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380 results for “depreciation”+ Section 255(7)clear

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Key Topics

Section 143(3)60Section 80I55Addition to Income47Section 14743Depreciation40Section 115J39Disallowance38Section 26334Deduction34Section 14A

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

In the result, the appeal of the Revenue is dismissed and cross objection of the assessee is allowed for statistical purposes

ITA 3076/DEL/2012[2006-07]Status: DisposedITAT Delhi27 Feb 2019AY 2006-07

Bench: : Shri Amit Shukla & Shri L.P. Sahuassessment Year: 2006-07

Section 10BSection 29Section 32Section 32(2)Section 43A

255, the assessee had 100% Export Oriented Undertaking eligible for deduction under section 10B of the Act. The undertaking was set up in the assessment year 1988-89. The assessee, however, claimed deduction for five consecutive years from assessment year 1992-93. The year under consideration before the Hon Court was assessment year 1994-95. The assessee had unabsorbed depreciation

PMV MALTINGS PVT LTD,NEW DELHI vs. ACIT CIRCLE-19(2), NEW DELHI

Showing 1–20 of 380 · Page 1 of 19

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23
Section 14823
Transfer Pricing22

In the result the appeal of the assessee for ITA No

ITA 6906/DEL/2019[2016-17]Status: DisposedITAT Delhi26 Sept 2025AY 2016-17

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla

Section 143(3)Section 32

7. Before us, learned counsel appearing in support of the appeal contended that it would be the provisions ofsection 49 of the Act which would apply and that both the CIT (Appeals) as well as the ITAT have clearlyerred in holding otherwise. Learned counsel referred to the definition of "cost of acquisition" as spelt out insection

PMV MALTINGS PVT LTD,NEW DELHI vs. ACIT CIRCLE-19(2), NEW DELHI

In the result the appeal of the assessee for ITA No

ITA 3103/DEL/2019[2015-16]Status: DisposedITAT Delhi26 Sept 2025AY 2015-16

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla

Section 143(3)Section 32

7. Before us, learned counsel appearing in support of the appeal contended that it would be the provisions ofsection 49 of the Act which would apply and that both the CIT (Appeals) as well as the ITAT have clearlyerred in holding otherwise. Learned counsel referred to the definition of "cost of acquisition" as spelt out insection

EXL SERVICE.COM (INDIA) PVT. LTD.,NEW DELHI vs. DCIT (LTU), NEW DELHI

In the result, the appeal by the assessee as well as ofthe department are partly allowed for statistical purposes

ITA 302/DEL/2015[2010-11]Status: DisposedITAT Delhi03 Jan 2017AY 2010-11

Bench: Sh. N. K. Saini, Am & Sh. Kuldip Singh, Jm Ita No. 302/Del/2015 : Asstt. Year : 2010-11 Exl Service.Com (India) Pvt. Ltd., Vs Deputy Commissioner Of Income 414, 4Th Floor, Dlf Jasola, Tax, Large Tax Payer Unit, Tower-B, Plot No. 10 & 11, Dda New Delhi District Centre, Jasola, New Delhi-110044 (Appellant) (Respondent) Ita No. 615/Del/2015 : Asstt. Year : 2010-11 Deputy Commissioner Of Income Vs Exl Service.Com (India) Pvt. Ltd., 414, 4Th Floor, Dlf Jasola, Tower- Tax, Circle-1 (Ltu), New Delhi-110017 B, Plot No. 10 & 11, Dda District Centre, Jasola, New Delhi-110044 (Appellant) (Respondent) Pan No. Aaace5174C Assessee By : Sh. Ajay Vohra, Adv. Sh. Abhishek Agarwal, Adv. Revenue By : Sh. Piyush Jain, Cit Dr Date Of Hearing : 07.10.2017 Date Of Pronouncement : 03.01.2017 Order Per N. K. Saini, Am:

For Appellant: Sh. Ajay Vohra, AdvFor Respondent: Sh. Piyush Jain, CIT DR
Section 143(3)Section 92D

7. Question No. 6 concerns deletion of addition of Rs.89,00,000/- made by the AO for computation of the income for the purposes of Minimum Alternate Tax (‘MAT’) under Section 115JB of the Act. This pertained to the expenditure incurred for earning exempt income under Section 14A read with Rule 8D. The ITAT has rightly held that this being

