DCIT,C-11(1), NEW DELHI vs. HERO MOTOCORP LTD.,, NEW DELHI

Appeal of the Revenue is dismissed

Bench: Shri Narendra Kumar Billaiya & Shri Kul Bharat

section 14A of the Act. 14. Whether, on the facts and circumstances of the case the Ld. CIT(A) has erred in deleting the adjustment of Rs. 38,82,000/- in the value of closing inventory in respect of proportionate amount of depreciation

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

14A read with Rule 8D in computing the profit under section 115 JB of the Act. AO/DRP have also allowed claim of additional depreciation

H.T. MEDIA LIMITED vs. PRINCIPAL COMMISSIONER OF INCOME TAX-IV

Bench: HON'BLE DR. JUSTICE S.MURALIDHAR,HON'BLE MS. JUSTICE PRATHIBA M. SINGH

14A of the Act and Rule 8D of the Rules, of satisfaction being recorded being met, the question of applying Rule 8D (1) did not arise. 39. Turning now to the order of the ITAT, in para 33, it recorded the submission of the AR that the AO did not record any satisfaction about the Assessee not properly offering expenditure

NIIT TECHNOLOGIES LTD.,NEW DELHI vs. ACIT, NEW DELHI

In the result, both the appeals of the assessee are partly allowed and the appeal of Revenue for assessment year 2007-08

Bench: Shri Bhavnesh Saini & Shri O.P. Kant

Depreciation and Amortization Expenses Insofar as depreciation/amortization is concerned, it is respectfully submitted that the same is non-cash expenditure and is basically in the nature of charge on the fixed assets utilized for business purposes, which cannot be subject matter of disallowance under section 14A

ACIT, NEW DELHI vs. M/S NIIT TECHNOLOGIES LTD.,, NEW DELHI

In the result, both the appeals of the assessee are partly allowed and the appeal of Revenue for assessment year 2007-08

Bench: Shri Bhavnesh Saini & Shri O.P. Kant

Depreciation and Amortization Expenses Insofar as depreciation/amortization is concerned, it is respectfully submitted that the same is non-cash expenditure and is basically in the nature of charge on the fixed assets utilized for business purposes, which cannot be subject matter of disallowance under section 14A

ACIT, NEW DELHI vs. M/S NIIT TECHNOLOGIES LTD.,, NEW DELHI

In the result, both the appeals of the assessee are partly allowed and the appeal of Revenue for assessment year 2007-08

Bench: Shri Bhavnesh Saini & Shri O.P. Kant

Depreciation and Amortization Expenses Insofar as depreciation/amortization is concerned, it is respectfully submitted that the same is non-cash expenditure and is basically in the nature of charge on the fixed assets utilized for business purposes, which cannot be subject matter of disallowance under section 14A

NIIT TECHNOLOGIES LTD.,NEW DELHI vs. ACIT, NEW DELHI

In the result, both the appeals of the assessee are partly allowed and the appeal of Revenue for assessment year 2007-08

Bench: Shri Bhavnesh Saini & Shri O.P. Kant

Depreciation and Amortization Expenses Insofar as depreciation/amortization is concerned, it is respectfully submitted that the same is non-cash expenditure and is basically in the nature of charge on the fixed assets utilized for business purposes, which cannot be subject matter of disallowance under section 14A

ACIT, CIRCLE- 21(1), NEW DELHI vs. RELIGARE FINVEST LTD., NEW DELHI

In the result, for assessment year 2007-08 the appeal of the assessee as well as Revenue are dismissed

Bench: Shri O.P. Kant & Shri Kuldip Singh, Judicialmember

Section 14A. In para 36 of the judgment, this Court noticed that with regard to retrospectivity of provisions Revenue had filed appeal, hence the said question was not gone into the aforesaid appeal. In the above case, this Court specifically left the question of retrospectivity to be decided in other appeals filed by the Revenue. We thus have proceeded

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

In the result, for assessment year 2007-08 the appeal of the assessee as well as Revenue are dismissed

