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

11: Disallowance of reimbursement of expenses under section 40(a)(ia) Facts: During the year under consideration, the assessee claimed expenses of Rs. 6

INDIAN GOLF UNION,NEW DELHI vs. ITO (E) WARD 2(3), NEW DELHI

The appeal is dismissed ex parte

Bench: Sh. Shamim Yahya & Sh. Anubhav Sharmathe Indian Golf Union Vs. Ito (Exemption) C1/52, 3Rd Floor, Ward 2(3), Hauz Khas Village Road, New Delhi Safdurjang Development Area Pan No. Aaatt3232B (Appellant) (Respondent)

disallowing the exemption on the basis of investment of 1 crore made by assessee in Mahindra and Mahindra Finance despite of the fact that, the Hon’ble CIT(A) duly admitted the assessee as a charitable institution and exemption is allowable under section 11 and 12 in her order. 3. For these grounds and any other ground or grounds that

TECHNOLOGIES LTD) vs. ACIT

Appeals are allowed

6 of 33 income [(refer Rule 8D(2)(i)] 2. Interest expenditure not directly attributable to any particular income [(refer Rule 8D (2)(ii)] 66,48,325 3. ½% of average investments [(refer Rule 8D(2)(iii)] 97,39,000 Total 1,63,87,325 Less: Suo motu disallowance by appellant/assessee 7,79,063 DISALLOWANCE

TECHNOLOGIES LTD) vs. ACIT

Appeals are allowed

6 of 33 income [(refer Rule 8D(2)(i)] 2. Interest expenditure not directly attributable to any particular income [(refer Rule 8D (2)(ii)] 66,48,325 3. ½% of average investments [(refer Rule 8D(2)(iii)] 97,39,000 Total 1,63,87,325 Less: Suo motu disallowance by appellant/assessee 7,79,063 DISALLOWANCE

TECHNOLOGIES LTD) vs. ACIT

Appeals are allowed

6 of 33 income [(refer Rule 8D(2)(i)] 2. Interest expenditure not directly attributable to any particular income [(refer Rule 8D (2)(ii)] 66,48,325 3. ½% of average investments [(refer Rule 8D(2)(iii)] 97,39,000 Total 1,63,87,325 Less: Suo motu disallowance by appellant/assessee 7,79,063 DISALLOWANCE

RICHMOND EDUCATIONAL SOCIETY,NOIDA vs. DCIT/ACIT CENTRAL CIRCLE, GHAZIABAD, GHAZIABAD

In the result, the appeal of the Assessee is allowed

6-7-1984 is reproduced below:-\n“28.6 It may be noted that new sub-section (1A) inserted in section 161 of the\nIncome-tax Act, which provides for taxation of the entire income received by trusts at\nthe maximum marginal rate is applicable only in the case of private trusts having\nprofits and gains of business

BHAGWANT SINGH CHARITABLE TRUST,NEW DELHI vs. ACIT(EXEMPTION), CIRCLE-1(1), NEW DELHI

In the result, the appeal of the assessee is dismissed

Bench: Sh. Saktijit Deydr. B. R. R. Kumar

section 11(4A) is not applicable in the case of the appellant trust.” Disallowing the Expenditure of Rs. 8,48,166/-: 3. The Assessing Officer noted that an expenditure of Rs.8,48,166/- was claimed on account of Round Square conference expenses incurred outside India at Florida. The assessee submitted that the said expenses have been incurred 3 Bhagwant Singh

DIRECTOR OF INCOME TAX (EXEMPTION) vs. CHARANJIV CHARITABLE TRUST

In the result both aspects of the first substantial question of law

Bench: It, Two By The Assessee Relating To The Assessment Years 2006-07 & 2007-08 & One By The Revenue Relating To The Assessment Year 2006-07. In Other Words, In Respect Of The Assessment Year 2006-07, There Were Cross- 2014:Dhc:1467-Db

11 and for the same reasons. He also added an amount of Rs.25 lakhs claimed to have been received by the assessee from M/s. Kuber Swamy Ashutosh Consultancy Pvt. Ltd. and Rs.9,06,000/- from M/s. Sun System Institute of Information Technology as corpus donations, disbelieving the assessee’s version and invoking Section 68 of the Act. He also took

ACIT, NEW DELHI vs. M/S. PTC INDIA FINANCIAL SERVICES LTD., NEW DELHI

In the result, the appeals of the assessee for AY 2013-14 and 2014-15

Bench: Shri N.K. Billaiya & Ms. Astha Chandraasstt. Year 2013-14 & Asstt. Year 2014-15

11,41,153/-; disallowance of notional loss of Rs.18,64,61,000/- booked under the head foreign exchange loss; disallowance of Rs. 59,58,893/- for non-deduction of TDS; disallowance of Rs. 1,13,55,875/- under section 14A and disallowance of Rs. 2,89,99,437/- under section 36(1)(viii) of the Act aggregating