DCIT (LTU), NEW DELHI vs. M/S. EXL SERVICE.COM (INDIA) PVT. LTD., NEW DELHI

In the result, the appeal by the assessee as well as ofthe department are partly allowed for statistical purposes

ITA 615/DEL/2015[2010-11]Status: DisposedITAT Delhi03 Jan 2017AY 2010-11

Bench: Sh. N. K. Saini, Am & Sh. Kuldip Singh, Jm Ita No. 302/Del/2015 : Asstt. Year : 2010-11 Exl Service.Com (India) Pvt. Ltd., Vs Deputy Commissioner Of Income 414, 4Th Floor, Dlf Jasola, Tax, Large Tax Payer Unit, Tower-B, Plot No. 10 & 11, Dda New Delhi District Centre, Jasola, New Delhi-110044 (Appellant) (Respondent) Ita No. 615/Del/2015 : Asstt. Year : 2010-11 Deputy Commissioner Of Income Vs Exl Service.Com (India) Pvt. Ltd., 414, 4Th Floor, Dlf Jasola, Tower- Tax, Circle-1 (Ltu), New Delhi-110017 B, Plot No. 10 & 11, Dda District Centre, Jasola, New Delhi-110044 (Appellant) (Respondent) Pan No. Aaace5174C Assessee By : Sh. Ajay Vohra, Adv. Sh. Abhishek Agarwal, Adv. Revenue By : Sh. Piyush Jain, Cit Dr Date Of Hearing : 07.10.2017 Date Of Pronouncement : 03.01.2017 Order Per N. K. Saini, Am:

For Appellant: Sh. Ajay Vohra, AdvFor Respondent: Sh. Piyush Jain, CIT DR
Section 143(3)Section 92D

7. Question No. 6 concerns deletion of addition of Rs.89,00,000/- made by the AO for computation of the income for the purposes of Minimum Alternate Tax (‘MAT’) under Section 115JB of the Act. This pertained to the expenditure incurred for earning exempt income under Section 14A read with Rule 8D. The ITAT has rightly held that this being

ACIT, NEW DELHI vs. M/S. JAY BHARAT MARUTI LTD., NEW DELHI

In the result, the appeal is allowed

ITA 908/DEL/2012[2005-06]Status: DisposedITAT Delhi29 Nov 2022AY 2005-06

Bench: Shri G.S. Pannu, Hon’Ble & Shri Saktijit Deyassessment Year: 2005-06 & Assessment Year: 2006-07 Acit, Vs. M/S. Jay Bharat Maruti Ltd., Circle-4(1), 601, Hemkunt Chamber, New Delhi 89-Nehru Place, New Delhi Pan :Aaacj2021K (Appellant) (Respondent) & C.O. No.113/Del/2012 [Arising Out Of Ita No.908/Del/2012] Assessment Year: 2005-06 & C.O. No.114/Del/2012 [Arising Out Of Ita No.909/Del/2012] Assessment Year: 2006-07 M/S. Jay Bharat Maruti Ltd., Vs. Acit, 601, Hemkunt Chamber, Circle-4(1), 89-Nehru Place, New Delhi New Delhi Pan :Aaacj2021K (Appellant) (Respondent) & Assessment Year: 2005-06 M/S. Jay Bharat Maruti Ltd., Vs. Acit, Neel House, Lado Sarai, Circle-4(1), Opp. Qutab Minar, Mehrauli, New Delhi New Delhi Pan :Aaacj2021K (Appellant) (Respondent)

Section 143(3)Section 147

7)(b) and section 94(8) were introduced to the Statute by Finance Act, 2004, w.e.f. 01.04.2005. Therefore, assessee’s claim that being unaware of the change in the statutory provision, which for the first time became applicable to the impugned assessment year, the assessee acted bona fide by claiming short term capital loss, in our view, is believable

M/S. JAY BHARAT MARUTI LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result, the appeal is allowed

