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1,567 results for “disallowance”+ Section 144clear

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Key Topics

Addition to Income76Section 14447Section 143(3)46Disallowance46Section 14843Section 14336Section 14733Section 271(1)(c)27Section 153A25Deduction

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

Appeal of the Revenue is dismissed

ITA 1982/DEL/2019[2014-15]Status: DisposedITAT Delhi03 Feb 2023AY 2014-15

Bench: Shri Narendra Kumar Billaiya & Shri Kul Bharat

Section 14ASection 2(22)(e)Section 40Section 40a

144 ITD 141 (Kol. Trib.) - Department appeal dismissed in CIT v. REI Agro Ltd.: I.T.A.TNo.220 of 2013 (Cal. HC) - ACIT v. Vireet Investment (P.) Ltd.: 165 ITD 27 (Del) (SB) - Religare Enterprises Ltd. v. DCIT: 1549/Del/2014 (Del Trib.) - Religare Securities Ltd vs. ACIT: ITA 2282/Del/2013 - Religare Securities Ltd vs. DCIT: ITA 230/Del/2017 Amendment in section 14A vide Finance

TECHNOLOGIES LTD) vs. ACIT

Appeals are allowed

Showing 1–20 of 1,567 · Page 1 of 79

...
24
Section 14A23
Transfer Pricing23
ITA/213/2020
HC Delhi
05 Jul 2021
For Appellant: -.................................................................... 8For Respondent: - .................................................................. 10
Section 10BSection 143(3)Section 14ASection 254Section 35D

144 of the new Act. We cannot, therefore, consistently with the rule of interpretation which denies retrospective operation to a statute which has the effect of creating or imposing a new obligation or liability, construe sub-section (6) of Section 171 as embracing a case where assessment of a Hindu Undivided Family is made under the provisions

TECHNOLOGIES LTD) vs. ACIT

Appeals are allowed

ITA/214/2020HC Delhi05 Jul 2021
For Appellant: -.................................................................... 8For Respondent: - .................................................................. 10
Section 10BSection 143(3)Section 14ASection 254Section 35D

144 of the new Act. We cannot, therefore, consistently with the rule of interpretation which denies retrospective operation to a statute which has the effect of creating or imposing a new obligation or liability, construe sub-section (6) of Section 171 as embracing a case where assessment of a Hindu Undivided Family is made under the provisions

TECHNOLOGIES LTD) vs. ACIT

Appeals are allowed

ITA/215/2020HC Delhi05 Jul 2021
For Appellant: -.................................................................... 8For Respondent: - .................................................................. 10
Section 10BSection 143(3)Section 14ASection 254Section 35D

144 of the new Act. We cannot, therefore, consistently with the rule of interpretation which denies retrospective operation to a statute which has the effect of creating or imposing a new obligation or liability, construe sub-section (6) of Section 171 as embracing a case where assessment of a Hindu Undivided Family is made under the provisions

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

In the result appeal of the assessee in ITA No

ITA 1545/DEL/2015[2010-11]Status: DisposedITAT Delhi24 Oct 2016AY 2010-11

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

For Appellant: Sh. Ajay Vohra, Sr. AdvFor Respondent: Sh. NC Sawain, CIT DR
Section 143Section 143(3)Section 144CSection 92C

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

PME POWER SOLUTIONS INDIA LTD,NEW DELHI vs. DY. COMMISSIONER OF INCOME TAX, NEW DELHI

In the result, both the appeal of the assessee are allowed

ITA 242/DEL/2024[2013-14]Status: DisposedITAT Delhi16 Oct 2024AY 2013-14

Bench: Shri M. Balaganesh & Shri Vimal Kumar

For Appellant: Shri Gaurav Jain, AdvFor Respondent: Shri Rajesh Dhanesta, Sr. DR
Section 139Section 139(9)Section 140ASection 143(1)Section 143(2)Section 143(3)Section 154Section 249(4)(a)Section 271(1)(c)Section 276C(2)

section 144 of the Act would also be initiated in these cases. ITA Nos.242 & 249/Del/2024 PME Power Projects India Ltd (ii) If the defects as specified are removed, the AD will treat the return as valid and proceed accordingly. (iii) If the defects are not removed and return remains invalid, the AD will proceed to pass order u/s 144

PME POWER SOLUTIONS INDIA LTD,NEW DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, NEW DELHI

In the result, both the appeal of the assessee are allowed

ITA 249/DEL/2024[2013-14]Status: DisposedITAT Delhi16 Oct 2024AY 2013-14

Bench: Shri M. Balaganesh & Shri Vimal Kumar

For Appellant: Shri Gaurav Jain, AdvFor Respondent: Shri Rajesh Dhanesta, Sr. DR
Section 139Section 139(9)Section 140ASection 143(1)Section 143(2)Section 143(3)Section 154Section 249(4)(a)Section 271(1)(c)Section 276C(2)

section 144 of the Act would also be initiated in these cases. ITA Nos.242 & 249/Del/2024 PME Power Projects India Ltd (ii) If the defects as specified are removed, the AD will treat the return as valid and proceed accordingly. (iii) If the defects are not removed and return remains invalid, the AD will proceed to pass order u/s 144