ADDL. CIT, SPECIAL RANGE- 7, NEW DELHI vs. PTC INDIA FINANCIAL SERVICES LTD, NEW DELHI

In the result, the appeals of the assessee for AY 2013-14 and 2014-15

Bench: Shri N.K. Billaiya & Ms. Astha Chandraasstt. Year 2013-14 & Asstt. Year 2014-15

11,41,153/-; disallowance of notional loss of Rs.18,64,61,000/- booked under the head foreign exchange loss; disallowance of Rs. 59,58,893/- for non-deduction of TDS; disallowance of Rs. 1,13,55,875/- under section 14A and disallowance of Rs. 2,89,99,437/- under section 36(1)(viii) of the Act aggregating

PTC INDIA FINANCIAL SERVICES LTD.,NEW DELHI vs. DCIT, CIRCLE- 19(2), NEW DELHI

In the result, the appeals of the assessee for AY 2013-14 and 2014-15

Bench: Shri N.K. Billaiya & Ms. Astha Chandraasstt. Year 2013-14 & Asstt. Year 2014-15

11,41,153/-; disallowance of notional loss of Rs.18,64,61,000/- booked under the head foreign exchange loss; disallowance of Rs. 59,58,893/- for non-deduction of TDS; disallowance of Rs. 1,13,55,875/- under section 14A and disallowance of Rs. 2,89,99,437/- under section 36(1)(viii) of the Act aggregating

M/S. PTC INDIA FINANCIAL SERVICES LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result, the appeals of the assessee for AY 2013-14 and 2014-15

Bench: Shri N.K. Billaiya & Ms. Astha Chandraasstt. Year 2013-14 & Asstt. Year 2014-15

11,41,153/-; disallowance of notional loss of Rs.18,64,61,000/- booked under the head foreign exchange loss; disallowance of Rs. 59,58,893/- for non-deduction of TDS; disallowance of Rs. 1,13,55,875/- under section 14A and disallowance of Rs. 2,89,99,437/- under section 36(1)(viii) of the Act aggregating

DCIT, NEW DELHI vs. M/S. SAHARA INDIA COMMERCIAL CORPORATION LTD., KOLKATA

In the result, appeal of the Revenue is dismissed and CO of the assessee is allowed

Bench: Shri Vikas Awasthy & Shri S Rifaur Rahmanआअसं.1977/धिल्ली/2013(नि.व. 2009-10) Sahara India Commercial Corporation Ltd., Sahara India Sadan, 2A, Shakespeare Sarani, Kolkata 700071 ...... अपीलार्थी/Appellant Pan: Aadcs-6118-F बिाम Vs. Deputy Commissioner Of Income Tax, Central Circle-6, R. No. 334, E-2, Ara, ..... प्रनिवादी/Respondent Centre Jhandewalan Extn. New Delhi आअसं.4728, 2795, 4729, 4730 और 4731/धिल्ली/2017(नि.व. 2010-11 से 2014-15)

6 of Revenue’s appeal are dismissed. Disallowance of Rate of Interest Charged on Circulating Capital in Partnership Firm:- 8. The AO disallowed interest to the extent of Rs.229,22,22,552/- claimed by the assessee on account of no or low interest on capital introduced in partnership firm where the assessee was the partner. The CIT(A) while dealing

SAHARA INDIA,KOLKATA vs. DCIT, NEW DELHI

In the result, appeal of the Revenue is dismissed and CO of the assessee is allowed

Bench: Shri Vikas Awasthy & Shri S Rifaur Rahmanआअसं.1977/धिल्ली/2013(नि.व. 2009-10) Sahara India Commercial Corporation Ltd., Sahara India Sadan, 2A, Shakespeare Sarani, Kolkata 700071 ...... अपीलार्थी/Appellant Pan: Aadcs-6118-F बिाम Vs. Deputy Commissioner Of Income Tax, Central Circle-6, R. No. 334, E-2, Ara, ..... प्रनिवादी/Respondent Centre Jhandewalan Extn. New Delhi आअसं.4728, 2795, 4729, 4730 और 4731/धिल्ली/2017(नि.व. 2010-11 से 2014-15)

6 of Revenue’s appeal are dismissed. Disallowance of Rate of Interest Charged on Circulating Capital in Partnership Firm:- 8. The AO disallowed interest to the extent of Rs.229,22,22,552/- claimed by the assessee on account of no or low interest on capital introduced in partnership firm where the assessee was the partner. The CIT(A) while dealing

SAHARA INDIA COMMERCIAL CORP. LTD.,KOLKATA vs. ACIT, CC- 1, NEW DELHI

In the result, appeal of the Revenue is dismissed and CO of the assessee is allowed

