SIGMA RESEARCH & CONSULTING PVT. LTD vs. COMMISSIONER OF INCOME TAX & ANR.

The appeal is allowed and the addition made under Section 40A(2)(a) of the Act

Bench: HON'BLE MR. JUSTICE SANJIV KHANNA,HON'BLE MR. JUSTICE ANUP JAIRAM BHAMBHANI

Delay of 03 days in re-filing the appeal is condoned for the reasons explained and stated in the application. Application is allowed. CM APP No. 4019/2018 (Stay) Disposed of as not pressed, in view of the fact that the appeal is taken- up for hearing. ITA 120/2018 page 2 of 9 ITA No.120/2018 Present appeal under Section 260A

UMAR DARAJ,MEERUT vs. ITO WARD-1(2)(4), MEERUT

In the result, the appeal filed by the assessee is partly allowed

Bench: Shri S.Rifaur Rahman & Shri Yogesh Kumar U.S.Umar Daraj, Vs. Ito, Ward 1(2)(4), 153/1, Hapur Road, Meerut. Umar Nagar, Meerut – 250 001 (Uttar Pradesh). (Pan : Ainpd8766H) (Appellant) (Respondent) Assessee By : Shri Sumit Lal Chandani, Advocate Revenue By : Shri Dayainder Singh Sidhu, Citdr Date Of Hearing : 17.09.2025 Date Of Order : 10.12.2025 O R D E R Per S. Rifaur Rahman:

condone the delay in filing the appeal before the Tribunal. 4. Brief facts of the case are, the assessee filed its original return of income on 20.09.2015 declaring total income of Rs.7,66,440/-. The case of the assessee was reopened by issue of notice under section 148 of the Income-tax Act, 1961 (for short ‘the Act’) dated

ACIT, NEW DELHI vs. M/S. CONTAINER CORPORATION OF INDIA LTD., NEW DELHI

In the result ITA No. 1364/Del/2012 for AY 2007-08 filed by the revenue is dismissed

Bench: Shri Kuldip Singh & Shri Prashant Maharishi

b. For Assessment Year 2007-08 it was submitted that order of the ld CIT(A) dated 19.08.2010 was communicated to Pr. CIT on 06.09.2010 for which time limit for filing of appeal before the coordinate bench expired on 05.11.2010. As the committee on Disputes (COD) approval is required which was refused on issues by minutes dated 18.02.2010 and subsequently

SIGMA CORPORATION INDIA LTD. vs. DCIT

The appeal is allowed in

Bench: HON'BLE MR. JUSTICE S. RAVINDRA BHAT,HON'BLE MR. JUSTICE NAJMI WAZIRI

delay of 11 days in re- filing the appeal is condoned. The appeal is taken on record. 2. The application stands disposed off. ITA 795/2016 3. The question of law which arises for consideration is as follows:- “Did the ITAT fall into error in restoring the disallowance of 50% of `48 lakhs paid to the appellant/assessee employee for the relevant

PR. COMMISSIONER OF INCOME TAX-7 vs. SMR AUTOMOTIVE SYSTEMS INDIA LTD.

condonation of delay of 54 days in filing the appeal] 2. This appeal concerns Assessment Year (AY) 2014-15. 3. Broadly, the only issue which arises for consideration is as to whether the Income Tax Appellate Tribunal [in short, “Tribunal] was correct in holding that the Specified Domestic Transactions (SDTs) did not attract the regime of transfer pricing, in view

NKC PROJECTS PRIVATE LIMITED,JAIPUR vs. PCIT DELHI-4, DELHI

In the result, the appeal of the assessee is allowed

40A(3) of the Act whereas the SCN under section 263 was regarding the FIFO method of valuation of closing stock adopted by the Assessee. These were, as rightly noted by the IT A T, unconnected issues and the assessment order could not have been held to be "erroneous and prejudicial to the interest of Revenue" when the AO could

PRINCIPAL COMMISSIONER OF INCOME TAX- 04 DELHI vs. MITSUBISHI CORPORATION (INDIA) PVT LTD

The appeal is dismissed against the Revenue

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

delay of 29 days in filing and 914 days in re-filing the appeal, is condoned. 2. Accordingly, the applications are disposed of. ITA 370/2025 3. This appeal is filed under Section 260A of The Income Tax Act, 1961 (the Act) lays a challenge to the order dated 12.08.2022 in ITA No. 9364/DEL/2019 passed by Income Tax Appellate Tribunal