Bench: Shri O.P. Kant & Shri Kuldip Singh, Judicialmember

Section 14A. In para 36 of the judgment, this Court noticed that with regard to retrospectivity of provisions Revenue had filed appeal, hence the said question was not gone into the aforesaid appeal. In the above case, this Court specifically left the question of retrospectivity to be decided in other appeals filed by the Revenue. We thus have proceeded

RELIGARE FINVEST LTD,NEW DELHI vs. ADDL.CIY, RANGE-21, NEW DELHI

In the result, for assessment year 2007-08 the appeal of the assessee as well as Revenue are dismissed

Bench: Shri O.P. Kant & Shri Kuldip Singh, Judicialmember

Section 14A. In para 36 of the judgment, this Court noticed that with regard to retrospectivity of provisions Revenue had filed appeal, hence the said question was not gone into the aforesaid appeal. In the above case, this Court specifically left the question of retrospectivity to be decided in other appeals filed by the Revenue. We thus have proceeded

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

In the result, for assessment year 2007-08 the appeal of the assessee as well as Revenue are dismissed

Bench: Shri O.P. Kant & Shri Kuldip Singh, Judicialmember

Section 14A. In para 36 of the judgment, this Court noticed that with regard to retrospectivity of provisions Revenue had filed appeal, hence the said question was not gone into the aforesaid appeal. In the above case, this Court specifically left the question of retrospectivity to be decided in other appeals filed by the Revenue. We thus have proceeded

DCIT, NEW DELHI vs. M/S. PETRONET LNG LTD., NEW DELHI

Appeal of the assessee is allowed

Bench: Sh. Sudhanshu Srivastavadr. B. R. R. Kumar(Through Video Conferencing) Ita No. 5230/Del/2015 : Asstt. Year : 2009-10 Ita No. 5231/Del/2015 : Asstt. Year : 2010-11 Ita No. 5232/Del/2015 : Asstt. Year : 2011-12 Petronet Lng Ltd., Vs Deputy Commissioner Of First Floor, World Trade Centre, Income Tax, Circle-19(2), Babar Road, Barakhamba Lane, New Delhi New Delhi-110001 (Appellant) (Respondent) Pan No. Aaacp8148D Ita No. 4902/Del/2015 : Asstt. Year : 2009-10 Ita No. 4903/Del/2015 : Asstt. Year : 2010-11 Ita No. 4904/Del/2015 : Asstt. Year : 2011-12 Deputy Commissioner Of Vs Petronet Lng Ltd., Income Tax, Circle-19(2), First Floor, World Trade Centre, New Delhi Babar Road, Barakhamba Lane, New Delhi-110001 (Appellant) (Respondent) Pan No. Aaacp8148D Assessee By : Sh. Vishal Kalra, Adv. Revenue By : Sh. H. K. Choudhary, Cit Dr Date Of Hearing: 27.01.2021 Date Of Pronouncement: 18.03.2021

section 801A of the Income tax Act, 1961. 2. On the facts and in the circumstances of the case, the Id CIT(A) has erred in law in deleting the disallowance of Rs. 469.01 lakhs under Rule 8D(2)(ii) by ignoring the mandatory provisions of Rule 8D w.r.s. 14A of the Income

DCIT, NEW DELHI vs. M/S. PETRONET LNG LTD., NEW DELHI

Appeal of the assessee is allowed

Bench: Sh. Sudhanshu Srivastavadr. B. R. R. Kumar(Through Video Conferencing) Ita No. 5230/Del/2015 : Asstt. Year : 2009-10 Ita No. 5231/Del/2015 : Asstt. Year : 2010-11 Ita No. 5232/Del/2015 : Asstt. Year : 2011-12 Petronet Lng Ltd., Vs Deputy Commissioner Of First Floor, World Trade Centre, Income Tax, Circle-19(2), Babar Road, Barakhamba Lane, New Delhi New Delhi-110001 (Appellant) (Respondent) Pan No. Aaacp8148D Ita No. 4902/Del/2015 : Asstt. Year : 2009-10 Ita No. 4903/Del/2015 : Asstt. Year : 2010-11 Ita No. 4904/Del/2015 : Asstt. Year : 2011-12 Deputy Commissioner Of Vs Petronet Lng Ltd., Income Tax, Circle-19(2), First Floor, World Trade Centre, New Delhi Babar Road, Barakhamba Lane, New Delhi-110001 (Appellant) (Respondent) Pan No. Aaacp8148D Assessee By : Sh. Vishal Kalra, Adv. Revenue By : Sh. H. K. Choudhary, Cit Dr Date Of Hearing: 27.01.2021 Date Of Pronouncement: 18.03.2021