Bench: Shri Vikas Awasthy & Shri S Rifaur Rahmanआअसं.1977/धिल्ली/2013(नि.व. 2009-10) Sahara India Commercial Corporation Ltd., Sahara India Sadan, 2A, Shakespeare Sarani, Kolkata 700071 ...... अपीलार्थी/Appellant Pan: Aadcs-6118-F बिाम Vs. Deputy Commissioner Of Income Tax, Central Circle-6, R. No. 334, E-2, Ara, ..... प्रनिवादी/Respondent Centre Jhandewalan Extn. New Delhi आअसं.4728, 2795, 4729, 4730 और 4731/धिल्ली/2017(नि.व. 2010-11 से 2014-15)

6 of Revenue’s appeal are dismissed. Disallowance of Rate of Interest Charged on Circulating Capital in Partnership Firm:- 8. The AO disallowed interest to the extent of Rs.229,22,22,552/- claimed by the assessee on account of no or low interest on capital introduced in partnership firm where the assessee was the partner. The CIT(A) while dealing

ACIT, CC- 1, NEW DELHI vs. SAHARA INDIA COMMERCIAL CORP. LTD., KOLKATA

In the result, appeal of the Revenue is dismissed and CO of the assessee is allowed

Bench: Shri Vikas Awasthy & Shri S Rifaur Rahmanआअसं.1977/धिल्ली/2013(नि.व. 2009-10) Sahara India Commercial Corporation Ltd., Sahara India Sadan, 2A, Shakespeare Sarani, Kolkata 700071 ...... अपीलार्थी/Appellant Pan: Aadcs-6118-F बिाम Vs. Deputy Commissioner Of Income Tax, Central Circle-6, R. No. 334, E-2, Ara, ..... प्रनिवादी/Respondent Centre Jhandewalan Extn. New Delhi आअसं.4728, 2795, 4729, 4730 और 4731/धिल्ली/2017(नि.व. 2010-11 से 2014-15)

6 of Revenue’s appeal are dismissed. Disallowance of Rate of Interest Charged on Circulating Capital in Partnership Firm:- 8. The AO disallowed interest to the extent of Rs.229,22,22,552/- claimed by the assessee on account of no or low interest on capital introduced in partnership firm where the assessee was the partner. The CIT(A) while dealing

ACIT, CC- 1, NEW DELHI vs. SAHARA INDIA COMMERCIAL CORP. LTD., KOLKATA

In the result, appeal of the Revenue is dismissed and CO of the assessee is allowed

Bench: Shri Vikas Awasthy & Shri S Rifaur Rahmanआअसं.1977/धिल्ली/2013(नि.व. 2009-10) Sahara India Commercial Corporation Ltd., Sahara India Sadan, 2A, Shakespeare Sarani, Kolkata 700071 ...... अपीलार्थी/Appellant Pan: Aadcs-6118-F बिाम Vs. Deputy Commissioner Of Income Tax, Central Circle-6, R. No. 334, E-2, Ara, ..... प्रनिवादी/Respondent Centre Jhandewalan Extn. New Delhi आअसं.4728, 2795, 4729, 4730 और 4731/धिल्ली/2017(नि.व. 2010-11 से 2014-15)

6 of Revenue’s appeal are dismissed. Disallowance of Rate of Interest Charged on Circulating Capital in Partnership Firm:- 8. The AO disallowed interest to the extent of Rs.229,22,22,552/- claimed by the assessee on account of no or low interest on capital introduced in partnership firm where the assessee was the partner. The CIT(A) while dealing

ACIT, CENTRAL CIRCLE-1, NEW DELHI vs. SAHARA INDIA COMMERCIAL CORP. LTD, LUCKNOW

In the result, appeal of the Revenue is dismissed and CO of the assessee is allowed

Bench: Shri Vikas Awasthy & Shri S Rifaur Rahmanआअसं.1977/धिल्ली/2013(नि.व. 2009-10) Sahara India Commercial Corporation Ltd., Sahara India Sadan, 2A, Shakespeare Sarani, Kolkata 700071 ...... अपीलार्थी/Appellant Pan: Aadcs-6118-F बिाम Vs. Deputy Commissioner Of Income Tax, Central Circle-6, R. No. 334, E-2, Ara, ..... प्रनिवादी/Respondent Centre Jhandewalan Extn. New Delhi आअसं.4728, 2795, 4729, 4730 और 4731/धिल्ली/2017(नि.व. 2010-11 से 2014-15)

6 of Revenue’s appeal are dismissed. Disallowance of Rate of Interest Charged on Circulating Capital in Partnership Firm:- 8. The AO disallowed interest to the extent of Rs.229,22,22,552/- claimed by the assessee on account of no or low interest on capital introduced in partnership firm where the assessee was the partner. The CIT(A) while dealing