DCIT, CIRCLE- 21(1), NEW DELHI vs. RELIGARE ENTERPRISES LTD.,, NEW DELHI

In the result, revenue’s appeal is dismissed and cross-objection

ITA 7552/DEL/2018[2014-15]Status: HeardITAT Delhi29 Aug 2022AY 2014-15

Bench: Shri Saktijit Dey & Shri Pradip Kumar Kedia:Assessment Year: 2014-15 Deputy Commissioner Of Vs. M/S. Religare Enterprises Income-Tax, Circle-21(1), Ltd., 2Nd Floor, Rajlok New Delhi Building, 24-Nehru Place, New Delhi-110019 Pan :Aaacv5888N (Appellant) (Respondent)

Section 14A

disallowance under section 14A of the Act, held that the said rule, being a substantive one, cannot be regarded as merely clarificatory and the same has been held to be applicable prospectively: • Godrej and Boyce Manufacturing Co. Ltd vs. DOT: 394 ITR 449 (SC); 13 ITA No. 7552 & CO. 27/Del./2018 • Maxopp Investment

EBRO INDIA PVT.LTD. ,DELHI vs. ACIT CIRCLE-7(1), DELHI

In the result, the ground no 4 raised by the assessee is allowed

ITA 1291/DEL/2022[2018-19]Status: HeardITAT Delhi09 Sept 2024AY 2018-19

Bench: SHRI S.RIFAUR RAHMAN (Accountant Member), SHRI YOGESH KUMAR U.S. (Accountant Member)

For Appellant: Shri Rohit Jain, AdvocateFor Respondent: Shri Rajesh Kumar, CIT DR
Section 143(3)Section 144BSection 144CSection 68

144, in the cases referred to in sub-section (2), shall be made in a faceless manner as per the following procedure, namely:— (i) the National Faceless Assessment Centre shall serve a notice on the assessee under sub-section (2) of section 143; ……….. (iii) where the assessee— (a) has furnished his return of income under section 139 or in response

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

Appeal of the assessee is partly allowed for statistical purpose

ITA 1351/DEL/2018[2009-10]Status: DisposedITAT Delhi23 Apr 2019AY 2009-10

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

For Appellant: Amount of Proposed international
Section 115JSection 143(3)Section 144C

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

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

In the result, both the appeals of the assessee are partly allowed and the appeal of Revenue for assessment year 2007-08

ITA 5492/DEL/2013[2008-09]Status: DisposedITAT Delhi28 Jan 2020AY 2008-09

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

For Appellant: 1. That the Commissioner of Income-Tax (Appeals) erred on facts and in law in up
Section 14ASection 35D

section 14A of the Act, which include disallowance of Rs.37,33,490/- towards indirect ITA Nos. 5524 & 5525/Del/2013 interest expenditure and ₹ 44,71,541/- towards administrative expenses. 5.1 The facts qua the issue in dispute that during the year under consideration, the assessee shown investment in mutual funds at ₹ 144

NIIT TECHNOLOGIES LTD.,NEW DELHI vs. ACIT, NEW DELHI

In the result, both the appeals of the assessee are partly allowed and the appeal of Revenue for assessment year 2007-08

ITA 5525/DEL/2013[2008-09]Status: DisposedITAT Delhi28 Jan 2020AY 2008-09

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

For Appellant: 1. That the Commissioner of Income-Tax (Appeals) erred on facts and in law in up
Section 14ASection 35D

section 14A of the Act, which include disallowance of Rs.37,33,490/- towards indirect ITA Nos. 5524 & 5525/Del/2013 interest expenditure and ₹ 44,71,541/- towards administrative expenses. 5.1 The facts qua the issue in dispute that during the year under consideration, the assessee shown investment in mutual funds at ₹ 144

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

In the result, both the appeals of the assessee are partly allowed and the appeal of Revenue for assessment year 2007-08

ITA 5491/DEL/2013[2007-08]Status: DisposedITAT Delhi28 Jan 2020AY 2007-08

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

For Appellant: 1. That the Commissioner of Income-Tax (Appeals) erred on facts and in law in up
Section 14ASection 35D

section 14A of the Act, which include disallowance of Rs.37,33,490/- towards indirect ITA Nos. 5524 & 5525/Del/2013 interest expenditure and ₹ 44,71,541/- towards administrative expenses. 5.1 The facts qua the issue in dispute that during the year under consideration, the assessee shown investment in mutual funds at ₹ 144

NIIT TECHNOLOGIES LTD.,NEW DELHI vs. ACIT, NEW DELHI

In the result, both the appeals of the assessee are partly allowed and the appeal of Revenue for assessment year 2007-08

ITA 5524/DEL/2013[2007-08]Status: DisposedITAT Delhi28 Jan 2020AY 2007-08

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

For Appellant: 1. That the Commissioner of Income-Tax (Appeals) erred on facts and in law in up
Section 14ASection 35D

section 14A of the Act, which include disallowance of Rs.37,33,490/- towards indirect ITA Nos. 5524 & 5525/Del/2013 interest expenditure and ₹ 44,71,541/- towards administrative expenses. 5.1 The facts qua the issue in dispute that during the year under consideration, the assessee shown investment in mutual funds at ₹ 144