section 801A of the Income tax Act, 1961. 2. On the facts and in the circumstances of the case, the Id CIT(A) has erred in law in deleting the disallowance of Rs. 469.01 lakhs under Rule 8D(2)(ii) by ignoring the mandatory provisions of Rule 8D w.r.s. 14A of the Income

PETRONET LNG LTD.,NEW DELHI vs. ADDL. CIT, NEW DELHI

Appeal of the assessee is allowed

Bench: Sh. Sudhanshu Srivastavadr. B. R. R. Kumar(Through Video Conferencing) Ita No. 5230/Del/2015 : Asstt. Year : 2009-10 Ita No. 5231/Del/2015 : Asstt. Year : 2010-11 Ita No. 5232/Del/2015 : Asstt. Year : 2011-12 Petronet Lng Ltd., Vs Deputy Commissioner Of First Floor, World Trade Centre, Income Tax, Circle-19(2), Babar Road, Barakhamba Lane, New Delhi New Delhi-110001 (Appellant) (Respondent) Pan No. Aaacp8148D Ita No. 4902/Del/2015 : Asstt. Year : 2009-10 Ita No. 4903/Del/2015 : Asstt. Year : 2010-11 Ita No. 4904/Del/2015 : Asstt. Year : 2011-12 Deputy Commissioner Of Vs Petronet Lng Ltd., Income Tax, Circle-19(2), First Floor, World Trade Centre, New Delhi Babar Road, Barakhamba Lane, New Delhi-110001 (Appellant) (Respondent) Pan No. Aaacp8148D Assessee By : Sh. Vishal Kalra, Adv. Revenue By : Sh. H. K. Choudhary, Cit Dr Date Of Hearing: 27.01.2021 Date Of Pronouncement: 18.03.2021

section 801A of the Income tax Act, 1961. 2. On the facts and in the circumstances of the case, the Id CIT(A) has erred in law in deleting the disallowance of Rs. 469.01 lakhs under Rule 8D(2)(ii) by ignoring the mandatory provisions of Rule 8D w.r.s. 14A of the Income

DCIT, NEW DELHI vs. M/S. PETRONET LNG LTD., NEW DELHI

Appeal of the assessee is allowed

Bench: Sh. Sudhanshu Srivastavadr. B. R. R. Kumar(Through Video Conferencing) Ita No. 5230/Del/2015 : Asstt. Year : 2009-10 Ita No. 5231/Del/2015 : Asstt. Year : 2010-11 Ita No. 5232/Del/2015 : Asstt. Year : 2011-12 Petronet Lng Ltd., Vs Deputy Commissioner Of First Floor, World Trade Centre, Income Tax, Circle-19(2), Babar Road, Barakhamba Lane, New Delhi New Delhi-110001 (Appellant) (Respondent) Pan No. Aaacp8148D Ita No. 4902/Del/2015 : Asstt. Year : 2009-10 Ita No. 4903/Del/2015 : Asstt. Year : 2010-11 Ita No. 4904/Del/2015 : Asstt. Year : 2011-12 Deputy Commissioner Of Vs Petronet Lng Ltd., Income Tax, Circle-19(2), First Floor, World Trade Centre, New Delhi Babar Road, Barakhamba Lane, New Delhi-110001 (Appellant) (Respondent) Pan No. Aaacp8148D Assessee By : Sh. Vishal Kalra, Adv. Revenue By : Sh. H. K. Choudhary, Cit Dr Date Of Hearing: 27.01.2021 Date Of Pronouncement: 18.03.2021

section 801A of the Income tax Act, 1961. 2. On the facts and in the circumstances of the case, the Id CIT(A) has erred in law in deleting the disallowance of Rs. 469.01 lakhs under Rule 8D(2)(ii) by ignoring the mandatory provisions of Rule 8D w.r.s. 14A of the Income

