TECHNOLOGIES LTD) vs. ACIT

Appeals are allowed

disallowance, Rs. 7,79,063/-, being proportionate time-cost of designated employees making investments. This amount, according to the appellant/assessee, was duly verified and certified by its auditors. As against this, the appellant/assessee had earned income by way of dividend which was 2021:DHC:1941-DB ITA 213-215/2020 Page 17 of 33 exempt from tax, via investments

TRIVENI TURBINE LTD,NOIDA vs. ACIT, CIRCLE 5(3)(1), NOIDA

In the result, the appeal of the assessee is dismissed

Bench: Shri Anubhav Sharma & Shri Krinwant Sahay[Assessment Year: 2018-19]

disallowed the deduction claimed by the appellant holding that donations forming part of CSR expenditure is not allowable as deduction under section 80G of the Act. 4. In this regard, it is respectfully submitted that the aforesaid issue is no longer re-integra and it has been held by various Benches of the Hon’ble Tribunal in the following cases

ASSISTANT COMMISSIONER OF INCOME TAX, NEW DELHI vs. JAIPUR GOLDEN TRANSPORT CO PRIVATE LIMITED, NEW DELHI

In the result, appeal of the Revenue is partly allowed

Bench: Shri Anubhav Sharma& Shri Amitabh Shukla[Assessment Year:2012-13] Assistant Commissioner, Of Jaipur Golden Transport Co. Income Tax, Private Limited, Room No.316A, C.R. Vs 4741, Roshananra Road, Building, I.P Estate, Malkaganj, North Delhi, New New Delhi-110002 Delhi-110007 Pan Aaacj4124B Appellant Respondent Revenue By Shri Om Prakash, Sr. Dr Assessee By Shri Y.K. Mehan, Ca, Shri Dheeraj Kumar, Ca Date Of Hearing 11.12.2025 Date Of Pronouncement 19.12.2025

section 133(6) had not been complied with or details furnished were unsatisfactory and incomplete. Even in cases where replies were received, the Assessing Officer observed discrepancies which the assessee could not reconcile. The Assessing Officer concluded that there was scope for manipulation of expenses booked under this head and proceeded to disallow

MR. SURINDER MALHOTRA,NEW DELHI vs. ACIT, NEW DELHI

In the result, appeal of the assessee is allowed

Bench: Dr. Brr Kumar & Ms. Astha Chandraasstt. Year: 2011-12

disallowance of Rs. 44,967/- under section 14A, hence ground no.1 is dismissed as infructuous. 3. During the assessment proceedings, the Ld. AO noticed from the balance sheet sundry creditors of Rs. 45,44,232/- in the name of 16 parties (para 2.1 of the Ld. AO’s order). He required the assessee to furnish the details of the creditors

ACIT, NEW DELHI vs. M/S. DEVINE INFRACON PVT. LTD., NEW DELHI

Bench: M Balaganesh, Accontant Member & Ms Madhumita Royassessment Year: 2010-11 The Assistant Vs. M/S Divine Infracon Commissioner Of Income Private Limited, Plot Tax, Central Circle-09, No. 4, Sector-13, Jhandewalan, New Delhi, Dwarka City Centre, Room No.357, Ara Centre, Dwarka, New Delhi- E-2, Jhandewalan 110075 Extension, New Delhi Pan :Aaccd4476A (Appellant) (Respondent) Assessee By Shri Salil Aggarwal, Sr, Advocate Department By Shri T James Singson, Cit, Dr

133(6) Shalimar Bagh, Delhi-110088 was directly PAN: AAACV4336K submitted with the learned officer by the lender and is part of the record.(page 225 to 226 of paper book) 5.6 It is thus, submitted that once the lenders have duly confirmed the factum of unsecured loan to the appellant company, addition under section

INCOME TAX OFFICER WARD-1 HISAR, HISAR vs. AJAY KUMAR, HISAR

In the result, the appeal filed by the Revenue for AY 2022-23 is dismissed

Section 133(6) of the Income-tax Act, 1961. It is\nrespectfully submitted that such an inference is both legally\nunsustainable and factually flawed, for the following reasons:\ni. Non-response by Third Parties Cannot Lead to any Disallowance

INCOME TAX OFFICER, HISAR vs. AJAY KUMAR, HISAR

In the result, the appeal filed by the Revenue for AY 2022-23 is dismissed

Section 133(6) of the Income-tax Act, 1961. It is\nrespectfully submitted that such an inference is both legally\nunsustainable and factually flawed, for the following reasons:\ni.\nNon-response by Third Parties Cannot Lead to any Disallowance

MANKIND PHARMA LIMITED,DELHI vs. DCIT, CIRCLE-1(1)(1), MEERUT

In the result, the additional Ground No

Bench: Shri Challa Nagendra Prasad & Shri Pradip Kumar Kedia

disallowance of claim of deduction of Rs. 8,00,95,000 is not justified on the counters of s. 35(1) merely owing to lesser quantification of eligible expenditure by DSIR. 58. We now advert to the second limb of the argument for eligibility of weighted deduction thereon amounting to Rs.4,00,47,500/- under the shelter of Section