ITA 4672/DEL/2011[2005-06]Status: DisposedITAT Delhi29 Nov 2022AY 2005-06

Bench: Shri G.S. Pannu, Hon’Ble & Shri Saktijit Deyassessment Year: 2005-06 & Assessment Year: 2006-07 Acit, Vs. M/S. Jay Bharat Maruti Ltd., Circle-4(1), 601, Hemkunt Chamber, New Delhi 89-Nehru Place, New Delhi Pan :Aaacj2021K (Appellant) (Respondent) & C.O. No.113/Del/2012 [Arising Out Of Ita No.908/Del/2012] Assessment Year: 2005-06 & C.O. No.114/Del/2012 [Arising Out Of Ita No.909/Del/2012] Assessment Year: 2006-07 M/S. Jay Bharat Maruti Ltd., Vs. Acit, 601, Hemkunt Chamber, Circle-4(1), 89-Nehru Place, New Delhi New Delhi Pan :Aaacj2021K (Appellant) (Respondent) & Assessment Year: 2005-06 M/S. Jay Bharat Maruti Ltd., Vs. Acit, Neel House, Lado Sarai, Circle-4(1), Opp. Qutab Minar, Mehrauli, New Delhi New Delhi Pan :Aaacj2021K (Appellant) (Respondent)

Section 143(3)Section 147

7)(b) and section 94(8) were introduced to the Statute by Finance Act, 2004, w.e.f. 01.04.2005. Therefore, assessee’s claim that being unaware of the change in the statutory provision, which for the first time became applicable to the impugned assessment year, the assessee acted bona fide by claiming short term capital loss, in our view, is believable

ACIT, NEW DELHI vs. M/S. JAY BHARAT MARUTI LTD., NEW DELHI

In the result, the appeal is allowed

ITA 909/DEL/2012[2006-07]Status: DisposedITAT Delhi29 Nov 2022AY 2006-07

Bench: Shri G.S. Pannu, Hon’Ble & Shri Saktijit Deyassessment Year: 2005-06 & Assessment Year: 2006-07 Acit, Vs. M/S. Jay Bharat Maruti Ltd., Circle-4(1), 601, Hemkunt Chamber, New Delhi 89-Nehru Place, New Delhi Pan :Aaacj2021K (Appellant) (Respondent) & C.O. No.113/Del/2012 [Arising Out Of Ita No.908/Del/2012] Assessment Year: 2005-06 & C.O. No.114/Del/2012 [Arising Out Of Ita No.909/Del/2012] Assessment Year: 2006-07 M/S. Jay Bharat Maruti Ltd., Vs. Acit, 601, Hemkunt Chamber, Circle-4(1), 89-Nehru Place, New Delhi New Delhi Pan :Aaacj2021K (Appellant) (Respondent) & Assessment Year: 2005-06 M/S. Jay Bharat Maruti Ltd., Vs. Acit, Neel House, Lado Sarai, Circle-4(1), Opp. Qutab Minar, Mehrauli, New Delhi New Delhi Pan :Aaacj2021K (Appellant) (Respondent)

Section 143(3)Section 147

7)(b) and section 94(8) were introduced to the Statute by Finance Act, 2004, w.e.f. 01.04.2005. Therefore, assessee’s claim that being unaware of the change in the statutory provision, which for the first time became applicable to the impugned assessment year, the assessee acted bona fide by claiming short term capital loss, in our view, is believable

M/S. JAY BHARAT MARUTI LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result, the appeal is allowed

ITA 2180/DEL/2017[2012-13]Status: DisposedITAT Delhi29 Nov 2022AY 2012-13

Bench: Shri G.S. Pannu, Hon’Ble & Shri Saktijit Deyassessment Year: 2005-06 & Assessment Year: 2006-07 Acit, Vs. M/S. Jay Bharat Maruti Ltd., Circle-4(1), 601, Hemkunt Chamber, New Delhi 89-Nehru Place, New Delhi Pan :Aaacj2021K (Appellant) (Respondent) & C.O. No.113/Del/2012 [Arising Out Of Ita No.908/Del/2012] Assessment Year: 2005-06 & C.O. No.114/Del/2012 [Arising Out Of Ita No.909/Del/2012] Assessment Year: 2006-07 M/S. Jay Bharat Maruti Ltd., Vs. Acit, 601, Hemkunt Chamber, Circle-4(1), 89-Nehru Place, New Delhi New Delhi Pan :Aaacj2021K (Appellant) (Respondent) & Assessment Year: 2005-06 M/S. Jay Bharat Maruti Ltd., Vs. Acit, Neel House, Lado Sarai, Circle-4(1), Opp. Qutab Minar, Mehrauli, New Delhi New Delhi Pan :Aaacj2021K (Appellant) (Respondent)

Section 143(3)Section 147

7)(b) and section 94(8) were introduced to the Statute by Finance Act, 2004, w.e.f. 01.04.2005. Therefore, assessee’s claim that being unaware of the change in the statutory provision, which for the first time became applicable to the impugned assessment year, the assessee acted bona fide by claiming short term capital loss, in our view, is believable

