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

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

135 of the paper book 54. The learned authorised representative submitted that aforesaid issue is squarely covered in favour of the appellant by the decision of Delhi bench of tribunal in the appellant‟s own case for the AY 2007-08 and 2008-09, wherein the Tribunal held that disallowance cannot be made merely on the basis that vouchers were

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

disallowing the above expense. In this regard, it is No. 3/2010 cannot override the decision humbly submitted that the Instructions of the Apex Court- Woodward (supra). Once the Apex Court has provided its 14 PTC India Financial Services Ltd. vs. ACIT, ACIT vs. PTC India Financial Services Ltd. & Addl.CIT vs. PTC India Financial Services Ltd. findings, it shall become binding

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

disallowing the above expense. In this regard, it is No. 3/2010 cannot override the decision humbly submitted that the Instructions of the Apex Court- Woodward (supra). Once the Apex Court has provided its 14 PTC India Financial Services Ltd. vs. ACIT, ACIT vs. PTC India Financial Services Ltd. & Addl.CIT vs. PTC India Financial Services Ltd. findings, it shall become binding

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

disallowing the above expense. In this regard, it is No. 3/2010 cannot override the decision humbly submitted that the Instructions of the Apex Court- Woodward (supra). Once the Apex Court has provided its 14 PTC India Financial Services Ltd. vs. ACIT, ACIT vs. PTC India Financial Services Ltd. & Addl.CIT vs. PTC India Financial Services Ltd. findings, it shall become binding

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

disallowing the above expense. In this regard, it is No. 3/2010 cannot override the decision humbly submitted that the Instructions of the Apex Court- Woodward (supra). Once the Apex Court has provided its 14 PTC India Financial Services Ltd. vs. ACIT, ACIT vs. PTC India Financial Services Ltd. & Addl.CIT vs. PTC India Financial Services Ltd. findings, it shall become binding

HERO MOTOCORP LIMITED,NEW DELHI vs. JCIT, NEW DELHI

In the result appeal of the assessee in ITA No

Bench: Sh. I. C. Sudhir & Shri Prashant Maharishihero Motocorp Limited, Jcit, 34, Basant Lok, Vasant Range-1, New Delhi Vs. Vihar, New Delhi Pan: Aaach0812J (Appellant) (Respondent) Dcit, M/S. Hero Moto Corp. Circle-11(1), Ltd., 34, Community Vs. New Delhi Centre, Basant Lok, Vasant Vihar, New Delhi-110057 (Appellant) (Respondent) Dcit, M/S. Hero Moto Corp. Circle-11(1), Ltd., 34, Community

section 143(3) of the Act and it cannot be said that the issue of valuation of closing stock has not been examined, and (ii) secondly, there is no mistake in the accounting/valuation method followed by the appellant in relation to the aforesaid expenses, since the issue of inclusion of the aforesaid expenses in closing inventory would arise only

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

disallowed the expenditure claimed stating it was not incurred wholly and exclusively for the purpose of business of the assessee. 72. The ld. CIT (A) supported the order of the Assessing Officer holding that the Corporate Social Responsibility expenditure is an application of income. An application of income is not an allowable deduction for computing taxable income of any company

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

disallowed the expenditure claimed stating it was not incurred wholly and exclusively for the purpose of business of the assessee. 72. The ld. CIT (A) supported the order of the Assessing Officer holding that the Corporate Social Responsibility expenditure is an application of income. An application of income is not an allowable deduction for computing taxable income of any company

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

disallowed the expenditure claimed stating it was not incurred wholly and exclusively for the purpose of business of the assessee. 72. The ld. CIT (A) supported the order of the Assessing Officer holding that the Corporate Social Responsibility expenditure is an application of income. An application of income is not an allowable deduction for computing taxable income of any company

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

disallowed the expenditure claimed stating it was not incurred wholly and exclusively for the purpose of business of the assessee. 72. The ld. CIT (A) supported the order of the Assessing Officer holding that the Corporate Social Responsibility expenditure is an application of income. An application of income is not an allowable deduction for computing taxable income of any company

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

disallowed the expenditure claimed stating it was not incurred wholly and exclusively for the purpose of business of the assessee. 72. The ld. CIT (A) supported the order of the Assessing Officer holding that the Corporate Social Responsibility expenditure is an application of income. An application of income is not an allowable deduction for computing taxable income of any company

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

disallowed the expenditure claimed stating it was not incurred wholly and exclusively for the purpose of business of the assessee. 72. The ld. CIT (A) supported the order of the Assessing Officer holding that the Corporate Social Responsibility expenditure is an application of income. An application of income is not an allowable deduction for computing taxable income of any company

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

disallowance, which is not the intention of legislature. Accordingly, ground raised by appellant stands allowed. "(emphasis supplied) 6.1 Ld. Counsel has relied judgment in Goldman Sachs Services Pvt Ltd vs JCIT: ITA No.2355/Bang/2019, of the Bangalore Bench of the Tribunal to submit that that deduction under section 80G cannot be denied in respect of CSR expenditure incurred under section 135

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

Appeal of the assessee is partly allowed for statistical purpose

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

disallowing this claim. Therefore, Ground No. 18 to 18.2 are allowed in favour of the assessee.” From the records it can be seen that the provision for the material is worked out in respect of price amendments which were already issued on 31.03.2009 which was made on the basis of actual supplied made upto the end of the year

