ACIT, NEW DELHI vs. M/S. SOUL SPACE PROJECTS LTD., DELHI

In the result, the appeals of the revenue are dismissed and the Cross Objections of the assessee are allowed

Bench: Ms. Sushma Chowladr. B. R. R. Kumarita No. 193/Del/2015 : Asstt. Year : 2007-08 Ita No. 1849/Del/2015 : Asstt. Year : 2008-09 Acit, Vs Soul Space Projects Ltd., Central Circle-15, E-23/B-1, Extn. Mcie, Mathura New Delhi-110055 Road, New Delhi-110044 (Appellant) (Respondent) Pan No. Aajcs7736F Co No. 271/Del/2015 : Asstt. Year : 2007-08 Co No. 284/Del/2015 : Asstt. Year : 2008-09 Soul Space Projects Ltd., Vs Acit, E-23/B-1, Extn. Mcie, Mathura Central Circle-15, Road, New Delhi-110044 New Delhi-110055 (Appellant) (Respondent) Pan No. Aajcs7736F

disallowed. Re: Addition of assumed, presumed and deemed assessable profits from Bikaner and Mohali Projects. 6. That the CIT(A) erred on facts and in law in not accepting method of accounting and accounting policies adopted by the appellant in respect of Bikaner and Mohali projects accounting for recognizing the revenue and cost thereof. 6.1 That the CIT(A) erred

M/S. CENTRAL GUM & CHEMICALS LIMITED,NEW DELHI vs. DCIT, NEW DELHI

In the result, the assessee’s appeal is allowed

Bench: Sh. Sudhanshu Srivastava & Sh. O.P. Kantassessment Year: 2008-09 M/S. Central Gum & Chemicals Vs. Dcit, Central –Iii, New Ltd., 308, Arunachal Building Delhi 19, Barakhamba Road, New Delhi Gir/Pan :Aaccc4405A (Appellant) (Respondent) Appellant By Sh. V. Raja Kumar, Adv. Respondent By Sh. Sunil Chander Sharma, Cit(Dr) Date Of Hearing 26.07.2016 Date Of Pronouncement 29.07.2016 Order Per O.P. Kant, A.M.: This Appeal By The Assessee Is Directed Against Order Dated 06/11/2013 Of The Learned Commissioner Of Income-Tax (Appeals)-Xxxiii, New Delhi For Assessment Year 2008-09 Raising Following Grounds: “That The Ld. Cit (A) Erred In Confirming The Assessment Order Passed U/S 143 (3) Of The Act On 27.12.2010 Which Is Bad Both On Facts & In Law; 2) That The Authorities Below Erred Both On Facts & In Law In Making An Addition Of Rs.24,17,66,963/- U/S 68 Of The Income-Tax Act, 1961 Without Appreciating The Fact

section 144A of the Act. In the background of these facts, the Tribunal in para 11 to 17 of the order has observed as under: “11. We have carefully considered the arguments of both the sides and perused relevant material placed before us. The facts in the case of all the companies are similar. Therefore, they are being taken

M/S. VIAGRA TRADING CO. PVT. LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result, the appeal of the assessee is allowed

Bench: Sh.N.K.Saini & Sh.K.N.Charyviagra Trading Co. Pvt. Ltd., Vs Dcit, 308, Arunachal Bldg., 19, Central Barakhamba Road, New Delhi-110001. Circle-Iii, Pan-Aabcv9360N New Delhi. (Appellant) (Respondent) Appellant By Sh. R.S.Singhvi & Sh. Satyajit Goyal, Ca Respondent By Sh. Sampurnanand, Sr.Dr Date Of Hearing 28.09.2017 Date Of Pronouncement .11.2017 Order Per K.N.Charyaggrieved By The Order Dated 29.01.2014 In Appeal No.380/10-11/352 Passing By The Commissioner Of Income Tax (Appeal) [In Short “Cit(A)”]-Xxxiii, New Delhi For 2008-09 Assessment Year, The Assessee Filed This Appeal.

disallowance, etc. or 5 variants of it, but always with reference to a particular assessment year. In this case, the Settlement Commission was seized of asst. yr. 2006-07. Whilst exercising its authority over the application, the Commission concededly exercised the vast plenitude of its power or jurisdiction. The petitioner had made a disclosure in its application

DHAMAKA TRADING & CONSTRUCTION PVT. LTD.,NEW DELHI vs. DCIT (HQ), NEW DELHI

In the result, assessee’s appeal is allowed

Bench: Shri S.V. Mehrotra : & Ms. Suchitra Kamble :Asstt. Yr: 2008-09 Dhamaka Trading & Vs. Dcit (Hq), Construction Pvt Ltd., Central Circle-Iii, (Now Known As Deus Trading & New Delhi. Construction Pvt. Ltd.), 308, Arunachal Building, 19, Barakhamba Road, New Delhi. Pan: Aabcd 9454 H ( Appellant ) (Respondent) Appellant By : Shri V. Raja Kumar Adv. Respondent By : Shri Amrit Lal Sr. Dr Date Of Hearing : 09/12/2015. Date Of Order : 02/02/2016. O R D E R Per S.V. Mehrotra, A.M:

section 148 for the A. Y. 2006-07 (the facts are same for A. Y. 2008-09 which is under consideration) that the A.O. has stated that the applicant has provided accommodation entry and charged premium varying from 4% to 8%. After discussing various facts, the A:a. has stated that the applicant has been providing the accommodation entries