LT FOODS LTD.,NEW DELHI vs. DCIT, NEW DELHI

The appeal of the assessee is partly allowed

Bench: Shri N.K. Billaiya & Shri Yogesh Kumar U.S

133. The underlying facts in this issue are that the Assessing Officer disallowed a sum of Rs. 2,58,94,143/- on account of non deduction of TDS and Rs. 7,26,890/- on account of short deduction of TDS. 134. The break-up of the disallowance made by the Assessing Officer can be understood from the following chart

INTERGLOBE TECHNOLOGY QUOTIENT PRIVATE LIMITED,NEW DELHI vs. ASSISTANT COMMISSIONER CIRCLE 10(1), NEW DELHI

Bench: Shri M. Balaganesh & Shri Anubhav Sharma[Assessment Year: 2020-21

disallowed the CSR expenditure while computing the taxable income. Since, the donee institutions are eligible institutions enjoying exemption u/s 80G of the Act, the assessee has claimed deduction u/s 80G of the Act which is also provided in the statute itself to the assessee. Hence, denial of deduction u/s 80G of the Act to the assessee would result in gross

DCIT, CENTRAL CIRCLE-1, NOIDA vs. AASHIKYANA CIVIL CONTRACTORS P.LTD, NEW DELHI

In the result, the appeal of the Revenue is dismissed

Bench: Sh. C. M. Gargdr. B. R. R. Kumar

disallowance/ addition must be related to some evidence or material placed on record. We relied on following decisions rendered:  Commissioner of Income-tax vs. Greaves Cotton & Co. Ltd., 68 ITR 200, SUPREME COURT OF INDIA  Mehta Parikh & Co. vs. Commissioner of Income-tax, 30 ITR 181, SUPREME COURT OF INDIA  Omar Salay Mohatned Sait Commissioner bf Income

DCIT, CC-20, DELHI vs. LOTUS HERBALS PVT. LTD., DELHI

In the result, appeal of the Revenue in appeal No

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

disallowance on account of payment to suspicious parties, involving some common parties, was made by the AO in AY 2019-20, which was deleted by CITEA) on same reasoning; however, the Revenue has not filed appeal on that issue in that year. Re (ii): Notice(s) under section 133

DCIT, CC-20, DELHI vs. LOTUS HERBALS PVT. LTD., DELHI

In the result, appeal of the Revenue in appeal No

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

disallowance on account of payment to suspicious parties, involving some common parties, was made by the AO in AY 2019-20, which was deleted by CITEA) on same reasoning; however, the Revenue has not filed appeal on that issue in that year. Re (ii): Notice(s) under section 133

DCIT, CC-20, DELHI vs. LOTUS HERBALS PVT. LTD., DELHI

In the result, appeal of the Revenue in appeal No

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

disallowance on account of payment to suspicious parties, involving some common parties, was made by the AO in AY 2019-20, which was deleted by CITEA) on same reasoning; however, the Revenue has not filed appeal on that issue in that year. Re (ii): Notice(s) under section 133

DCIT, CENTRAL CIRCLE-20, DELHI vs. LOTUS HERBALS PVT. LTD, DELHI

In the result, appeal of the Revenue in appeal No

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

disallowance on account of payment to suspicious parties, involving some common parties, was made by the AO in AY 2019-20, which was deleted by CITEA) on same reasoning; however, the Revenue has not filed appeal on that issue in that year. Re (ii): Notice(s) under section 133

DCIT, CENTRAL CIRCLE-20, NEW DELHI vs. LOTUS HERBALS P.LTD, DELHI

In the result, appeal of the Revenue in appeal No

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

disallowance on account of payment to suspicious parties, involving some common parties, was made by the AO in AY 2019-20, which was deleted by CITEA) on same reasoning; however, the Revenue has not filed appeal on that issue in that year. Re (ii): Notice(s) under section 133

COSMIC INFORMATICS PVT. LTD.,NEW DELHI vs. ACIT CENTRAL CIRCLE - 2, NEW DELHI

In the result, appeal of the Revenue in appeal No

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

disallowance on account of payment to suspicious parties, involving some common parties, was made by the AO in AY 2019-20, which was deleted by CITEA) on same reasoning; however, the Revenue has not filed appeal on that issue in that year. Re (ii): Notice(s) under section 133

COSMIC INFORMATICS PVT. LTD.,NEW DELHI vs. ACIT CENTRAL CIRCLE - 2, NEW DELHI

In the result, appeal of the Revenue in appeal No

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

disallowance on account of payment to suspicious parties, involving some common parties, was made by the AO in AY 2019-20, which was deleted by CITEA) on same reasoning; however, the Revenue has not filed appeal on that issue in that year. Re (ii): Notice(s) under section 133