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

disallowed on the ground of the same being contingent in nature. He further submitted that similar provision for increase in prices as at the end of the year was accepted and allowed in Hero MotoCorp Limited Vs. JCIT & DCIT Vs. Hero MotoCorp Ltd. ITA Nos. 1545/Del/2015 and 2424/Del/2015 (AY 2010-11) ITA No. 1609/Del/2016 and 914/Del/2016 (AY 2011-12) Page

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

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

In the result, the appeal of the Revenue in ITA No

Bench: Shri Shamim Yahya & Shri Kul Bharat[Assessment Year : 2010-11] Maruti Suzuki India Ltd., Vs Dcit, Plot No.1, Nelson Mandela Road, Circle-16(1), Vasant Kunj, New Delhi-110070. New Delhi. Pan-Aaacm0829Q Appellant Respondent [Assessment Year : 2010-11] Dcit, Vs Maruti Suzuki India Ltd., Circle-16(1), Plot No.1, Nelson Mandela Road, New Delhi. Vasant Kunj, New Delhi-110070. Pan-Aaacm0829Q Appellant Respondent Appellant By Shri Ajay Vohra, Sr.Adv., Shri Neeraj Jain, Adv. & Ms. Tejasvi Jain & Ms. Somya Jain, Ca Respondent By Shri G.C.Srivastava, Adv., Shri Kalrav Mehrotra, Adv. & Shri Mayank Patawari, Ca Date Of Hearing 11.11.2022 Date Of Pronouncement 09.02.2023

disallowed the expenditure on account of warranty provision amounting to Rs.20,98,82,138/-. Further, the AO also made addition by invoking the provisions of section

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

In the result, the appeal of the Revenue in ITA No

Bench: Shri Shamim Yahya & Shri Kul Bharat[Assessment Year : 2010-11] Maruti Suzuki India Ltd., Vs Dcit, Plot No.1, Nelson Mandela Road, Circle-16(1), Vasant Kunj, New Delhi-110070. New Delhi. Pan-Aaacm0829Q Appellant Respondent [Assessment Year : 2010-11] Dcit, Vs Maruti Suzuki India Ltd., Circle-16(1), Plot No.1, Nelson Mandela Road, New Delhi. Vasant Kunj, New Delhi-110070. Pan-Aaacm0829Q Appellant Respondent Appellant By Shri Ajay Vohra, Sr.Adv., Shri Neeraj Jain, Adv. & Ms. Tejasvi Jain & Ms. Somya Jain, Ca Respondent By Shri G.C.Srivastava, Adv., Shri Kalrav Mehrotra, Adv. & Shri Mayank Patawari, Ca Date Of Hearing 11.11.2022 Date Of Pronouncement 09.02.2023

disallowed the expenditure on account of warranty provision amounting to Rs.20,98,82,138/-. Further, the AO also made addition by invoking the provisions of section

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

disallowed an amount of salary and administrative expenses of Rs.1,69,36,938/- incurred indirectly relatable for exempt income by way of dividend income following the objective method of computation. The AO has recorded that the assessee made investments in equity shares of Indian companies, the dividend income from whom is exempt under section 10(34) and investment in Mutual

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

disallowed an amount of salary and administrative expenses of Rs.1,69,36,938/- incurred indirectly relatable for exempt income by way of dividend income following the objective method of computation. The AO has recorded that the assessee made investments in equity shares of Indian companies, the dividend income from whom is exempt under section 10(34) and investment in Mutual

TRIVENI ENGINEERING & INDUSTRIES LTD.,NOIDA vs. ACIT, NEW DELHI

Bench: Shri R. K. Panda & Ms Suchitra Kamble

Section 115JB was assessed at Rs. 5,92,24,133/- and the tax due thereon was fully adjusted against the taxes already paid by the assessee. Thus, the summary of the additions / disallowances made by the Assessing Officer are as follows: i) Interest on SDF loan: Addition of Rs.63,90,848/- (ii) ERP, Software & Design Development & BPR Expenses: Addition

TRIVENI ENGINEERING & INDUSTRIES LTD.,NOIDA vs. ACIT, NEW DELHI

Bench: Shri R. K. Panda & Ms Suchitra Kamble

Section 115JB was assessed at Rs. 5,92,24,133/- and the tax due thereon was fully adjusted against the taxes already paid by the assessee. Thus, the summary of the additions / disallowances made by the Assessing Officer are as follows: i) Interest on SDF loan: Addition of Rs.63,90,848/- (ii) ERP, Software & Design Development & BPR Expenses: Addition

TRIVENI ENGINEERING & INDUSTRIES LTD.,NOIDA vs. ACIT, NEW DELHI

Bench: Shri R. K. Panda & Ms Suchitra Kamble

Section 115JB was assessed at Rs. 5,92,24,133/- and the tax due thereon was fully adjusted against the taxes already paid by the assessee. Thus, the summary of the additions / disallowances made by the Assessing Officer are as follows: i) Interest on SDF loan: Addition of Rs.63,90,848/- (ii) ERP, Software & Design Development & BPR Expenses: Addition

