DCIT, NEW DELHI vs. M/S MARUTI SUZUKI INDIA LTD.,, NEW DELHI

In the result, the appeals of the assessee are allowed and the appeals of the revenue are dismissed

Bench: Sh. Amit Shukladr. B. R. R. Kumar(E-Court Module) Ita No. 2553/Del/2013 : Asstt. Year : 1999-00 Maruti Suzuki India Ltd., Vs Commissioner Of Income Tax Plot No. 1, Nelson Mandela Road, (Appeals)-Ix, Income Tax Vasant Kunj, New Delhi-110070 Office, Laxmi Nagar, New Delhi (Appellant) (Respondent) Pan No. Aaacm0829Q Ita No. 2641/Del/2013 : Asstt. Year : 1999-00 Dcit, Vs Maruti Suzuki India Ltd., Circle-6(1), Plot No. 1, Nelson Mandela Road, New Delhi Vasant Kunj, New Delhi-110070 (Appellant) (Respondent) Pan No. Aaacm0829Q Ita No. 468/Del/2014 : Asstt. Year : 1994-95 Maruti Suzuki India Ltd., Vs Jcit(Osd), Plot No. 1, Nelson Mandela Road, Circle-6(1), Vasant Kunj, New Delhi-110070 New Delhi (Appellant) (Respondent) Pan No. Aaacm0829Q

1) to Section 244A. 36. In the case of H.E.G, the revenue has not provided interest on the TDS i.e. the tax paid u/s 206 which the Court has ordered to pay interest on the TDS of Rs.45,73,528/- on the ITA Nos. 2553 & 2641/Del/2013 Maruti Suzuki India Ltd. original assessment till the date of payment. To reiterate

MARUTI SUZUKI INDIA LTD.,NEW DELHI vs. JCIT (OSD), NEW DELHI

In the result, the appeals of the assessee are allowed and the appeals of the revenue are dismissed

Bench: Sh. Amit Shukladr. B. R. R. Kumar(E-Court Module) Ita No. 2553/Del/2013 : Asstt. Year : 1999-00 Maruti Suzuki India Ltd., Vs Commissioner Of Income Tax Plot No. 1, Nelson Mandela Road, (Appeals)-Ix, Income Tax Vasant Kunj, New Delhi-110070 Office, Laxmi Nagar, New Delhi (Appellant) (Respondent) Pan No. Aaacm0829Q Ita No. 2641/Del/2013 : Asstt. Year : 1999-00 Dcit, Vs Maruti Suzuki India Ltd., Circle-6(1), Plot No. 1, Nelson Mandela Road, New Delhi Vasant Kunj, New Delhi-110070 (Appellant) (Respondent) Pan No. Aaacm0829Q Ita No. 468/Del/2014 : Asstt. Year : 1994-95 Maruti Suzuki India Ltd., Vs Jcit(Osd), Plot No. 1, Nelson Mandela Road, Circle-6(1), Vasant Kunj, New Delhi-110070 New Delhi (Appellant) (Respondent) Pan No. Aaacm0829Q

1) to Section 244A. 36. In the case of H.E.G, the revenue has not provided interest on the TDS i.e. the tax paid u/s 206 which the Court has ordered to pay interest on the TDS of Rs.45,73,528/- on the ITA Nos. 2553 & 2641/Del/2013 Maruti Suzuki India Ltd. original assessment till the date of payment. To reiterate

DCIT, NEW DELHI vs. M/S. MARUTI SUZUKI INDIA LTD., NEW DELHI

In the result, the appeals of the assessee are allowed and the appeals of the revenue are dismissed

Bench: Sh. Amit Shukladr. B. R. R. Kumar(E-Court Module) Ita No. 2553/Del/2013 : Asstt. Year : 1999-00 Maruti Suzuki India Ltd., Vs Commissioner Of Income Tax Plot No. 1, Nelson Mandela Road, (Appeals)-Ix, Income Tax Vasant Kunj, New Delhi-110070 Office, Laxmi Nagar, New Delhi (Appellant) (Respondent) Pan No. Aaacm0829Q Ita No. 2641/Del/2013 : Asstt. Year : 1999-00 Dcit, Vs Maruti Suzuki India Ltd., Circle-6(1), Plot No. 1, Nelson Mandela Road, New Delhi Vasant Kunj, New Delhi-110070 (Appellant) (Respondent) Pan No. Aaacm0829Q Ita No. 468/Del/2014 : Asstt. Year : 1994-95 Maruti Suzuki India Ltd., Vs Jcit(Osd), Plot No. 1, Nelson Mandela Road, Circle-6(1), Vasant Kunj, New Delhi-110070 New Delhi (Appellant) (Respondent) Pan No. Aaacm0829Q

