DCIT, CC-29, NEW DELHI vs. DHARAMPAL SATYALPAL LTD., NEW DELHI

Bench: Shri G. S. Pannu & Shri Yogesh Kumar U.S.I.T.A. No. 1977/Del/2020 (A.Y 2014-15)

144C(4)/143(3) of the Act dated 31/01/2018. As against the assessment order dated 31/01/2018 the assessee has preferred an Appeal before the CIT(A). The Ld.CIT(A) vide order dated 24/09/2020 partly allowed on the Appeal. 5. Aggrieved by the order dated 24/09/2020 the Department of Revenue has preferred the present Appeal. 6. At the time of hearing

DCIT, CC-29, NEW DELHI vs. DHARAMPAL SATYAPAL LTD., NEW DELHI

Bench: Shri G. S. Pannu & Shri Yogesh Kumar U.S.I.T.A. No. 1976/Del/2020 (A.Y 2013-14)

144C(4)/143(3) of the Act dated 31/1/2018. As against the assessment order dated 31/01/2018 the assessee has preferred an Appeal before the CIT(A). The Ld.CIT(A) vide order dated 24/09/2020 partly allowed the Appeal. 7. Aggrieved by the order dated 24/09/2020 the Department of Revenue has preferred the present Appeal. 8. At the time of hearing

M/S. GLOBERIAN INDIA PVT. LTD.,NEW DELHI vs. DCIT, NEW DELHI

Bench: Shri R.K. Panda & Shri Kuldip Singh

depreciation 1,14,36,265 (As per para 3 above) ii) Addition under transfer pricing 4,12,04,919 adjustment as discussed in para 4.3 above TOTAL TAXABLE INOCME 5,26,41,184 3. Aggrieved with the order passed by the AO, the assessee company come up before the Tribunal by way of filing the present appeal. 4. We have

M/S. DHARAMPAL SATYAPAL LTD.,DELHI vs. ACIT, NEW DELHI

Bench: Shri Amit Shukla & Sh. Prashant Maharishi(Through Video Conferencing) Assessment Year: 2012-13 M/S. Dharampal Satyapal Ltd. Acit, 1711, S. P. Mukherjee Marg, Vs Central Circle – 29, Delhi-110006 New Delhi Pan No. Aaacd0132H (Appellant) (Respondent) Appellant By Sh. R. S. Singhavi, Ca Sh. Satyajeet Goel, Ca Respondent By Sh. Sanjay I. Bara, Cit Dr Date Of Hearing: 28/08/2020 Date Of Pronouncement: 07/10/2020 Order

depreciation and consequential claim of deduction u/s 80IB/80IC is illegal, arbitrary and based on conjectures and surmises. 12(i). That on facts and circumstances of the case, the Ld. Assessing officer was not justified in making the disallowance of claim of statutory deduction u/s 80IB/80IC to the extent of Rs.5,29,68,064/- by applying provisions of section 80IA(8

A.T. KEARNEY LTD.- INDIA BRANCH OFFICE,GURGAON vs. ADIT, NEW DELHI

In the result, the appeal of assessee is allowed

Bench: Shri N.K. Billaiya & Shri Kuldip Singhआ.अ.सं/.I.T.A No.4405/Del/2011 िनधा"रणवष"/Assessment Year:2003-04 बनाम A.T. Kearney Ltd., Adit India Branch Office, Vs. Circle 1(1) 14Th Floor, Tower D, International Taxation, Global Business Park, New Delhi. Gurgaon.

depreciation had been allowed by the Ld. Assessing Officer by way of rectification of original assessment order dated March 23, 2006. 6. That on the facts and circumstances of the case and in law, the Ld. Assessing Officer/Hon’ble DRP has erred in levying interest under section 234B of the Act. 7. That on the facts and circumstances

GEODIS OVERSEAS PVT. LTD.,GURGAON vs. DCIT, NEW DELHI

The appeal of the assessee is allowed

Bench: Shri N. K. Billaiya & Ms Suchitra Kamble

144C (5) of the Act vide order dated 18/10/2016. After following the directions issued by the DRP, the Transfer Pricing Officer has given an order giving effect vide order dated 8/11/2016 thereby making revised total adjustment to that of 5 Rs.9,09,36,248/-. The assessment order was passed on 24/11/2016 thereby making an additions as per the directions given

