CIT vs. TEI TECHNOLOGIES PVT LTD

Bench: CASES PERTAINING TO SPL.DIVISION BENCHES

depreciation and losses of the unit, the income from which was not eligible for deduction under Section 10A cannot be set off against the current profit of the eligible unit for computing the deduction under Section 10A. Referring to its earlier judgment in the case of Hindustan Unilever Ltd. (supra) it was held as under: - “2. Section

DCIT, NEW DELHI vs. M/S. NEW DELHI TELEVISION LTD., NEW DELHI

Bench: Shri H. S. Sidhu & Shri Prashant Maharishinew Delhi Television Ltd, Vs. Acit, 207, Okhla Industrial Estate, Phase- Circle-13(1), Iii, New Delhi New Delhi Pan: Aaacn0865D (Appellant) (Respondent) Acit, Vs. New Delhi Television Ltd, Circle-13(1), 207, Okhla Industrial Estate, New Delhi Phase-Iii, New Delhi Pan: Aaacn0865D (Appellant) (Respondent)

b. Up gradation of software Rs. 21528 c. Accounting software Rs. 2216476 d. license and right to use software ₹ 3 9410 e. other software is having limited life ₹ 5 05378 f. Amount wrongly booked under software expenditure Rs. 550577/- The learned assessing officer treated the annual maintenance cost of Rs. 2732939/– as revenue expenditure and disallowed the balance expenditure

M/S. NEW DELHI TELEVISION LTD.,NEW DELHI vs. ACIT, NEW DELHI

Bench: Shri H. S. Sidhu & Shri Prashant Maharishinew Delhi Television Ltd, Vs. Acit, 207, Okhla Industrial Estate, Phase- Circle-13(1), Iii, New Delhi New Delhi Pan: Aaacn0865D (Appellant) (Respondent) Acit, Vs. New Delhi Television Ltd, Circle-13(1), 207, Okhla Industrial Estate, New Delhi Phase-Iii, New Delhi Pan: Aaacn0865D (Appellant) (Respondent)

b. Up gradation of software Rs. 21528 c. Accounting software Rs. 2216476 d. license and right to use software ₹ 3 9410 e. other software is having limited life ₹ 5 05378 f. Amount wrongly booked under software expenditure Rs. 550577/- The learned assessing officer treated the annual maintenance cost of Rs. 2732939/– as revenue expenditure and disallowed the balance expenditure

THE COMMISSIONER OF INCOME TAX vs. M.S.AGGARWAL

120 lacs and at page No. 56 and 57 annexed to the revised agreement showing consideration at Rs. 65 lacs. Thus the items purchased were the same and only balance consideration was passed on to the seller in cash out of undeclared sources of income. Q.17 These plant and machinery are still used by you or has again been

KUNSHAN Q TECH MICROELECTRONICS (INDIA) PVT. LTD.,UTTAR PRADESH vs. DCIT, CENTRAL CIRCLE-30, DELHI

4,68,86,17,357/- while framing order u/s 144C(5) of the Act.\n11. That on the facts, law and in the circumstances of the case, the Ld. AO, Ld. TPO as well as the Ld. DRP has erred in law in making arbitrary transfer pricing adjustment on account of purchase of raw material

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

In the result, the Revenue’s appeal is dismissed and the Cross Objection of the assessee is allowed

Bench: Shri G. S. Pannu & Shri Amit Shukla

depreciation of Rs.6,61,873/- (iv) Disallowance on account of rates and taxes of Rs.15,02,655/- 4. Apart from that, Assessing Officer has also disallowed the claim of deduction u/s.24(A) while assessing the income from house property on the ground that assessee has not produced any evidence. 5. Before the Ld. CIT(A), Kolkata, the assessee challenged that

PRASIDH FINCAP LTD. ,NEW DELHI vs. DCIT CIRCLE-20(1), NEW DELHI

In the result, all the appeals of the assessee are allowed

Bench: Shri M. Balaganesh & Shri Vimal Kumarprasidh Fincap Ltd, Vs. Dcit, 2Nd Floor, Rsn Arcade, 6 Circle-20(1), Lsc, Near Peince New Delhi Apartment, Ip Extension, Parparganj, New Delhi (Appellant) (Respondent) Pan:Aaacp6704D

