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

254, section 260, section 262, section 263, or section 264 or in an order of any court in a proceeding otherwise than by way of appeal or reference under this Act, on or before the expiry of twelve months from the end of the month in which such order is received or passed by the [Principal Chief Commissioner or Chief

HL MALHOTRA AND COMPANY PVT. LTD.

The appeal is disposed of

254(2) of the Act is pending consideration, this Court should not condone the delay in the present case. He states that condonation of ARGUMENTS ON BEHALF OF THE RESPONDENT 2020:DHC:3695-DB ITA NO.211/2020 Page 4 of 10 delay in filing the appeal would amount to allowing the appellant to midway abandon its application under Section

ITO, NEW DELHI vs. M/S GRAVITY SYSTEMS PVT. LTD., DELHI

In the result, appeal of the Revenue is dismissed while the cross objection of the assessee is partly allowed

Bench: Shri. P. K. Bansal & Shri K.N. Charry Assessment Year:2004-05

condone the delay and admit the cross objection taken by the assessee for hearing. 6. In the cross objection, the assessee has taken legal issues. We, therefore, have decided to dispose of the cross objection first. 7. Ground No.3 in the cross objection taken by the assessee since not pressed stands dismissed as not pressed. 8. Grounds No.1 & 2 relate

PR. COMMISSIONER OF INCOME TAX (CENTRAL)-2 vs. GREEN MARK INFRA LTD.

delay in re-filling the Digitally Signed By:ATUL JAIN Signing Date:14.03.2023 12:03:38 Signature Not Verified NEUTRAL CITATION NO : 2023/DHC/001806 ITA Nos.78/2023 & 79/2023 Page 2 of 5 appeals is condoned. 5. The applications are disposed of in the aforesaid terms. ITA 78/2023 ITA 79/2023 6. These appeals are directed against order dated 01.04.2022 passed by the Income

M/S. DOON VALLEY SPECIAL AREA DEVELOPMENT AUTHORITY,DEHRADUN vs. DCIT, DEHRADUN

In the result all the above four appeals filed by the assessee are disposed off by this common order

Bench: Smt Diva Singh & Shri Prashant Maharishidoon Valley Special Area Vs. Cit (Exemption), Development Authority, Tc 46V, Up State 12, Pritam Road, Construction & Dehradun Infrastructure Development Pan: Aaald0125F Corporation, Vibhuti Khand, Gomti Nagar, Lucknow (Appellant) (Respondent)

2)(b) passed by CBDT subsequently, condoning the delay filing the application for registration which was originally passed on 29.01.2010. He further stated that the assessee should have attended the office of the ld CIT(E) on the appointed date and requested him for amendment in the order passed u/s 12AA of the Act. The assessee has not appeared

M/S. DOON VALLEY SPECIAL AREA DEVELOPMENT AUTHORITY,DEHRADUN vs. DCIT, DEHRADUN

In the result all the above four appeals filed by the assessee are disposed off by this common order

Bench: Smt Diva Singh & Shri Prashant Maharishidoon Valley Special Area Vs. Cit (Exemption), Development Authority, Tc 46V, Up State 12, Pritam Road, Construction & Dehradun Infrastructure Development Pan: Aaald0125F Corporation, Vibhuti Khand, Gomti Nagar, Lucknow (Appellant) (Respondent)

2)(b) passed by CBDT subsequently, condoning the delay filing the application for registration which was originally passed on 29.01.2010. He further stated that the assessee should have attended the office of the ld CIT(E) on the appointed date and requested him for amendment in the order passed u/s 12AA of the Act. The assessee has not appeared

M/S DOON VALLEY SPECIAL AREA DEVELOPMENT AUTHORITY,DEHRADUN vs. DCIT, DEHRADUN

In the result all the above four appeals filed by the assessee are disposed off by this common order

Bench: Smt Diva Singh & Shri Prashant Maharishidoon Valley Special Area Vs. Cit (Exemption), Development Authority, Tc 46V, Up State 12, Pritam Road, Construction & Dehradun Infrastructure Development Pan: Aaald0125F Corporation, Vibhuti Khand, Gomti Nagar, Lucknow (Appellant) (Respondent)

2)(b) passed by CBDT subsequently, condoning the delay filing the application for registration which was originally passed on 29.01.2010. He further stated that the assessee should have attended the office of the ld CIT(E) on the appointed date and requested him for amendment in the order passed u/s 12AA of the Act. The assessee has not appeared