PETRONET LNG LTD.,NEW DELHI vs. ADDL. CIT, NEW DELHI

Appeal of the assessee is allowed

Bench: Sh. Sudhanshu Srivastavadr. B. R. R. Kumar(Through Video Conferencing) Ita No. 5230/Del/2015 : Asstt. Year : 2009-10 Ita No. 5231/Del/2015 : Asstt. Year : 2010-11 Ita No. 5232/Del/2015 : Asstt. Year : 2011-12 Petronet Lng Ltd., Vs Deputy Commissioner Of First Floor, World Trade Centre, Income Tax, Circle-19(2), Babar Road, Barakhamba Lane, New Delhi New Delhi-110001 (Appellant) (Respondent) Pan No. Aaacp8148D Ita No. 4902/Del/2015 : Asstt. Year : 2009-10 Ita No. 4903/Del/2015 : Asstt. Year : 2010-11 Ita No. 4904/Del/2015 : Asstt. Year : 2011-12 Deputy Commissioner Of Vs Petronet Lng Ltd., Income Tax, Circle-19(2), First Floor, World Trade Centre, New Delhi Babar Road, Barakhamba Lane, New Delhi-110001 (Appellant) (Respondent) Pan No. Aaacp8148D Assessee By : Sh. Vishal Kalra, Adv. Revenue By : Sh. H. K. Choudhary, Cit Dr Date Of Hearing: 27.01.2021 Date Of Pronouncement: 18.03.2021

section 801A of the Income tax Act, 1961. 2. On the facts and in the circumstances of the case, the Id CIT(A) has erred in law in deleting the disallowance of Rs. 469.01 lakhs under Rule 8D(2)(ii) by ignoring the mandatory provisions of Rule 8D w.r.s. 14A of the Income

PETRONET LNG LTD.,NEW DELHI vs. ADDL. CIT, NEW DELHI

Appeal of the assessee is allowed

Bench: Sh. Sudhanshu Srivastavadr. B. R. R. Kumar(Through Video Conferencing) Ita No. 5230/Del/2015 : Asstt. Year : 2009-10 Ita No. 5231/Del/2015 : Asstt. Year : 2010-11 Ita No. 5232/Del/2015 : Asstt. Year : 2011-12 Petronet Lng Ltd., Vs Deputy Commissioner Of First Floor, World Trade Centre, Income Tax, Circle-19(2), Babar Road, Barakhamba Lane, New Delhi New Delhi-110001 (Appellant) (Respondent) Pan No. Aaacp8148D Ita No. 4902/Del/2015 : Asstt. Year : 2009-10 Ita No. 4903/Del/2015 : Asstt. Year : 2010-11 Ita No. 4904/Del/2015 : Asstt. Year : 2011-12 Deputy Commissioner Of Vs Petronet Lng Ltd., Income Tax, Circle-19(2), First Floor, World Trade Centre, New Delhi Babar Road, Barakhamba Lane, New Delhi-110001 (Appellant) (Respondent) Pan No. Aaacp8148D Assessee By : Sh. Vishal Kalra, Adv. Revenue By : Sh. H. K. Choudhary, Cit Dr Date Of Hearing: 27.01.2021 Date Of Pronouncement: 18.03.2021

section 801A of the Income tax Act, 1961. 2. On the facts and in the circumstances of the case, the Id CIT(A) has erred in law in deleting the disallowance of Rs. 469.01 lakhs under Rule 8D(2)(ii) by ignoring the mandatory provisions of Rule 8D w.r.s. 14A of the Income

TECHNOLOGIES LTD) vs. ACIT

Appeals are allowed

14A of the Act and Rule 8D of the Rules, of satisfaction being recorded being met, the question of applying Rule 8D (1) did not arise. 39. Turning now to the order of the ITAT, in para 33, it recorded the submission of the AR that the AO did not record any satisfaction about the Assessee not properly offering expenditure