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

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

disallowances. On 07 April and 28 July 2021, the petitioner was served with notices under Section 92CA intimating it of a reference having been made to the TPO. The TPO issued a show cause notice on 03 September 2021 apprising the writ petitioner of various adjustments which were proposed to be made. Since the additions proposed would have been binding

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

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

disallowances. On 07 April and 28 July 2021, the petitioner was served with notices under Section 92CA intimating it of a reference having been made to the TPO. The TPO issued a show cause notice on 03 September 2021 apprising the writ petitioner of various adjustments which were proposed to be made. Since the additions proposed would have been binding

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

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

disallowances. On 07 April and 28 July 2021, the petitioner was served with notices under Section 92CA intimating it of a reference having been made to the TPO. The TPO issued a show cause notice on 03 September 2021 apprising the writ petitioner of various adjustments which were proposed to be made. Since the additions proposed would have been binding

M/S. CHANDER PRABHU FINANCIAL SERVICE PVT. LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result, appeal of the assessee is allowed

Bench: Sh. N. K. Sainiita No. 3421/Del/2014 : Asstt. Year : 2008-09 M/S Chander Prabhu Financial Vs Dy. Commissioner Of Income Tax Service Pvt. Ltd., 308, Arunachal (Hq), Central Circle-Iii, Bldg., 19, Barakhamba Road, New Delhi New Delhi-110001 (Appellant) (Respondent) Pan No. Aaccc1205G Assessee By : Sh. Sandeep Kumar, Ca Revenue By : Sh. Amrit Lal, Sr. Dr Date Of Hearing : 24.08.2016 Date Of Pronouncement : 26.10.2016 Order This Is An Appeal By The Assessee Against The Order Dated 29.01.2014 Of Ld. Cit(A)-Xxxiii, New Delhi.

section 148 for the A. Y. 2006-07 (the facts are same for A. Y. 2008-09 which is under consideration) that the A.O. has stated that the applicant has provided accommodation entry and charged premium varying from 4% to 8%. After discussing various facts, the A:a. has stated that the applicant has been providing the accommodation entries

INCOME TAX OFFICER WARD-2(1), FARIDABAD vs. PRAHLAD, PALWAL

In the result, the Revenue’s appeal is partly allowed as above

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishra

section 145(3) of the Income Tax Ad. 1961 which was forwarded to the Range Head on the very same day. The Range Head of this unit on 27.00.2022 has given the following directions u/s 144A of the Act. 1. Being the data of High Risk Billers received from the CBIC and the CASS Rationale highlighted to verify the genuineness

DALMIA (BROS) PVT LTD,NEW DELHI vs. DCIT, CIRCLE-7(1), NEW DELHI

In the result, the appeal filed by the assessee is allowed

Bench: Shri Satbeer Singh Godara & Shris.Rifaur Rahmandalmia (Bros) Pvt. Ltd., Vs. Dcit, Circle 7 (1), C/O Shri Vinod Kumar Bindal & Co., New Delhi. Chartered Accountants, Shiv Sushil Bhawan, D-219, Vivek Vihar, Phase 1, Delhi – 110 095. (Pan :Aaacd3525G) (Appellant) (Respondent) Assessee By : Shri Vinod Kumar Bindal, Advocate Ms. Rinky Sharma, Itp Revenue By : Shri Rajesh Kumar Dhanesta, Sr. Dr Date Of Hearing : 03.07.2025 Date Of Order : 22.09.2025 O R D E R Per S. Rifaur Rahman: 1. The Assessee Has Filed Appeal Against The Order Of The Learned Addl./Jcit (A)-7, Kolkata [“Ld. Jcit(A)”, For Short] Dated 19.01.2024 For The Assessment Year 2015-16 Raising Following Grounds Of Appeal :- “1. The Learned Cit (A) Erred In Law & On Facts In Confirming The Disallowance Of Vehicle Running Expenses Amounting To Rs.4,00,204/- Though Evidences Placed On Record. Thus, The Addition Made On Surmises & Conjectures Must Be Deleted.

