M/S. BHARTI AIRTEL LTD.,NEW DELHI vs. ADDL. CIT, NEW DELHI

In the result appeal of the assessee with respect to ground No

Bench: Shri I.C.Sudhir & Shri Prashant Maharishibharti Airtel Ltd, Addl Cit, Bharti Crescent, 1, Vs. Range-2, Cr Building, Ip Nelson Mandela Road, Vasant Estate, New Delhi Kunj, New Delhi Pan:Aaacb2894G (Appellant) (Respondent) Bharti Airtel Ltd, Addl Cit, Bharti Crescent, 1, Vs. Range-2, Cr Building, Ip Nelson Mandela Road, Vaxant Estate, New Delhi Kunj, New Delhi Pan:Aaacb2894G (Appellant) (Respondent)

disallowance of the payment under section 40(a)(ia) of the Act. iii. Considering the aforesaid contention, the Bombay High Court held in favour of the assessee observing as under: “31. The object of introducing section 40(a)(ia), as explained in the Central Board of Direct Taxes Circular No. 5, dated July

ANIL CHAUDHARY,NEW DELHI vs. ACIT CENTRAL CIRCLE-17, NEW DELHI

In the result, appeals filed by the assessee are allowed

Bench: Shri S.Rifaur Rahman & Shri Anubhav Sharma

151 and section 153, where the Assessing Officer is satisfied that any money, bullion, jewellery or other valuable article or thing or books of account or documents seized or requisitioned belongs or belong to a person, other than the person referred to in section 153A, then the books of account or documents or assets seized or requisitioned shall be handed

ANIL CHAUDHARY,NEW DELHI vs. ACIT CENTRAL CIRCLE-17, NEW DELHI

In the result, appeals filed by the assessee are allowed

Bench: Shri S.Rifaur Rahman & Shri Anubhav Sharma

151 and section 153, where the Assessing Officer is satisfied that any money, bullion, jewellery or other valuable article or thing or books of account or documents seized or requisitioned belongs or belong to a person, other than the person referred to in section 153A, then the books of account or documents or assets seized or requisitioned shall be handed

ANIL CHAUDHARY,NEW DELHI vs. ACIT CENTRAL CIRCLE-17, NEW DELHI

In the result, appeals filed by the assessee are allowed

Bench: Shri S.Rifaur Rahman & Shri Anubhav Sharma

151 and section 153, where the Assessing Officer is satisfied that any money, bullion, jewellery or other valuable article or thing or books of account or documents seized or requisitioned belongs or belong to a person, other than the person referred to in section 153A, then the books of account or documents or assets seized or requisitioned shall be handed

ANIL CHAUDHARY,NEW DELHI vs. ACIT CENTRAL CIRCLE-17, NEW DELHI

In the result, appeals filed by the assessee are allowed

Bench: Shri S.Rifaur Rahman & Shri Anubhav Sharma

151 and section 153, where the Assessing Officer is satisfied that any money, bullion, jewellery or other valuable article or thing or books of account or documents seized or requisitioned belongs or belong to a person, other than the person referred to in section 153A, then the books of account or documents or assets seized or requisitioned shall be handed

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

MAMRAJ AGGARWAL,DELHI SADAR BAZAR, DELHI vs. INCOME TAX OFFICER WARD 47(1), DELHI, DELHI

In the result the appeal of the assessee is allowed

151(ii) of the Act\nrendering the proceedings bad in law and liable to be quashed.\n3. That the addition of Rs.11,67,49,280/- made by Ld. AO and upheld by Ld.\nCIT(A) on account of unexplained expenditure under section 69C of the Income\nTax Act 1961 is bad in law since the source of expenditure was explained

ANIL KUMAR JAIN,NEW DELHI vs. DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-26, JHANDEWALAN, NEW DELHI

In the result, the appeal of the assessee is allowed

Bench: SHRI YOGESH KUMAR U.S. (Judicial Member), SHRI MANISH AGARWAL (Accountant Member)

151 of the Income Tax Act, 1961. 1.2. On the facts and circumstances of the case, the CIT(A) erred in confirming the initiation of reassessment u/s 148 merely on the change of opinion. 1.3. On the facts and circumstances of the case, the AO erred in initiating reassessment u/s 148 in gross violation of dictum laid down

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

ACIT, NEW DELHI vs. SH. EMPIRE CASTING PVT. LTD., NEW DELHI

In the result, the appeal of the revenue and C

Bench: : Shri Bhavnesh Saini & Shri L.P. Sahu

disallowance of deduction u/s 80IB are illegal, unjust, bad in law and are highly excessive and the same can not be justified. 5. That the respondent reserves the right to add/amend/alter the grounds of cross objection.” 2. Brief facts of the case are that a search and seizure action u/s 132 of the Act was carried out on M/s Wings

M/S. GLOBAL TELEVENTURE LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result, all the 4 Appeals filed by the Assessee stand allowed