TRIVENI ENGINEERING & INDUSTRIES LTD.,NOIDA vs. ACIT, NEW DELHI

Bench: Shri R. K. Panda & Ms Suchitra Kamble

Section 115JB was assessed at Rs. 5,92,24,133/- and the tax due thereon was fully adjusted against the taxes already paid by the assessee. Thus, the summary of the additions / disallowances made by the Assessing Officer are as follows: i) Interest on SDF loan: Addition of Rs.63,90,848/- (ii) ERP, Software & Design Development & BPR Expenses: Addition

TRIVENI ENGINEERING & INDUSTRIES LTD.,NOIDA vs. ADDL. CIT, NEW DELHI

Bench: Shri R. K. Panda & Ms Suchitra Kamble

Section 115JB was assessed at Rs. 5,92,24,133/- and the tax due thereon was fully adjusted against the taxes already paid by the assessee. Thus, the summary of the additions / disallowances made by the Assessing Officer are as follows: i) Interest on SDF loan: Addition of Rs.63,90,848/- (ii) ERP, Software & Design Development & BPR Expenses: Addition

MARUTI SUZUKI INDIA LTD.,NEW DELHI vs. ADDL. CIT, NEW DELHI

In the result, the appeal of the assessee is allowed in part for statistical purposes

Bench: Shri N.K. Saini & Shri K.N. Charry

138 TTJ 240 (Del), Bunge Agribusiness (India) (P.) Ltd. v. Dy. CIT: 132 ITD 549 (Mum.) also. 6.4. In the present case of the assessee, the assessing officer has simply applied the procedure prescribed in Rule 8D of the Rules to compute the amount disallowable under section

M/S. DHARAMPAL SATYAPAL LTD.,DELHI vs. ACIT, NEW DELHI

Bench: Shri Amit Shukla & Sh. Prashant Maharishi(Through Video Conferencing) Assessment Year: 2012-13 M/S. Dharampal Satyapal Ltd. Acit, 1711, S. P. Mukherjee Marg, Vs Central Circle – 29, Delhi-110006 New Delhi Pan No. Aaacd0132H (Appellant) (Respondent) Appellant By Sh. R. S. Singhavi, Ca Sh. Satyajeet Goel, Ca Respondent By Sh. Sanjay I. Bara, Cit Dr Date Of Hearing: 28/08/2020 Date Of Pronouncement: 07/10/2020 Order

disallowance of deduction to that extent only. Accordingly, ground number 7 of appeal of assessee is allowed partly to that extent.” 30. Therefore respectfully following the decision of the coordinate bench in assessee’s own case for immediately preceding year we direct the learned assessing officer to recompute the eligible profit following the order of the coordinate bench in earlier

MUFG BANK LTD,NEW DELHI vs. ACIT (INTERNATIONAL TAXATION) CIRCLE-2(2)(1), NEW DELHI

In the result appeal of the assessee is partly allowed

Bench: Shri Amit Shukla & Shri Prashant Maharishi(Through Video Conferencing) Mufg Bank Ltd, Vs. Acit (International Taxation), 5Th Floor, Worldmark 2, Asset 8, Circle-2(2)(1), Aerocity, Nh-8, New Delhi New Delhi Pan: Aabct3880D (Appellant) (Respondent)

138 ITD 83) (Para 14 Page 355 of Compilation). Therefore, it is submitted that the provisions of section 14A cannot be invoked as the DTAA does not allow the disallowance

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

disallowed an\namount of salary and administrative expenses of Rs.1,69,36,938/- incurred\nindirectly relatable for exempt income by way of dividend income following\nthe objective method of computation. The AO has recorded that the assessee\nmade investments in equity shares of Indian companies, the dividend income\nfrom whom is exempt under section 10(34) and investment in Mutual

HERO MOTOCROP LTD.,NEW DELHI vs. ACIT, CIRCLE- 11(1), NEW DELHI

The appeal of the assessee is partly allowed

Bench: Shri Sudhanshu Srivastava & Shri O.P. Kantassessment Year: 2015-16

disallowance made in that year was deleted on the ground that since in the first place, the Hero Motocorp Ltd. vs. ACIT parties were not related to the assessee company in terms of section 40A (2), disallowance on ground of excessive purchase price could not have been made under that section. Further, the Tribunal held that the transactions were entered

SERCO INDIA PVT. LTD.,PUNE vs. DCIT, GURGAON

In the result, appeal filed by the Assessee stands allowed

Bench: Shrianil Chaturvedi, Am & Shri N. K. Choudhry, Jm

disallowed Rs. 1,85,20,176/- of reimbursement of salary u/s 40(a)(i) of the Act. The Hon’ble ITAT held as under: “12. Thus, keeping in view the discussions made above, in final analysis, we hold that the payment of Rs.1,85,20,176/- made by the Assessee towards reimbursement of expenses is in the nature of salary

JINDAL STAINLESS LTD.,HISAR vs. DCIT, NEW DELHI

Accordingly, ground number 2 of the appeal of the learned AO for 2007 – 08 is dismissed

Bench: Smt Diva Singh & Shri Prashant Maharishi

Section 92(4) of the Act). 137. The question of aggregation and disaggregation of transactions when the TNM Method or even in other methods is sought to be applied, must have reference to the strength and weaknesses of the TNM Method or the applicable method. Aggregation of transactions is desirable and not merely permissible, if the nature of transaction