1) to Section 244A. 36. In the case of H.E.G, the revenue has not provided interest on the TDS i.e. the tax paid u/s 206 which the Court has ordered to pay interest on the TDS of Rs.45,73,528/- on the ITA Nos. 2553 & 2641/Del/2013 Maruti Suzuki India Ltd. original assessment till the date of payment. To reiterate

PR. COMMISSIONER OF INCOME TAX -7 vs. SUMITOMO CORPORATION INDIA (P) LTD.

Bench: HON'BLE MR. JUSTICE YASHWANT VARMA,HON'BLE MR. JUSTICE RAVINDER DUDEJA

244A, the provisions of the fourth proviso shall apply accordingly.] Explanation 2.— For the purposes of this section, where, by an order referred to in clause (i) of sub-section (6),— (a) any income is excluded from the total income of the assessee for an assessment year, then, an assessment of such income for Digitally Signed By:KAMLESH KUMAR Signing

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

244A, the provisions of the fourth proviso shall apply accordingly.] Explanation 2.— For the purposes of this section, where, by an order referred to in clause (i) of sub-section (6),— (a) any income is excluded from the total income of the assessee for an assessment year, then, an assessment of such income for Digitally Signed By:KAMLESH KUMAR Signing

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

244A, the provisions of the fourth proviso shall apply accordingly.] Explanation 2.— For the purposes of this section, where, by an order referred to in clause (i) of sub-section (6),— (a) any income is excluded from the total income of the assessee for an assessment year, then, an assessment of such income for Digitally Signed By:KAMLESH KUMAR Signing

PROVIDENT INV. & INDUSTRIES (P) LTD.,NEW DELHI vs. ITO, NEW DELHI

In the result ground No. 5 of the appeal of the assessee is dismissed

Bench: Shri H.S.Sidhu & Shri Prashant Maharishiprovident Inv & Industries P Ltd, Vs. Ito, Ward-14(2), 4Th Floor, Ito, A-49, Mohan Cooperative Industrial Estate, Mathura Road, New Delhi Cr Building, New Delhi Pan:Aabcj4816P (Appellant) (Respondent)

condoned the delay in filing the appeal. 4. The assessee is a private limited company who filed its return of income declaring loss of Rs. 129603/- on 30.09.2008. Subsequently, on 16.12.2010 the ld Assessing Officer, during the course of assessment proceedings, found that there are complexity in the accounts of the assessee and in the interest of revenue its books

FLYING FABRICATION,NEW DELHI vs. DCIT, CPC, BENGALURU

In the result, the disallowance confirmed by the Appeal Centre is deleted

Bench: Shri Amit Shukla & Shri Prashant Maharishi

244A relating to refunds as claimed in the return of income. 10. That the Appellant denies liability towards interest charged u/s 234A, u/s 234B and u/s 234C and prays for appropriate relief.” 4 I.T.A. No.1049 & 1407/Del/2021 2. The facts in brief are that the assessee is engaged in the business of providing security/labour/manpower services. It has e-filed its return

FLYING FABRICATION ,GURGAON vs. ADIT, CPC, BENGALURUR

In the result, the disallowance confirmed by the Appeal Centre is deleted

Bench: Shri Amit Shukla & Shri Prashant Maharishi

244A relating to refunds as claimed in the return of income. 10. That the Appellant denies liability towards interest charged u/s 234A, u/s 234B and u/s 234C and prays for appropriate relief.” 4 I.T.A. No.1049 & 1407/Del/2021 2. The facts in brief are that the assessee is engaged in the business of providing security/labour/manpower services. It has e-filed its return

PR COMMISSIONER OF INCOME TAX 4 NEW DELHI vs. HCL INFOTECH PVT LTD

Bench: HON'BLE MR. JUSTICE DINESH MEHTA,HON'BLE MR. JUSTICE VINOD KUMAR

1. The instant application has been filed under Section 5 of the Limitation Act, 1963 read with Section 151 of CPC, seeking condonation of 690 days delay in re-filing the appeal. 2. For the reasons stated in the application, the delay is condoned. 3. The application is allowed. CM APPL. 3574/2026 (Exemption) 4. Exemption allowed, subject to all just