PRINCIPAL COMMISSIONER OF INCOME TAX - 4 DELHI vs. MITSUBISHI CORPORATION (INDIA) PVT LTD

The appeals are dismissed against the

condonation of 38 days delay in filing the appeal and also 906 days delay in refilling the appeal in ITA 329/2025 and 38 days delay in filing the appeal and also 905 days delay in refilling the appeal in ITA 332/2025. 4. For the reasons stated in the applications, we allow the delay in refilling as well as the delay

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

B’, NEW DELHI BEFORE SH. R.K. PANDA, ACCOUNTANT MEMBER AND SH. N. K. CHOUDHRY, JUDICIAL MEMBER (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

SURYA ROSHNI LIMITED,NEW DELHI vs. PRINCIPAL COMMISSIONER OF INCOME TAX - 7, NEW DELHI

In the result, appeal filed by the assessee is allowed

40A(2)(b) of the Act. Therefore, assessee is required to file\nAuditor's Report in form 3CEB in accordance with the provisions of section 92E and\nsame is required to file electronically as defined in Rule 12. However, no such report is\navailable on record.\n\n\"if any person who has entered into an international transaction or specified

ACIT CIRCLE 54(1), NEW DELHI vs. SWADESH KUMAR MISHRA, GURGAON

In the result, appeal filed by the assessee i

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

40A(3) would not automatically amount to furnishing inaccurate particulars of income or concealment of income as the incurring of the said expenditure is not in dispute. (Principal CIT v Torque Pharmaceuticals P. Ltd., 2016 SCC On Line P&H 7150; Solidity Developers Private Ltd v CIT 2018 SCC On Line ITAT 20748). 27.3 Further submitted that Irrelevant limb

COMMISSIONER OF INCOME TAX DELHI II vs. LEO FINANCIAL SERVICES LTD.

Appeal is dismissed

Bench: HON'BLE MR. JUSTICE SANJIV KHANNA,HON'BLE MR. JUSTICE R.V.EASWAR

condone the delay in refiling. ITA 558/2010 Having heard the counsel for the parties, we have frame the following substantial question of law: “Whether the Income Tax Appellate Tribunal was right in setting aside the order of the Commissioner of Income Tax under Section 263 of the Income Tax Act, 1961?” 2. During the course of hearing it is stated

PR. COMMISSIONER OF INCOME TAX(CENTRAL)-2 vs. NAGAR DAIRY PVT. LTD.

In the result, Appeal of the Revenue in ITA No

delay of 14 days in filing the appeal is condoned. The application shall stand disposed of. ITA 320/2023, ITA 326/2023, ITA 341/2023 & ITA 369/2023 1. Since the respondents are duly represented, no further steps need be taken. 2. The Principal Commissioner of Income Tax impugns the order of the Income Tax Appellate Tribunal1 dated 24 November 2022 and has posited

GUPTA SUBHASH & SONS HUF,DELHI vs. ITO, WARD 34(3), DELHI, CIVIC CENTRE

In the result, the appeal filed by the assessee is allowed

Bench: SHRIS.RIFAUR RAHMAN (Accountant Member), SHRI VIMAL KUMAR (Judicial Member)

condone the delay in filing the appeal before the Tribunal. 5. Brief facts of the case are, assessee filed its return of income on 05.10.2017 declaring total income of Rs.3,49,095/- which was processed under section 143(1) of the Income-tax Act, 1961 (for short ‘the Act’). The case was selected for scrutiny through CASS. Notices