VEDANTA LTD (SUCCESSOR TO CAIRN INDIA LTD),GURGAON vs. ACIT, CIRCLE-26(1), NEW DELHI

Bench: Hon’Ble, Shri N.K. Saini & Shri Kuldip Singh

144C of the 2 Income-tax Act, 1961 (for short ‘the Act’) qua the assessment year 2013-14 on the grounds inter alia that :- “1. That on the facts and circumstances of the case & in law, the Ld. Assessing Officer (AO) erred in assessing the total income and adjusted book profit of the Appellant at Rs.906

ADOBE SYSTEMS INDIA P.LTD,NOIDA vs. DCIT, NOIDA

In the result, the appeal of the assessee is allowed

depreciation in relation to lease rent. D. Reversal of provision for Rent Equalisation amounting to INR 46,87,009 2.9 On the facts and in the circumstances of the case and in law, the learned AO and DRP have erred in not appreciating that out of the disallowance of INR 19, II ,08,847, an amount

K.R.PULP AND PAPERS LTD.,DELHI vs. ACIT, CENTRAL CIRCLE-19, DELHI

In the result, appeal of the assessee is partly allowed

144C of the Act.\n2. That the learned AO/TPO/DRP has erred both in law and on facts in\ndisallowing the claim of deduction of Rs.16,40,46,786/- u/s\n80IA(4)(iv) of the Act by holding that an adjustment of Rs.\n84,32,16,460/- is warranted in respect of transfer of power and steam\nfrom eligible units

MOBASE INDIA PVT. LTD. ,UTTAR PRADESH vs. ACIT , DELHI

In the result, the appeal of the assessee is allowed

Bench: Shri Saktijit Deydr. B. R. R. Kumara.Y. : 2016-17 Mobase India Pvt. Ltd., Vs The Acit, 1C, Front Part Of Front Building, National E-Assessment Centre, Udyog Vihar, Ecotech-Ii, Greater New Delhi. Noida 201306, Up (Appellant) (Respondent) Pan No. Aaecd 8832 G Assessee By : Sh. Rajesh Dua, Ca Revenue By : Sh. Rajesh Kumar, Cit(Dr) Date Of Hearing: 06.12.2023 Date Of Pronouncement: 27.02.2024

depreciable assets, the sale proceeds of the assets is required to be reduced from the WDV of the assets as per the provisions of section 43(6) 3 Mobase India P Ltd., of the Act, which the assessee has duly done following the provisions of section 43(6). D- Other Grounds 8. Levy of Interest U/s 234B, 234C and 234D

JINDAL STEEL & POWER LTD.,NEW DELHI vs. ACIT, HISAR

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

Bench: Sh. Bhavnesh Saini & Sh. N. S. Sainiita No. 893/Del/2014 : Asstt. Year : 2009-10 Jindal Steel & Power Ltd., Vs Asstt. Commissioner Of Jindal Centre, 12, Bhikaji Cama Income Tax, Hisar Circle, Place, New Delhi-110066 Hisar (Appellant) (Respondent) Pan No. Aaacj7079D Assessee By : Sh. Salil Kapoor, Adv., Sh. Sumit Lal Chandani, Adv., Ms. Ananya Kapoor, Adv. & Ms. Pallavi Saigal, Adv. Revenue By : Sh. Sanjay I. Bara, Cit Dr Date Of Hearing :05.03.2019 Date Of Pronouncement : 29.04.2019 Order Per N. S. Saini: This Is An Appeal Filed By The Assessee Against The Order Of Assessing Officer U/S 143(3)/144C(13) Of The Income Tax Act, 1961 Dated 29.10.2018 For Assessment Years 2013-14

144C of the Income-tax Act, 1961 (‘the Act’), is illegal and bad in law. 1.1 That the assessing officer erred on facts and in law in completing the impugned assessment at an income of Rs. 1322,13,35,445 against income of Rs. 2 Jindal Steel & Power Ltd. 1006,66,79,810 declared by the appellant in the return