120 Business Profit subject to charge of income-tax (40% of 240 600) 13. Analysing the above two charts, we find that at the end of computation the income chargeable to tas by applying rule 8 comes to Rs. 240. Under Illustration 'A', the normal depreciation is Rs. 100 which is deductible from Rs. 1,000 being the income from

PRASIDH FINCAP LTD,NEW DELHI vs. ITO, WARD-20(2), NEW DELHI

In the result, all the appeals of the assessee are allowed

Bench: Shri M. Balaganesh & Shri Vimal Kumarprasidh Fincap Ltd, Vs. Dcit, 2Nd Floor, Rsn Arcade, 6 Circle-20(1), Lsc, Near Peince New Delhi Apartment, Ip Extension, Parparganj, New Delhi (Appellant) (Respondent) Pan:Aaacp6704D

120 Business Profit subject to charge of income-tax (40% of 240 600) 13. Analysing the above two charts, we find that at the end of computation the income chargeable to tas by applying rule 8 comes to Rs. 240. Under Illustration 'A', the normal depreciation is Rs. 100 which is deductible from Rs. 1,000 being the income from

PRASIDH FINCAP LTD,NEW DELHI vs. ITO, WARD-20(1), NEW DELHI

In the result, all the appeals of the assessee are allowed

Bench: Shri M. Balaganesh & Shri Vimal Kumarprasidh Fincap Ltd, Vs. Dcit, 2Nd Floor, Rsn Arcade, 6 Circle-20(1), Lsc, Near Peince New Delhi Apartment, Ip Extension, Parparganj, New Delhi (Appellant) (Respondent) Pan:Aaacp6704D

120 Business Profit subject to charge of income-tax (40% of 240 600) 13. Analysing the above two charts, we find that at the end of computation the income chargeable to tas by applying rule 8 comes to Rs. 240. Under Illustration 'A', the normal depreciation is Rs. 100 which is deductible from Rs. 1,000 being the income from

VEDANTA LTD ,GURGAON vs. ACIT, CIRCLE- 26(2), NEW DELHI

Bench: Shri N.K. Billaiya & Shri Kuldip Singh[Assessment Year: 2014-15]

b)(iii) of the Act and, consequently, the assessee is entitled to the benefit of section 32A(1) of the Act. The question whether the High Court was correct in holding that the activity did not amount to "manufacture" is left open. The civil appeal is, accordingly, dismissed but without any order as to costs.” 56. In light

ACIT, CIRCLE - 10(1), DELHI vs. M/S HYDERABAD RING ROAD PROJECT PRIVATE LIMITED, DELHI

In the result Appeal of the assessee in ITA No

Bench: Ms. Madhumita Roy & Shri Naveen Chandra

4 of 23 ITA No. 4090/DEL/2025 CO No. 81/DEL/2025 Hyderabad Ring Road Project Vs ACIT [A.Y. 2017-18] maintain and transfer the said infrastructure facility in terms of an agreement with the Government of Andhra Pradesh. 9. Moreover, after the end of the specified period, assessee was to transfer the said infrastructure facility to the Government of Andhra Pradesh free

HYDERABAD RING ROAD PROJECT PRIVATE LIMITED,INDIA vs. ACIT, CIRCLE

In the result Appeal of the assessee in ITA No

Bench: Ms. Madhumita Roy & Shri Naveen Chandra

4 of 23 ITA No. 4090/DEL/2025 CO No. 81/DEL/2025 Hyderabad Ring Road Project Vs ACIT [A.Y. 2017-18] maintain and transfer the said infrastructure facility in terms of an agreement with the Government of Andhra Pradesh. 9. Moreover, after the end of the specified period, assessee was to transfer the said infrastructure facility to the Government of Andhra Pradesh free

RAJ SHEELA GROWTH FUND (P) LTD.,NEW DELHI vs. ITO, WARD- 21(1), NEW DELHI

In the result, the appeal of the assessee is partly allowed

Bench: Shri Amit Shukla & Shri L. P. Sahu

120 and Section 124 are not attracted.” The aforesaid clarification by the Hon’ble Jurisdictional High Court clearly clinches the issue that if the case is being transferred from one Assessing Officer having jurisdiction over the assessee to another assessing officer who otherwise was not having the jurisdiction in terms of direction of the Board u/s.120

