THE COMMISSIONER OF INCOME TAX -INTERNATIONAL TAXATION -2 vs. THE BANK OF TOKYO -MITSUBISHI UFJ LTD.

condone the delay. 8.1 It is ordered accordingly. 9. The application is disposed of. ITA 140/2023 10. This appeal concerns Assessment Year (AY) 2007-2008. 11. Mr Bhatia points out that in another AY concerning the respondent/assessee, the revenue’s appeal has been admitted. 12. The core issue which arises for consideration in the present appeal is: whether the Tribunal

ACIT, NEW DELHI vs. M/S. HUMBOLDT WEDAG INDIA PVT. LTD., NEW DELHI

In the result ITA 3207/Del/2016 stands allowed

Bench: Shri R.K. Panda & Shri Sudhanshu Srivastava

condone the delay. 3. Brief facts of the case are that the assessee is a wholly owned subsidiary of KHD Humboldt Wedag International GmbH (Humboldt Austria). The company is primarily engaged in designing, supplying of equipment, supervision of installation, erection and commissioning activities for the cement industry on a turn-key basis (non-civil). The return of income for assessment

HUMBOLDT WEDAG INDIA PVT. LTD.,DELHI vs. ACIT, NEW DELHI

In the result ITA 3207/Del/2016 stands allowed

Bench: Shri R.K. Panda & Shri Sudhanshu Srivastava

condone the delay. 3. Brief facts of the case are that the assessee is a wholly owned subsidiary of KHD Humboldt Wedag International GmbH (Humboldt Austria). The company is primarily engaged in designing, supplying of equipment, supervision of installation, erection and commissioning activities for the cement industry on a turn-key basis (non-civil). The return of income for assessment

HUMBOLDT WEDAG INDIA PVT. LTD.,NEW DELHI vs. ACIT, NEW DELHI

In the result ITA 3207/Del/2016 stands allowed

Bench: Shri R.K. Panda & Shri Sudhanshu Srivastava

condone the delay. 3. Brief facts of the case are that the assessee is a wholly owned subsidiary of KHD Humboldt Wedag International GmbH (Humboldt Austria). The company is primarily engaged in designing, supplying of equipment, supervision of installation, erection and commissioning activities for the cement industry on a turn-key basis (non-civil). The return of income for assessment

SHRI CHETAN SETH,NEW DELHI vs. ITO, NEW DELHI

The appeals of the assessee are partly allowed

Bench: Shri Satbeer Singh Godara\Nand\Nshri Brajesh Kumar Singh\Nita Nos.1808/Del/2023 & 2983, 2984 & 2985/Del/2015\N[Assessment Years: 2004-05, 2005-06, 2006-07 & 2007-08]\Nshri Chetan Seth,\Nplot No.14, Lcs, Sector-B-1,\Nvasant Kunj,\Nnew Delhi-110070\Npan-Aolps2992A\Nappellant\Nincome Tax Officer,\Nward-15(3),\Nvs New Delhi\Nrespondent\Nappellant By\Nrespondent By\Nshri Arun Kishore, Ca &\Nshri Alok Suri, Ca\Nshri Rajesh Kumar Dhanesta, Sr.\N(Dr)\Ndate Of Hearing\Ndate Of Pronouncement\N28.03.2025\N25.06.2025\Norder\Nper Brajesh Kumar Singh, Am,\Nthese Four Appeals Filed By The Assessee Are Directed Against The\Norder Of Ld. Commissioner Of Income Tax (Appeals)-7, Delhi, Dated\N24.02.2015 For Ay 2004-05, 27.02.2015 For Ay 2005-06, 2006-07 And\N2007-08 Respectively Arising Out Of Assessment Orders Passed U/S 147/144\Nof The Income Tax Act, 1961 (Hereinafter Referred To ‘The Act') Dated\N31.10.2011 For All The Above Assessment Years, Respectively. Since, The\Nissues Are Common & Connected, Hence, These Appeals Were Heard\Ntogether & Are Disposed Of By This Common Order.\N2. First, We Shall Take Up The Ita No.1808/Del/2023 Pertaining To Ay\N2004-05.\N2.

sections": [ "147", "144", "2(22)(e)", "148", "151", "127", "129", "234A", "234B", "234D", "244A", "143(1)", "143(3)", "153", "154", "155", "150(1)", "150(2)" ], "issues": "1. Condonation of delay

