Shri Vikas Awasthy & Shri Naveen Chandra[A.Y 2008-09] M/S Esm Group Inc. Vs. The Dy.C.I.T Suite 118 N, 300, Corporate Park Circle -1(2)(2) Way Amherst, New York International Taxation New Delhi Pan: Aacce 4072 H (Applicant) (Respondent) Assessee By :Shri Sudhir Kumar Dash, Ca Department By :Ms. C. Chandra Kanta, Cit-Dr Date Of Hearing : 29.11.2024 Date Of Pronouncement : 25.02.2025

section 144C of the Income Tax Act, 1961. 2. That on the facts and circumstances of the case and in law, the LD, AO has erred in holding that the Appellant has a Permanent Establishment ("PE") in the form and DAPE inM/s. Rajalakshmi International Corporation (Proprietor Anand Mathur) 3. That on the facts and circumstances of the case

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