DCIT, NEW DELHI vs. M/S. CORNELL OVERSEAS (P) LTD., NEW DELHI

In the result, appeal of the department is dismissed

Bench: Sh. N. K. Saini, Am & Smt. Beena Pillai, Jm Ita No. 2166/Del/2011 : Asstt. Year : 2003-04 Dcit, Vs Cornell Overseas (P) Ltd., Circle-3(1), B-235, Okhla Indl. Area, Phase-I, New Delhi New Delhi-110020 (Appellant) (Respondent) Pan No. Aaacc0034F Assessee By : Ms. Vandana Bhandari, Ca Revenue By : Sh. Neeraj Kumar, Sr. Dr Date Of Hearing : 03.02.2017 Date Of Pronouncement : 02.05.2017 Order Per N. K. Saini, Am: This Is An Appeal By The Department Against The Order Dated 28.02.2011 Of Ld. Cit(A)-Xx, New Delhi.

depreciation u/s 32(iia) of the I.T. Act is not available on record. Further, the assessee also failed to file the audit report even before the completion of the assessment. 4. The Ld. CIT(A) has erred on facts and in law in deleting addition of Rs.1,57,35,495/- on account of Arm's Length Price u/s 90CA

M/S. RELIGARE FINVEST LTD.,NEW DELHI vs. ACIT, NEW DELHI

In the result, the appeal filed by the revenue is dismissed

Bench: Sh. I.C. Sudhir & Sh. O.P. Kantassessment Year: 2008-09 Vs. Acit, Circle-15(1), New Delhi Religare Finvest Ltd., D-3, P3B, District Centre, Saket, New Delhi Pan : Aafcs6801H (Appellant) (Respondent) Appellant By Sh. Rohit Garg, Adv. & Ms. Tejasvi Jain, Ca Respondent By Sh. F.R. Meena, Sr.Dr Date Of Hearing 28.03.2017 Date Of Pronouncement 28.04.2017 Order Per O.P. Kant, A.M.: This Appeal By The Assessee Is Directed Against The Order Of Learned Commissioner Of Income Tax (Appeals)-Xviii, New Delhi, Dated 28.02.2013, Raising The Following Grounds Of Appeal:

4. With regard to grounds no. 1 to 2.2, learned counsel for the assessee submitted that the issue involved in these grounds are covered in favour of the assessee in case of sister concerns i.e M/s Religare Commodities Ltd. by the order of ITAT dated 04.01.2017 passed in ITA No. 2283/Del/2013 and 3634/Del/2014 for assessment years

ACIT, MORADABAD vs. M/S JUBLIANT ORGANOSYS LTD., UTTAR PRADESH

The appeal is dismissed

Bench: Smt Beena A. Pillai & Shri Prashant Maharishi

4 of appeal of assessee. 79. Ground number 5 of appeal is on issue of disallowance of INR 516339/- under section 35D of the act. Assessee has claimed deduction under section 35D of act amounting to INR 516339/- for share issue expenses incurred by amalgamating companies. The claim of assessee is that it has been allowed to assessee in previous

JUBILANT ORGANOSYS LTD.,NOIDA vs. ADDL. CIT, MORADABAD

The appeal is dismissed

Bench: Smt Beena A. Pillai & Shri Prashant Maharishi

4 of appeal of assessee. 79. Ground number 5 of appeal is on issue of disallowance of INR 516339/- under section 35D of the act. Assessee has claimed deduction under section 35D of act amounting to INR 516339/- for share issue expenses incurred by amalgamating companies. The claim of assessee is that it has been allowed to assessee in previous

ACIT, MORADABAD vs. M/S. JUBILANT ORGANOSYES LTD., UTTAR PRADESH

The appeal is dismissed

Bench: Smt Beena A. Pillai & Shri Prashant Maharishi

4 of appeal of assessee. 79. Ground number 5 of appeal is on issue of disallowance of INR 516339/- under section 35D of the act. Assessee has claimed deduction under section 35D of act amounting to INR 516339/- for share issue expenses incurred by amalgamating companies. The claim of assessee is that it has been allowed to assessee in previous