MARELLI (INDIA) PRIVATE LIMITED,GURUGRAM vs. DEPUTY COMMISSIONAR OF INCOME-TAX, CIRCLE 16(1), NEW DELHI

In the result, the appeal of the assessee is allowed for statistical purpose

Bench: Sh. Sudhir Kumar & Sh.Manish Agarwalassessment Year: 2020-21 Marelli (India) Private Limited Vs Deputy Commissioner Of 5Th Floor, Tower 8, Candor Income Tax, Circle 16(1) Teachspace,One Reality Project Cr Building, Delhi It/Ites Sez Village Tikri Sector 48 Gurugram Haryana-122018 Pan No. Aagcm2620K (Appellant) (Respondent)

condoned the delay and extended the due date for filing or filing form no.10IC for AY 2020-21 to 30/06/2022. 4.8 As at present, the appellant has not established that the Form 10IC has been filed within the extended due date, the corresponding ground of appeal is therefore dismissed. Ground relating to levy of interest under section 234B, 234C

TIRUPATI INKS LTD.,NEW DELHI vs. DCIT, CIRCLE- 25(1), NEW DELHI

In the result, the appeal filed by the Assessee stands allowed for statistical purposes

Bench: Sh. R.K. Panda & Sh. N. K. Choudhry(Through Video Conferencing) Assessment Year: 2013-14 Tirupati Inks Ltd. Vs Dcit 1517, Devika Tower, Circle- 25 (1) 6, Nehru Place, New Delhi New Delhi Pan No. Aaacs2222F (Appellant) (Respondent) Appellant By None Respondent By Shriharpal Singh Kharb, Sr. Dr Date Of Hearing: 06/01/2022 Date Of Pronouncement: 06/01/2022

Section 250(6) of the Income Tax Act, 1961 (in short „the Act‟) for assessment year 2013- 14. 2. None appeared on behalf of the Assessee at the time of hearing. Even no application seeking adjournment of the case has been filed. Though three notices for the date of hearing on 18/08/2021, 2/11/2021 and 06/01/2022 were sent though RPAD

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

234D of the Act upto the date of order passed under Section 254 read with Section 143(3) and Section 144C of the Act (i.e. till April 29, 2016) in complete ignorance of the fact that refund granted to the appellant for subject AY was recovered on January 31, 2011, by way of adjustment of refund determined

ITL LABS PVT. LTD.,NEW DELHI vs. ASST. COMMISSIONER OF INCOME-TAX, CIRCLE 12(2), NEW DELHI, NEW DELHI

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

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.

section 115BBE of the Income-tax Act, 1961 without considering that the source of the cash deposits being bank withdrawals and cash sales, was duly explained and hence no addition u/s 68 r.w.s. 115BBE can be upheld. 4. That in the facts and circumstances of the case, the Ld. AO erred in making the addition

SAMTA MITTAL,FARIDABAD vs. INCOME TAX OFFICER, DELHI

In the result, the appeal of the assessee is dismissed

Bench: Sh. Sudhir Kumar & Sh. Manish Agarwalassessment Year: 2018-19 Samta Mittal Vs. Ito 601, Royal Retreat, New Delhi Surajkund, Faridabad Pan No. Agzpm5730G (Appellant) (Respondent)

234D. 7. That the appellant craves the leave to add, modify, amend or 7 delete any of the grounds of appeal at the time of hearing and all the above grounds are without prejudice to each other. Whether there is any delay in filing of appeal (if yes, 11 please attach application seeking condonation of delay

CARITAS INDIA,NEW DELHI vs. ITO (E), NEW DELHI

Appeal is allowed for statistical purposes

Bench: Shri R.S. Syal & Shri Kuldip Singh

condone the delay in filing income and expenditure account along with Form 10AA before the prescribed authority viz. Director of Income Tax (Exemptions). 2. Without prejudice, that the Commissioner of Income Tax (Appeals) erred on facts and in law in not reducing the addition made in the assessment order by an amount of Rs.10,97,87,750, since the amount

DR. PRIYA NARULA,NEW DELHI vs. ITO WARD INT. TAX 2(2)(2), NEW DELHI

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

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

Section 115BBE of the Act could not be invoked and accordingly the Assessment Orders U/s 143(3) dated 24.12.2019 ("assessment orders) are arbitrary in nature and against the natural principles of natural justice. 7. That the Ld. AO also erred in charging interest u/s 234B and 234D of the Act while determining demand payable by the Appellant without appreciating that

PRINCIPAL COMMISSIONER OF INCOME TAX, DELHI-1 vs. BORGWARNER EMISSIONS SYSTEMS INDIA PRIVATE LTD.