DCIT, NEW DELHI vs. M/S. JAY BHARAT MARUTI LTD., NEW DELHI

In the result, the appeal is allowed

ITA 1885/DEL/2017[2012-13]Status: DisposedITAT Delhi29 Nov 2022AY 2012-13

Bench: Shri G.S. Pannu, Hon’Ble & Shri Saktijit Deyassessment Year: 2005-06 & Assessment Year: 2006-07 Acit, Vs. M/S. Jay Bharat Maruti Ltd., Circle-4(1), 601, Hemkunt Chamber, New Delhi 89-Nehru Place, New Delhi Pan :Aaacj2021K (Appellant) (Respondent) & C.O. No.113/Del/2012 [Arising Out Of Ita No.908/Del/2012] Assessment Year: 2005-06 & C.O. No.114/Del/2012 [Arising Out Of Ita No.909/Del/2012] Assessment Year: 2006-07 M/S. Jay Bharat Maruti Ltd., Vs. Acit, 601, Hemkunt Chamber, Circle-4(1), 89-Nehru Place, New Delhi New Delhi Pan :Aaacj2021K (Appellant) (Respondent) & Assessment Year: 2005-06 M/S. Jay Bharat Maruti Ltd., Vs. Acit, Neel House, Lado Sarai, Circle-4(1), Opp. Qutab Minar, Mehrauli, New Delhi New Delhi Pan :Aaacj2021K (Appellant) (Respondent)

Section 143(3)Section 147

7)(b) and section 94(8) were introduced to the Statute by Finance Act, 2004, w.e.f. 01.04.2005. Therefore, assessee’s claim that being unaware of the change in the statutory provision, which for the first time became applicable to the impugned assessment year, the assessee acted bona fide by claiming short term capital loss, in our view, is believable

CAIRN ENERGY HYDROCARBON LTD. ,GURGAON vs. DCIT, INTL. TAXATION, CIRCLE, GURGAON

In the result, the appeals of the assessee are partly allowed and the appeals of the revenue are dismissed

ITA 6277/DEL/2018[2013-14]Status: DisposedITAT Delhi31 Jan 2023AY 2013-14

Bench: Sh. Saktijit Deydr. B. R. R. Kumarita No. 6357/Del/2013: Asstt. Year : 2010-11 Dcit, Vs Cairn Energy Hydrocarbon Ltd., C/O. Cairn India Ltd., 3Rd & 4Th Circle-3(2), International Taxation, Floor, Vipul Plaza, Suncity, Sector- New Delhi 54, Gurgaon (Appellant) (Respondent) Pan No. Aaccc3279J

For Appellant: Sh. Ajay Vohra, Sr. AdvFor Respondent: Sh. Gangadhar Panda, CIT-DR
Section 40aSection 57Section 80I

depreciation’. 7. The revenue has raised the following grounds in ITA No. 5989/Del/2018 for Assessment Year 2014-15:- “1. Whether, on the facts and in the circumstances of the case, the Ld. CIT(A) has erred in allowing the exploration and development expenditure of Rs. 8,79,43,82,537/- which had been disallowed by the AO on the ground

DDIT, NEW DELHI vs. M/S. CAIRN ENERGY HYDROCARBONS LTD., GURGAON

In the result, the appeals of the assessee are partly allowed and the appeals of the revenue are dismissed

ITA 6357/DEL/2013[2010-11]Status: DisposedITAT Delhi31 Jan 2023AY 2010-11

Bench: Sh. Saktijit Deydr. B. R. R. Kumarita No. 6357/Del/2013: Asstt. Year : 2010-11 Dcit, Vs Cairn Energy Hydrocarbon Ltd., C/O. Cairn India Ltd., 3Rd & 4Th Circle-3(2), International Taxation, Floor, Vipul Plaza, Suncity, Sector- New Delhi 54, Gurgaon (Appellant) (Respondent) Pan No. Aaccc3279J

For Appellant: Sh. Ajay Vohra, Sr. AdvFor Respondent: Sh. Gangadhar Panda, CIT-DR
Section 40aSection 57Section 80I

depreciation’. 7. The revenue has raised the following grounds in ITA No. 5989/Del/2018 for Assessment Year 2014-15:- “1. Whether, on the facts and in the circumstances of the case, the Ld. CIT(A) has erred in allowing the exploration and development expenditure of Rs. 8,79,43,82,537/- which had been disallowed by the AO on the ground