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

ITA 1024/DEL/2016[2011-12]Status: DisposedITAT Delhi08 Oct 2025AY 2011-12

Bench: Shris.Rifaur Rahman & Shri Vimal Kumar

For Appellant: Shri Ajay Vohra, Sr. AdvocateFor Respondent: Shri G.C. Srivastava, Spl. Counsel for the Department
Section 143(3)Section 144CSection 144C(1)Section 144C(5)Section 14ASection 32Section 35Section 43B

144 ITD 141 (Kol. Trib.) – Revenue appeal dismissed by Calcutta HC in appeal No.GA No.3581 of 2013  ACIT v. Vireet Investments Pvt. Ltd.: 165 ITD 27 / 188 TTJ 1 (Del Trib.) (SB)  Religare Enterprises Ltd. v. DCIT: 1549/Del/2014 (Del Trib.)  11. It is submitted that if only the dividend yielding investments are considered for the purpose of section

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

ITA 901/DEL/2017[2012-13]Status: DisposedITAT Delhi08 Oct 2025AY 2012-13

Bench: Shris.Rifaur Rahman & Shri Vimal Kumar

For Appellant: Shri Ajay Vohra, Sr. AdvocateFor Respondent: Shri G.C. Srivastava, Spl. Counsel for the Department
Section 143(3)Section 144CSection 144C(1)Section 144C(5)Section 14ASection 32Section 35Section 43B

144 ITD 141 (Kol. Trib.) – Revenue appeal dismissed by Calcutta HC in appeal No.GA No.3581 of 2013  ACIT v. Vireet Investments Pvt. Ltd.: 165 ITD 27 / 188 TTJ 1 (Del Trib.) (SB)  Religare Enterprises Ltd. v. DCIT: 1549/Del/2014 (Del Trib.)  11. It is submitted that if only the dividend yielding investments are considered for the purpose of section

DCIT, NEW DELHI vs. M/S. GUJARAT GUARDIAN LTD., NEW DELHI

In the result, appeal filed by the revenue against the direction of the Ld

ITA 1106/DEL/2015[2010-11]Status: DisposedITAT Delhi16 Aug 2018AY 2010-11

Bench: Shri S.K.Yadav & Shri Prashant Maharishim/S. Guajarat Guardian Ltd, Vs. Dcit, 4-7/C, Dda Shopping Centre, Circle-12(1), (Now Circle- New Friends Colony, 10(2), New Delhi Cr Building, Ip Estate, Pan: Aaacg1622K New Delhi (Appellant) (Respondent) Dcit, Vs. M/S. Guajarat Guardian Ltd, Circle-12(1), (Now Circle-10(2), 4-7/C, Dda Shopping Cr Building, Ip Estate, Centre, New Delhi New Friends Colony, New Delhi Pan: Aaacg1622K (Appellant) (Respondent)

For Appellant: Shri Neeraj Jain, AdvFor Respondent: Smt Meeta Singh CIT DR
Section 144Section 144CSection 14A

144 C (5) of the Act. The Ld. assessing officer is also aggrieved by the direction of the Ld. Dispute resolution panel and therefore he has filed an appeal before us. 2. The assessee has raised the following grounds of appeal in ITA NO. 973/Del/2015:- “1. That the assessing officer erred on facts and in law in completing the assessment

PR. COMMISSIONER OF INCOME TAX -7 vs. SUMITOMO CORPORATION INDIA (P) LTD.

ITA/52/2023HC Delhi02 Sept 2024

Bench: HON'BLE MR. JUSTICE YASHWANT VARMA,HON'BLE MR. JUSTICE RAVINDER DUDEJA

disallowance of deduction under section 10B of the Act of Rs.2,79,46,551.  Objections were filed by the Petitioner against the DAO before the DRP, which issued directions dated 24.12.2014 under section 144

THE PR. COMMISSIONER OF INCOME TAX -6 vs. MICROSOFT INDIA ( R & D) PVT. LTD.

ITA/993/2019HC Delhi02 Mar 2020

Bench: HON'BLE MR. JUSTICE VIPIN SANGHI,HON'BLE MR. JUSTICE SANJEEV NARULA

disallowance of deduction under section 10B of the Act of Rs.2,79,46,551.  Objections were filed by the Petitioner against the DAO before the DRP, which issued directions dated 24.12.2014 under section 144

THE PR. COMMISSIONER OF INCOME TAX -6 vs. MARUTI SUZUKI INDIA LTD.

ITA/995/2019HC Delhi02 Mar 2020

Bench: HON'BLE MR. JUSTICE VIPIN SANGHI,HON'BLE MR. JUSTICE SANJEEV NARULA

disallowance of deduction under section 10B of the Act of Rs.2,79,46,551.  Objections were filed by the Petitioner against the DAO before the DRP, which issued directions dated 24.12.2014 under section 144