M/S. DOON VALLEY SPECIAL AREA DEVELOPMENT AUTHORITY,DEHRADUN vs. CIT (EXEMPTIONS), LUCKNOW

In the result all the above four appeals filed by the assessee are disposed off by this common order

Bench: Smt Diva Singh & Shri Prashant Maharishidoon Valley Special Area Vs. Cit (Exemption), Development Authority, Tc 46V, Up State 12, Pritam Road, Construction & Dehradun Infrastructure Development Pan: Aaald0125F Corporation, Vibhuti Khand, Gomti Nagar, Lucknow (Appellant) (Respondent)

2)(b) passed by CBDT subsequently, condoning the delay filing the application for registration which was originally passed on 29.01.2010. He further stated that the assessee should have attended the office of the ld CIT(E) on the appointed date and requested him for amendment in the order passed u/s 12AA of the Act. The assessee has not appeared

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

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

IMPERIAL AUTO INUDSTRIES LIMITED,DELHI vs. DCIT, DELHI

Bench: Shri G. S. Pannu & Ms. Madhumita Royi.T.A. No. 3927/Del/2023 (Assessment Year : 2020-21) M/S. Imperial Auto Vs. Asst. Director Of Income Tax Industries Ltd., Centralized Processing Plot No.202, Kushal Cell, Bengaluru Bazar, 32-33, Nehru Place, New Delhi-110019 Pan: Aaaci 0645 J (Appellant) .. (Respondent)

254 days, because the reasons assigned for the condonation were not sufficient reasons for condonation of the delay. I am further fortified by the decision of the Hon'ble Supreme Court in the case of Balwant Singh (Dead) vs Jagdish Singh & Ors, dated 08/07/2010, where it has held in para 6 that "Law of limitation may harshly affect a particular

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]

condonation of delay. 3 5. Giving thoughtful consideration to the matter on record it can be observed that the assessee is a public sector bank. The present issue has a chequered history as reflected in para no. 2 of the order of Ld. CIT(A) as follows :- “2. Brief Facts of the Case Briefly the facts of the case

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

254, Sec. 255, Sec. 260, Sec.262, Sec. 263, Sec. 264, Sec. 245D(4) effectively directed to re- compute the refund determined u/s 143(1) or Sec. 143(3) and to pre-determine the quantum of the refund of the amount due afresh. Thus after receipt of the order under these sections, the tax payable/refund payable would be re-computed

MARUTI SUZUKI INDIA LTD.,NEW DELHI vs. DCIT, 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

254, Sec. 255, Sec. 260, Sec.262, Sec. 263, Sec. 264, Sec. 245D(4) effectively directed to re- compute the refund determined u/s 143(1) or Sec. 143(3) and to pre-determine the quantum of the refund of the amount due afresh. Thus after receipt of the order under these sections, the tax payable/refund payable would be re-computed

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

254, Sec. 255, Sec. 260, Sec.262, Sec. 263, Sec. 264, Sec. 245D(4) effectively directed to re- compute the refund determined u/s 143(1) or Sec. 143(3) and to pre-determine the quantum of the refund of the amount due afresh. Thus after receipt of the order under these sections, the tax payable/refund payable would be re-computed

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

254, Sec. 255, Sec. 260, Sec.262, Sec. 263, Sec. 264, Sec. 245D(4) effectively directed to re- compute the refund determined u/s 143(1) or Sec. 143(3) and to pre-determine the quantum of the refund of the amount due afresh. Thus after receipt of the order under these sections, the tax payable/refund payable would be re-computed

MITHLESH KUMAR TRIPATHI,DELHI vs. ITO,WARD-24(4), DELHI

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

Bench: Shri Yogesh Kumar U.S. & Shri Avdhesh Kumar Mishra

section 254 of the Act, the Tribunal may pass such orders as it 6 Mithlesh Kumar Tripathi thinks fit. We are of the considered view that there was no malafide or deliberate delay in filing this appeal. In the interest of substantial justice, the delay in filing this appeal deserves to be condoned and this appeal be decided on merit

ACIT, NEW DELHI vs. M/S WORLDWIDE REALTORS PVT. LTD.,, NEW DELHI

In the result, three appeals by Revenue are dismissed

Bench: Shri Amit Shukla & Shri Anadee Nath Misshra

2. That the CIT(A) has substantially erred on facts and in law in condoning the dealy in filing the appeal without considering without considering that the assessee had remained completely non complain and non cooperative even after the search and had not filed nay details before the investigation authorities. 3. That the CIT (A) has erred on facts