DCIT, INTL. TAXATION, CIRCLE, GURGAON vs. CAIRN ENERGY HYDROCARBON LTD. , GURGAON

In the result, the appeals of the assessee are partly allowed and the appeals of the revenue are dismissed

ITA 5988/DEL/2018[2013-14]Status: DisposedITAT Delhi31 Jan 2023AY 2013-14

Bench: Sh. Saktijit Deydr. B. R. R. Kumarita No. 6357/Del/2013: Asstt. Year : 2010-11 Dcit, Vs Cairn Energy Hydrocarbon Ltd., C/O. Cairn India Ltd., 3Rd & 4Th Circle-3(2), International Taxation, Floor, Vipul Plaza, Suncity, Sector- New Delhi 54, Gurgaon (Appellant) (Respondent) Pan No. Aaccc3279J

For Appellant: Sh. Ajay Vohra, Sr. AdvFor Respondent: Sh. Gangadhar Panda, CIT-DR
Section 40aSection 57Section 80I

depreciation’. 7. The revenue has raised the following grounds in ITA No. 5989/Del/2018 for Assessment Year 2014-15:- “1. Whether, on the facts and in the circumstances of the case, the Ld. CIT(A) has erred in allowing the exploration and development expenditure of Rs. 8,79,43,82,537/- which had been disallowed by the AO on the ground

CAIRN ENERGY HYDROCARBON LTD. ,GURGAON vs. DCIT, INTL. TAXATION, CIRCLE, GURGAON

In the result, the appeals of the assessee are partly allowed and the appeals of the revenue are dismissed

ITA 6278/DEL/2018[2014-15]Status: DisposedITAT Delhi31 Jan 2023AY 2014-15

Bench: Sh. Saktijit Deydr. B. R. R. Kumarita No. 6357/Del/2013: Asstt. Year : 2010-11 Dcit, Vs Cairn Energy Hydrocarbon Ltd., C/O. Cairn India Ltd., 3Rd & 4Th Circle-3(2), International Taxation, Floor, Vipul Plaza, Suncity, Sector- New Delhi 54, Gurgaon (Appellant) (Respondent) Pan No. Aaccc3279J

For Appellant: Sh. Ajay Vohra, Sr. AdvFor Respondent: Sh. Gangadhar Panda, CIT-DR
Section 40aSection 57Section 80I

depreciation’. 7. The revenue has raised the following grounds in ITA No. 5989/Del/2018 for Assessment Year 2014-15:- “1. Whether, on the facts and in the circumstances of the case, the Ld. CIT(A) has erred in allowing the exploration and development expenditure of Rs. 8,79,43,82,537/- which had been disallowed by the AO on the ground

DCIT, INTL. TAXATION, CIRCLE, GURGAON vs. CAIRN ENERGY HYDROCARBON LTD. , GURGAON

In the result, the appeals of the assessee are partly allowed and the appeals of the revenue are dismissed

ITA 5989/DEL/2018[2014-15]Status: DisposedITAT Delhi31 Jan 2023AY 2014-15

Bench: Sh. Saktijit Deydr. B. R. R. Kumarita No. 6357/Del/2013: Asstt. Year : 2010-11 Dcit, Vs Cairn Energy Hydrocarbon Ltd., C/O. Cairn India Ltd., 3Rd & 4Th Circle-3(2), International Taxation, Floor, Vipul Plaza, Suncity, Sector- New Delhi 54, Gurgaon (Appellant) (Respondent) Pan No. Aaccc3279J

For Appellant: Sh. Ajay Vohra, Sr. AdvFor Respondent: Sh. Gangadhar Panda, CIT-DR
Section 40aSection 57Section 80I

depreciation’. 7. The revenue has raised the following grounds in ITA No. 5989/Del/2018 for Assessment Year 2014-15:- “1. Whether, on the facts and in the circumstances of the case, the Ld. CIT(A) has erred in allowing the exploration and development expenditure of Rs. 8,79,43,82,537/- which had been disallowed by the AO on the ground

CAIRN ENERGY HYDROCARBONS LTD.,GURGAON vs. DDIT, NEW DELHI

In the result, the appeals of the assessee are partly allowed and the appeals of the revenue are dismissed