144A of the Act-was introduced by the Finance Act, 2001 with retrospective effect from 01.04.1962. The purpose for introduction of section 14A with retrospective effect since inception of the Act was clarified vide Circular No.14 of 2001 as under: "Certain incomes are not includible while computing the total income, as these exempt under various provisions of the Act. There

MOHAN SHARMA(INDIVIDUAL),BALLABGARH vs. ITO, WARDE-1(5), FARIDABAD

In the result, the appeal filed by the assessee is allowed

Bench: Shri Satbeer Singh Godara & Shris.Rifaur Rahmandalmia (Bros) Pvt. Ltd., Vs. Dcit, Circle 7 (1), C/O Shri Vinod Kumar Bindal & Co., New Delhi. Chartered Accountants, Shiv Sushil Bhawan, D-219, Vivek Vihar, Phase 1, Delhi – 110 095. (Pan :Aaacd3525G) (Appellant) (Respondent) Assessee By : Shri Vinod Kumar Bindal, Advocate Ms. Rinky Sharma, Itp Revenue By : Shri Rajesh Kumar Dhanesta, Sr. Dr Date Of Hearing : 03.07.2025 Date Of Order : 22.09.2025 O R D E R Per S. Rifaur Rahman: 1. The Assessee Has Filed Appeal Against The Order Of The Learned Addl./Jcit (A)-7, Kolkata [“Ld. Jcit(A)”, For Short] Dated 19.01.2024 For The Assessment Year 2015-16 Raising Following Grounds Of Appeal :- “1. The Learned Cit (A) Erred In Law & On Facts In Confirming The Disallowance Of Vehicle Running Expenses Amounting To Rs.4,00,204/- Though Evidences Placed On Record. Thus, The Addition Made On Surmises & Conjectures Must Be Deleted.

144A of the Act-was introduced by the Finance Act, 2001 with retrospective effect from 01.04.1962. The purpose for introduction of section 14A with retrospective effect since inception of the Act was clarified vide Circular No.14 of 2001 as under: "Certain incomes are not includible while computing the total income, as these exempt under various provisions of the Act. There

COMMISSIONER OF INCOME TAX vs. GITWAKO FARMS (I) P.LTD.

The appeal is dismissed

144A, the AO completed the assessment under Section 143(3) on 27th December, 2006 and disallowed the deduction amount to Rs.54

COMMISSIONER OF INCOME TAX vs. GITWAKO FARMS (I) P.LTD.

The appeal is dismissed

Bench: HON'BLE MR. JUSTICE A.K.SIKRI,HON'BLE MR. JUSTICE M.L. MEHTA

144A, the AO completed the assessment under Section 143(3) on 27th December, 2006 and disallowed the deduction amount to Rs.54

ACIT, CENTRAL CIRCLE-19, DELHI, DELHI vs. YASMIN KAPOOR, DELHI

Appeals of the assessee are allowed

Bench: Shri M. Balaganesh & Shri Raj Kumar Chauhanacit, Vs. Deepa Talwar, Central Circle-19, 6/14, Shanti Niketan, Delhi New Delhi (Appellant) (Respondent) Pan: Aaupt4464F

144A of the Act. She stated that even the Additional CIT/JCIT is involved in the preparation of final assessment order by way of instructing the Assessing Officer issuing final show cause notice. She referred to Paragraph 3.2 of the Manual, which reads as under:- “3.2 All the issues and evidence that is going to be relied upon in the assessment

ACIT, CENTRAL CIRCLE-19, DELHI, DELHI vs. DEEPA TALWAR, DELHI

Appeals of the assessee are allowed

Bench: Shri M. Balaganesh & Shri Raj Kumar Chauhanacit, Vs. Deepa Talwar, Central Circle-19, 6/14, Shanti Niketan, Delhi New Delhi (Appellant) (Respondent) Pan: Aaupt4464F

144A of the Act. She stated that even the Additional CIT/JCIT is involved in the preparation of final assessment order by way of instructing the Assessing Officer issuing final show cause notice. She referred to Paragraph 3.2 of the Manual, which reads as under:- “3.2 All the issues and evidence that is going to be relied upon in the assessment

YASMIN KAPOOR,DELHI vs. DCIT, CENTRAL CIRCLE - 19, DELHI, DELHI

144A of the Act. She stated that even the\nAdditional CIT/JCIT is involved in the preparation of final\nassessment order by way of instructing the Assessing Officer\nissuing final show cause notice. She referred to Paragraph 3.2 of\nthe Manual, which reads as under:-\n\n“3.2\nAll the issues and evidence that is going to be relied\nupon

ACIT, CENTRAL CIRCLE-19, DELHI, DELHI vs. YASMIN KAPOOR, DELHI

Accordingly, the respective grounds raised by the respective\nassessees are hereby allowed

144A of the Act. She stated that even the\nAdditional CIT/JCIT is involved in the preparation of final\nassessment order by way of instructing the Assessing Officer\nissuing final show cause notice. She referred to Paragraph 3.2 of\nthe Manual, which reads as under:-\n\n“3.2 All the issues and evidence that is going to be relied\nupon

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

In the result, the appeal of the assessee is allowed and the appeal of the revenue is dismissed

Bench: Shri A.T. Varkey & Shri Prashant Maharishi

section 80IC which were then considered in original assessment proceedings included "Claim of 80IC deduction on Interest Income, Capital gains, excise Refund & Miscellaneous income"( Assessment order page 2), amounting to Rs.66,26,94,688/-. Only on these limited aspects the matter was examined u/s 144A by Addl.CIT also, and vide letter dated 22.12.2006, he directed that the income shown under