K R PULP AND PAPERS LTD. ,DELHI vs. DCIT CENTRAL CIRCLE-19 , DELHI

In the result, appeal of the assessee is partly allowed

144C of the Act.\n2.\nThat the learned AO/TPO/DRP has erred both in law and on facts in\ndisallowing the claim of deduction of Rs.16,40,46,786/- u/s\n801A(4)(iv) of the Act by holding that an adjustment of Rs.\n84,32,16,460/- is warranted in respect of transfer of power and steam\nfrom eligible units

HERO MOTO CORP LTD.,NEW DELHI vs. NEAC, DELHI

Bench: Shri Kul Bharat & Shri Prashant Maharishi(Through Video Conferencing)

144C of the Income-tax Act, 1961 ('the Act'), vide order dated 30.04.2021, at an income of Rs. 31,66,82,06,82 1-/- under the normal provisions and at book profit of Rs. 43,79,43,08,839 under section 1l5JB of the Act. Re: Transfer Pricing Adjustment under section 92CA relating to inter unit transfer 2. That

DCM SHRIRAM INDUSTRIS LTD,NEW DELHI vs. DCIT CIRCLE-7(1), NEW DELHI

In the result, the appeal filed by the assessee is allowed in above terms

Bench: Shri Challa Nagemdra Prasad & Shri S. Rifaur Rahman

depreciation. Regard must also be had to the fact that Section 10B(1) is essentially concerned with the grant of exemptions to newly established hundred per cent export-oriented undertakings and the deduction of profits and gains derived by such an enterprise. Sub-section (8) thereof enables an assessee to opt out of the exemption provisions contained therein subject

HEWITT ASSOCIATES (INDIA) PVT. LTD.,GURGAON vs. ACIT, NEW DELHI

In the result, the appeal of the assesee is treated as allowed for statistical purposes

Bench: Shri R.K. Panda & Ms. Astha Chandraasstt. Year : 2007-08

144C of the Act, we request your goodself to allow us the benefit of working capital adjustment. Based on the above submission, we request your goodself to rectify the above- mentioned defects by passing a suitable order under section 154 of the Act and accordingly issue the revised assessment order. ------------------------------ Unquote 2. In addition to the above-mentioned prima facie

UCWEB MOBILE PRIVATE LIMITED,GURGAON vs. ASSESSMENT UNIT, INOCOME TAX DEPARTMENT, GURGAON

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

Bench: SHRI MAHAVIR SINGH (Vice President), SHRI MANISH AGARWAL (Accountant Member)

section 144C (8). 2.1. Without prejudice to the above, The Ld. TPO in the order giving effect to the DRP Directions erred in applying the service income filter for deciding the comparability of the companies considered by the Appellant in its TP documentation. Transfer Pricing Grounds 3. Attribution of AMP Expenses ("Advertisement, Marketing, and Promotion expenses") towards creation of marketing

NALWA STEEL POWER LIMITED,NEW DELHI vs. ACIT, CIRCLE- 17(2), NEW DELHI

Appeal of the assessee is partly allowed for statistical purpose

Bench: Shri N. K. Billaiya & Ms Suchitra Kamble

144C(5) of the Act, is a vitiated order having been passed in violation of principle of natural justice and is otherwise arbitrary and thus bad in law and 2 void ab-initio. 2. That the Hon'ble DRP-2 direction are bad in law to the extent the same are prejudicial to the appellant because: - (a) That

SHIVALIK PRINTS LTD.,NEW DELHI vs. JCIT, SPECIAL RANGE-8, NEW DELHI

In the result, assessees’ appeals in ITA nos

Bench: Shri Kul Bharat & Shri Avdhesh Kumar Mishraassessment Year: 2011-12 & Assessment Year: 2012-13

144C of the Act accepting the returned income. Against the assessment order so passed the assessee preferred appeal before learned CIT(Appeals), wherein vide ground no. 2 the assessee had taken a ground claiming deduction u/s 80 JJAA of the Act. After considering the submissions made by the assessee the learned CIT(Appeals) partly allowed the appeal. Thereby, in respect