ITA 6346/DEL/2013[2010-11]Status: DisposedITAT Delhi31 Jan 2023AY 2010-11

Bench: Sh. Saktijit Deydr. B. R. R. Kumarita No. 6357/Del/2013: Asstt. Year : 2010-11 Dcit, Vs Cairn Energy Hydrocarbon Ltd., C/O. Cairn India Ltd., 3Rd & 4Th Circle-3(2), International Taxation, Floor, Vipul Plaza, Suncity, Sector- New Delhi 54, Gurgaon (Appellant) (Respondent) Pan No. Aaccc3279J

For Appellant: Sh. Ajay Vohra, Sr. AdvFor Respondent: Sh. Gangadhar Panda, CIT-DR
Section 40aSection 57Section 80I

depreciation’. 7. The revenue has raised the following grounds in ITA No. 5989/Del/2018 for Assessment Year 2014-15:- “1. Whether, on the facts and in the circumstances of the case, the Ld. CIT(A) has erred in allowing the exploration and development expenditure of Rs. 8,79,43,82,537/- which had been disallowed by the AO on the ground

ARIVENT TECHNOLOGIES HOLDINGS LTD.,NEW DELHI vs. DCIT, NEW DELHI

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

ITA 1308/DEL/2015[2010-11]Status: DisposedITAT Delhi29 Nov 2019AY 2010-11

Bench: Ms. Sushma Chowla & Shri Prashant Maharishi

For Appellant: Sh. Ajay Vohra, Sr.Adv. &For Respondent: Sh. Sanjay I.Bara, CIT DR
Section 143(3)Section 144CSection 144C(1)Section 144C(5)Section 92C

255 by allegedly re- characterizing the outstanding receivables from the associated enterprise as in the nature of international transaction of unsecured loans. 4.1 That the assessing officer/TPO erred on facts and in law in not appreciating that delay in receipt of receivable does not constitute an international transaction in terms of section 92B of the Act but is a consequence

M/S. ARICENT TECHNOLOGIES (HOLDINGS) LTD.,NEW DELHI vs. ADDL. CIT, NEW DELHI

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

ITA 1944/DEL/2017[2012-13]Status: DisposedITAT Delhi29 Nov 2019AY 2012-13

Bench: Ms. Sushma Chowla & Shri Prashant Maharishi

For Appellant: Sh. Ajay Vohra, Sr.Adv. &For Respondent: Sh. Sanjay I.Bara, CIT DR
Section 143(3)Section 144CSection 144C(1)Section 144C(5)Section 92C

255 by allegedly re- characterizing the outstanding receivables from the associated enterprise as in the nature of international transaction of unsecured loans. 4.1 That the assessing officer/TPO erred on facts and in law in not appreciating that delay in receipt of receivable does not constitute an international transaction in terms of section 92B of the Act but is a consequence

ARICENT TECHNOLOGIES (HOLDINGS) LTD.,NEW DELHI vs. JCIT, SPECIAL RANGE- 1 , NEW DELHI

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

ITA 7112/DEL/2017[2013-14]Status: DisposedITAT Delhi29 Nov 2019AY 2013-14

Bench: Ms. Sushma Chowla & Shri Prashant Maharishi

For Appellant: Sh. Ajay Vohra, Sr.Adv. &For Respondent: Sh. Sanjay I.Bara, CIT DR
Section 143(3)Section 144CSection 144C(1)Section 144C(5)Section 92C

255 by allegedly re- characterizing the outstanding receivables from the associated enterprise as in the nature of international transaction of unsecured loans. 4.1 That the assessing officer/TPO erred on facts and in law in not appreciating that delay in receipt of receivable does not constitute an international transaction in terms of section 92B of the Act but is a consequence

ARICENT TECHNOLOGIES (HOLDINGS) LTD.,NEW DELHI vs. ADDL. CIT, SPECIAL RANGE- 1 , NEW DELHI

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

ITA 7637/DEL/2018[2014-15]Status: DisposedITAT Delhi29 Nov 2019AY 2014-15

Bench: Ms. Sushma Chowla & Shri Prashant Maharishi

For Appellant: Sh. Ajay Vohra, Sr.Adv. &For Respondent: Sh. Sanjay I.Bara, CIT DR
Section 143(3)Section 144CSection 144C(1)Section 144C(5)Section 92C

255 by allegedly re- characterizing the outstanding receivables from the associated enterprise as in the nature of international transaction of unsecured loans. 4.1 That the assessing officer/TPO erred on facts and in law in not appreciating that delay in receipt of receivable does not constitute an international transaction in terms of section 92B of the Act but is a consequence