NALWA SONS INVESTMENTS LTD.,,HISAR vs. ACIT, NEW DELHI

In the result, the appeal stands allowed

Bench: Sh. G.D. Agrawal, Hon’Ble & Smt. Beena A Pillai, Jm

condoned the delay. 2.5 The Ld. CIT(A) held as under: “It is undisputed that MAT was paid by appellant as claimed it is well settled position of law that credit of MAT is to be allowed as prepaid taxes as decided by orderable apex court in C I T VS. Tulsyan NEC Ltd. reported

UNITED BANK OF INDIA (FORMELY) NOW PUNJAB NATIONAL BANK ,DELHI vs. ACIT LTU-1 KOLKATA (UNDER TRANSFER TO CIRCLE 19(1), DELHI

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

Bench: Shri Shamim Yahya & Shri Challa Nagendra Prasad[Assessment Year: 2009-10]

1, this Appeal was instituted on 01.02.2019 against the order dated 28.11.2017 by the AO for the assessment year 2009- 10. Thus there is a delay of 704 days in filing this appeal. However, the Appellant has claimed in Form 35 that the order was received by the Banking section on 1/12/2017 and so there is a delay of only

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

UNITED BANK OF INDIA (NOW MERGED WITH PNB),NEW DELHI vs. DCIT, CIRCLE-6, KOLKATA

Bench: Sh. Shamim Yahya & Sh. Anubhav Sharmaita No.1903/Del/2021, A.Y. 2008-09

1) & ITA No. 1903.Del.2021 United Bank of India 2 115WE(3) of the Income Tax Act, 1961 passed by DCIT, Circle-6, Kolkata (hereinafter referred to as the Assessing Officer or ‘AO’). 2. Heard and perused the record. 3. Ld. AR submitted that Ld. CIT(A) has been unjust in not accepting the factual explanation of the delay while

DCIT CIRCLE 4(2), NEW DELHI vs. CANON INDIA PVT. LTD., NEW DELHI

In the result, to sum up and conclude:

Bench: Shri Challa Nagendra Prasad & Shri Naveen Chandra

delay is therefore is condoned. The solitary ground raised by the assessee in the cross objection read as under: “That on the facts and in the circumstances of the case and in law, the Respondent should be allowed interest u/s 244A of the Act on refund and while computing such interest, the foreign tax credit should be kept

CANON INDIA PVT. LTD,GURUGRAM vs. NEAC, DELHI

In the result, to sum up and conclude:

Bench: Shri Challa Nagendra Prasad & Shri Naveen Chandra

delay is therefore is condoned. The solitary ground raised by the assessee in the cross objection read as under: “That on the facts and in the circumstances of the case and in law, the Respondent should be allowed interest u/s 244A of the Act on refund and while computing such interest, the foreign tax credit should be kept

ACIT, CIRCLE-24(1), NEW DELHI vs. SPRING INFRADEV LTD., NEW DELHI

Bench: Shri Yogesh Kumar Us & Shri Brajesh Kumar Singh[Assessment Year:2016-17]

delay of 1726 days in filing the cross objection is condoned. CO No.118/Del/2024 6. During the hearing before us, the assessee reiterated the above fact of inadvertently offering the above capital gains and submitted that the AO is obligated to assess the correct income relying upon Board Circular No.14 XL-35, dated 11.04.1955. It was further submitted that tax collection

CHETAN SETH,NEW DELHI vs. ITO,WARD-15(3), DELHI

Bench: Shri Satbeer Singh Godara & Shri Brajesh Kumar Singh

condone the delay of 2947 days and admit this appeal for hearing. 3. Grounds of appeal raised by the assessee in ITA No.1808/Del/2023 for AY 2004-05 are as under:- “1.1. That the CIT (A) erred on facts and in law in not holding that the assessment order passed by the assessing officer under section 147/144 of the Income

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

Bench: Shri Satbeer Singh Godara & Shri Brajesh Kumar Singh

condone the delay of 2947 days and admit this appeal for hearing. 3. Grounds of appeal raised by the assessee in ITA No.1808/Del/2023 for AY 2004-05 are as under:- “1.1. That the CIT (A) erred on facts and in law in not holding that the assessment order passed by the assessing officer under section 147/144 of the Income