MCKINSEY GLOBAL CAPABILITIES AND SERVICES PRIVATE LIMITED (MGCS) [MGSIPL NOW MERGED WITH MGCS],HARYANA vs. ADDITIONAL / JOINT / DEPUTY / ASSISTANT COMMISSIONER OF INCOME TAX / INCOME-TAX OFFICER, DELHI

Appeal is allowed

Bench: Sh. Satbeer Singh Godara & Sh. Amitabh Shuklaita No. 5314/Del/2025 : Asstt. Year : 2018-19 Mckinsey Global Capabilities & Vs Cit(A)/Nfac, Services Pvt. Ltd. (Mckinsey Global Delhi Services India Pvt. Ltd.), 3Rd Floor, Block-Iii, Vatika Business Park, Sector-49, Sohna Road, Gurgaon-12201 (Appellant) (Respondent) Pan No. Aaccm2356G Assessee By : Sh. Nikhil Tiwari, Ca Revenue By : Ms. Ankush Kalra, Sr. Dr Date Of Hearing: 15.01.2026 Date Of Pronouncement: 15.01.2026 Order Per Satbeer Singh Godara: This Assessee’S Appeal For Assessment Year 2018-19, Arises Against The Cit(A)/Nfac, Delhi’S Din & Order No. Itba/Nfac/S/250/2025–26/1077218408(1) Dated 19.06.2025, In Proceedings U/S 143(3) Of The Income Tax Act, 1961 (In Short “The Act”).

disallowance, which is not the intention of legislature. Accordingly, ground raised by appellant stands allowed. "(emphasis supplied) 6.1 Ld. Counsel has relied judgment in Goldman Sachs Services Pvt. Ltd. vs JCIT: ITA No.2355/Bang/2019, of the Bangalore Bench of the Tribunal to submit that that deduction under section 80G cannot be denied in respect of CSR expenditure incurred under section 135

ACIT, CIRCLE-7(1), DELHI, DELHI vs. FIS GLOBAL BUSINESS SOLUTIONS INDIA PRIVATE LIMITED, DELHI

In the result, the appeal of the revenue as well as cross objection of the assessee are dismissed

Bench: Shri C.N. Prasad & Shri Naveen Chandra[Assessment Year: 2020-21] Dcit Vs. Fis Global Business Solutions New Delhi India Private Limited S-405, Lower Ground Floor, Greater Kailash, Part Ii New Delhi Pan No.Aaach2851H Appellant Respondent Co. No. 213/Del/2025 (In Ita No.5002/Del/2025) [Assessment Year: 2020-21] Fis Global Business Vs. Dcit Solutions India Private New Delhi Limited S-405, Lower Ground Floor, Greater Kailash, Part Ii New Delhi Pan No.Aaach2851H Appellant Respondent Revenue By Ms. Ankush Kalra, Sr. Dr Assessee By Sh. Vishal Kalra, Advocate Ms. Reema Grewal, Ca Sh. Kashish Gupta, Advocate Date Of Hearing 18.11.2025 Date Of Pronouncement 14.01.2026

disallowance, which is not the intention of legislature. Accordingly, ground raised by appellant stands allowed. "(emphasis supplied). 6.1 Ld. Counsel has relied judgment in Goldman Sachs Services Pvt Ltd vs JCIT: ITA No.2355/Bang/2019, of the Bangalore Bench of the Tribunal to submit that that deduction under section 80G cannot be denied in respect of CSR expenditure incurred under section 135

VIKAS GLOBALONE LTD.,NEW DELHI vs. DCIT, CIRCLE- 26(2), NEW DELHI

In the result, appeal of Assessee is partly allowed

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

Section cannot be extended to disallow expenditure which is assumed to have been incurred for earning non taxable income. The assessee relied upon the decision of the ITAT 9 ITA.No.2498/Del./2018 M/s. Vikas Globalone Ltd., (Now known as M/s. Vikas Ecotech Ltd.,) New Delhi. Delhi Bench in the case

DCIT, NEW DELHI vs. M/S. MARUTI SUZUKI INDIA LTD., NEW DELHI

In the result, all the three appeals of the assessee are allowed as indicated above and the appeal of Revenue is partly allowed

Bench: Shris.Rifaur Rahman & Shri Vimal Kumar

section 135 of the Companies Act, 2013 shall not be deemed to be incurred for the purpose of business. The aforesaid Explanation inserted w.e.f. 1.04.2015. Therefore, in the present assessment year the said explanation will not be applicable. Hence, the expenditure has to be allowed because ultimately the assessee was publicizing its product at the prominent places by maintaining them

MARUTI SUZUKI INDIA LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result, all the three appeals of the assessee are allowed as indicated above and the appeal of Revenue is partly allowed

Bench: Shris.Rifaur Rahman & Shri Vimal Kumar

section 135 of the Companies Act, 2013 shall not be deemed to be incurred for the purpose of business. The aforesaid Explanation inserted w.e.f. 1.04.2015. Therefore, in the present assessment year the said explanation will not be applicable. Hence, the expenditure has to be allowed because ultimately the assessee was publicizing its product at the prominent places by maintaining them