AMBAWATT BUILDWELL PVT. LTD.,NEW DELHI vs. PR. CIT (C), GURGAON

In the result, the appeal filed by the assessee is allowed

Bench: Shri R.K. Panda & Ms Suchitra Kambleassessment Year: 2014-15 Ambawatt Buildwell Pvt. Ltd., Vs Pr. Cit (C), Kh 267, 1St Floor, 7Th Floor, Hsiidc Building, Chatterpur Enclave, Udyog Vihar, Phase-V, Mehrauli, Gurgaon. New Delhi. Pan: Aagca0991B (Appellant) (Respondent) Assessee By : Shri P.C. Yadav, Advocate Revenue By : Shri Satpal Gulati, Cit, Dr Date Of Hearing : 10.03.2021 Date Of Pronouncement : 21.05.2021 Order Per R.K. Panda, Am: This Appeal Filed By The Assessee Is Directed Against The Order Dated 17Th February, 2017 Passed U/S 263 Of The Act By The Cit, Central, Gurgaon, Relating To Assessment Year 2014-15. 2. Facts Of The Case, In Brief, Are That The Assessee Is A Company Engaged In The Business Of Real Estate. It Filed Its Return Of Income On 30Th September, 2014, Declaring Nil Income. The Case Of The Assessee Was Selected For Compulsory Scrutiny & A Notice U/S 143(2) Of The Act Was Issued To The Assessee On 20Th September, 2015. Notice U/S 142(1) Along With A Questionnaire Was Also Issued On 12Th May, 2016. In Response To The Statutory Notices Issued By The Ao, The Assessee Appeared Before Him From Time To Time & Furnished Replies Which Were Kept On Record. The Ao, On The Basis Of Various Details Furnished Before Him, Disallowed An Amount Of Rs.3,91,936/- U/S 40A(3) Out Of Car Repairs & Maintenance & Determined The Total Loss Of The Assessee At Rs.94,25,270/- As Against The Returned Loss Of Rs.98,17,203/-.

40A(3) out of car repairs and maintenance and determined the total loss of the assessee at Rs.94,25,270/- as against the returned loss of Rs.98,17,203/-. 3. Subsequently, the ld.PCIT called for the records and examined the same and noted that no revenue from operations has been shown by the assessee during the relevant financial year

ZETA BUILDTECH PRIVATE LIMITED,DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-7, DELHI, DELHI

In the result, appeal filed by the assessee is allowed

Bench: Shri S. Rifaur Rahman & Shri Raj Kumar Chauhan

condone the delay in filing the appeal before the Tribunal. 4. Brief facts of the case are, assessee filed its return of income for Assessment Year 2020-21 on 08.01.2021 declaring total income of Rs. 98,48,230/- and claimed Refund of Rs. 80,80,460/-. Subsequently, the Return of Income was processed u/s 143(1)(a) of the Income

MOHD ABID,GHAZIABAD vs. ITO WARD 2(1)(3), GHAZIABAD

In the result, assessee’s appeal stands allowed for statistical purposes only

Bench: Shri Kul Bharat[Assessment Year: 2016-17

2. Facts giving rise to the present appeal are that in this case assessee had filed his return of income electronically on 17.10.2016 declaring total income at Rs. 6,69,770/-. Return was processed u/s 143(1) of the Income-tax Act, 1961 (hereinafter referred to as the “Act”). Thereafter the case was selected for scrutiny and the assessment

REFRESHMENT PRODUCT SERVICE INDIA PRIVATE LIMITED,NEW DELHI vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE 19(1), NEW DELHI

In the result, the appeal filed by the assessee is allowed for statistical purposes

Bench: Sh. S. Rifaur Rahman & Sh. Sudhir Kumarassessment Year: 2018-19 Refreshment Product Vs. Acit Service India Private Circle – 19 (1) Limited, B-91, Mayapuri New Delhi Industrial Area, Phase-1, New Delhi Pan No.Aagcr4112D (Appellant) (Respondent) Appellant By Sh. Sachit Jolly, Advocate Sh. Abhyudaya Shankar Bajpai, Advocate Sh. Aditya Rathore, Advocate Respondent By Ms. Shashi Kajle, Sr. Dr Date Of Hearing: 12/08/2024 Date Of Pronouncement: 16/08/2024 Order Per Sudhir Kumar, Jm:

B-91, Mayapuri New Delhi Industrial Area, Phase-1, New Delhi PAN No.AAGCR4112D (APPELLANT) (RESPONDENT) Appellant by Sh. Sachit Jolly, Advocate Sh. Abhyudaya Shankar Bajpai, Advocate Sh. Aditya Rathore, Advocate Respondent by Ms. Shashi Kajle, Sr. DR Date of hearing: 12/08/2024 Date of Pronouncement: 16/08/2024 ORDER PER SUDHIR KUMAR, JM: This appeal by the assessee is directed against the order