Appeal is allowed

Bench: HON'BLE MR. JUSTICE V. KAMESWAR RAO,HON'BLE MR. JUSTICE VINOD KUMAR

delay of 310 days in re- filing the appeal is condoned. 2. The application is disposed of. ITA 750/2025 3. This appeal has been filed with the following prayers:- “1. Frame the substantial Questions of Law mentioned in Para 3 of the appeal; 2. Frame any other substantial Questions of Law which may arise from the Impugned Order dated

MANPOWERGROUP SERVICES INDIA PRIVATE LIMITED,DELHI vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2, DELHI , JHANDEWALAN EXTENSION, NEW DELHI

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

Bench: Shri Mahavir Singh & Shri Naveen Chandra

234D. 8. That on the facts and in the circumstances of the case and in law, the AO has erred in initiating penalty proceedings u/s 270A(9)(a), 271B and 271AA read with section 274 of the Act. 9. The Assessee prays for leave to add, alter, amend and/ or' modify any of the grounds of appeal at or before

VAG INFOTECH ,DELHI vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-53(1), NEW DELHI, DELHI

In the result, the Assessee’s appeal is allowed for statistical purposes

Bench: Shri Shamim Yahya & Shri Vimal Kumara.Yr. : 2013-14 Vag Infotech, Vs. Acit, Circle 53(1), D-42, South Extension Part-I, New Delhi New Delhi – 110 049 (Pan: Aaafv2681C) (Appellant) (Respondent)

section 50C. 4. That in any case and in any view of the matter, action of Ld. CIT(A) in not deleting the various addition/disallowances as stated above, is bad in law and against the facts and circumstances of the case. 5. That having regard to the facts and circumstances of the case, Ld. CIT(A) has erred

KEMA INDIA PRIVATE LIMITED,NEW DELHI vs. ITO WARD - 14(3), NEW DELHI

The appeal of the assessee is allowed with direction to the Ld

Bench: Sh. R.K.Panda & Sh. Anubhav Sharmam/S. Kema India Private Vs. Ito Limited, Ward-14(3), 2Nd Floor, Elegance Tower, New Delhi Jasola District Centre, Old Mathura Road,, New Delhi Pan – Aaeck5438P (Appellant) (Respondent)

delay condonation application of the assessee is allowed. 3. Coming to the merits, the brief facts are that the appellant is a Private Limited Company engaged in the business of energy supply, environment and quality assurance wherein it acts as consultants and technical advisors. The return for the assessment year 2015-16 was taken up for scrutiny through CASS

ALEXIS GLOBAL PRIVATE LIMITED,NEW DELHI vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE 2(2), DELHI, DELHI

Bench: SHRI S.RIFAUR RAHMAN (Accountant Member), SHRI SUDHIR KUMAR (Judicial Member)

234D of the Act. 10. That the grounds of appeal are independent and without prejudice to each other.” 7. At the time of hearing, the Ld. AR submitted elaborately before us and also filed a written submissions, which is reproduced as under:- “1.SOURCE ESTABLISHED AS PAYMENTS DULY RECORDED IN BOOKS OF ACCOUNT AND MADE THROUGH BANKING CHANNEL OUT OF FUNDS

NIMBUS (INDIA) LTD.,NEW DELHI vs. DCIT, CENTRAL CIRCLE, NOIDA

In the result, both the appeals filed by the assessee are partly allowed

Bench: Shri R.K. Panda & Shri K. Narasimha Chary

234D of Income Tax Act, 1961. 8. That the appellant craves the leave to add, modify, amend or delete any of the grounds of appeal at the time of hearing and all the above grounds are without prejudice to each other.” 12. The ld. Counsel for the assessee, at the time of hearing, fairly conceded that grounds of appeal