Bench: Shri H.S. Sidhu & Shri O.P. Kant

151 section 153, where the and section 153, where the Assessing Officer is satisfied Assessing Officer is satisfied that any money, bullion, that any money, bullion, jewellery or other valuable jewellery or other valuable article or thing or books of article or thing or books of account or documents seized account or documents seized or requisitioned belongs or or requisitioned

M/S. GLOBAL REALTY CREATIONS LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result, all the 4 Appeals filed by the Assessee stand allowed

Bench: Shri H.S. Sidhu & Shri O.P. Kant

151 section 153, where the and section 153, where the Assessing Officer is satisfied Assessing Officer is satisfied that any money, bullion, that any money, bullion, jewellery or other valuable jewellery or other valuable article or thing or books of article or thing or books of account or documents seized account or documents seized or requisitioned belongs or or requisitioned

M/S. GLOBAL HERITAGE VENTURE LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result, all the 4 Appeals filed by the Assessee stand allowed

Bench: Shri H.S. Sidhu & Shri O.P. Kant

151 section 153, where the and section 153, where the Assessing Officer is satisfied Assessing Officer is satisfied that any money, bullion, that any money, bullion, jewellery or other valuable jewellery or other valuable article or thing or books of article or thing or books of account or documents seized account or documents seized or requisitioned belongs or or requisitioned

M/S. GLOBAL HERITAGE VENTURE LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result, all the 4 Appeals filed by the Assessee stand allowed

Bench: Shri H.S. Sidhu & Shri O.P. Kant

151 section 153, where the and section 153, where the Assessing Officer is satisfied Assessing Officer is satisfied that any money, bullion, that any money, bullion, jewellery or other valuable jewellery or other valuable article or thing or books of article or thing or books of account or documents seized account or documents seized or requisitioned belongs or or requisitioned

ACIT, CIRCLE 10(2), NEW DELHI vs. GREEN INFRA WIND FARM ASSETS LTD., GURUGRAM

In the result, the appeal of the Revenue is dismissed

disallowance under section 36(1)(iii) of INR\n1,89,40,151/-. The AO also disallowed half percent of the average

BHAVIKA BHUWALKA,DELHI vs. INCOME TAX OFFICER, WARD-5(1)(2), NOIDA, NOIDA

In the result, the appeal of the assessee is allowed

Bench: Shri C.N. Prasad[Assessment Year: 2013-14] Bhavika Bhuwalka Vs. Ito C055, Iind Floor, Preet Ward-5 (1) (2) Vihar, Delhi Noida Pan No. Amnpb8209R Appellant Respondent

section 151 for issuance of notice u/s.148 of the Act, submitted that on a single day on 30.03.2021 the Ld.PCIT had sanctioned approval u/s.151 in as many as 47 cases on a single day. 5. The Ld. Counsel for the assessee placing reliance on the decision of Hon’ble Delhi High Court in the case of PCIT Vs. Pioneer Town

ACIT, CIRCLE 10(2), NEW DELHI vs. GREEN INFRA WIND FARM ASSET LTD., GURGAON

In the result, both captioned appeals of the Revenue are dismissed

disallowance under section 36(1)(iii) of INR\n1,89,40,151/-. The AO also disallowed half percent of the average

DCIT CENTRAL CIRCLE-II, NOIDA vs. APPLE COMMODITIES LTD, NOIDA

In the result, the appeal of the assessee in ITA Nos

Bench: Shri G.S. Pannu, Hon’Ble & Shri Challa Nagendra Prasadआ.अ.सं/.I.T.A Nos.2239 & 2240/Del/2019 िनधा"रणवष"/Assessment Years:2009-10 & 2010-11 बनाम Dcit Apple Commodities Ltd., 701-A, 7Th Floor, Vs. Central Circle-Ii, 2Nd Floor, Arto Complex, Gd-Itl Tower, Plot No.B- Sector-33, Noida, 08, Uttar Pradesh. Netaji Subhash Place, Pitampura, New Delhi. Pan No.Aadca0300K अपीलाथ" Appellant ""यथ"/Respondent & Cross Objection Nos. 122 & 123/Del/2019 (In Ita Nos. 2239 To 2240/Del/2019) Assessment Years: 2009-10 & 2010-11 बनाम Apple Commodities Ltd., Dcit 701-A, 7Th Floor, Vs. Central Circle-Ii, 2Nd Floor, Arto Complex, Gd-Itl Tower, Plot No.B-08, Netaji Subhash Place, Sector-33, Noida, Pitampura, New Delhi. Uttar Pradesh. Pan No. Aadca0300K अपीलाथ" Appellant ""यथ"/Respondent

disallowance of interest and enhancement of gross profit or unexplained foreign remittances. However, AO has not discussed or mentioned any incriminating seized document, which is found and seized, as a result of search and belonging to the appellant company for making such additions in the assessment orders. It is evident from the assessment order that all the additions made

DCIT CENTRAL CIRCLE-II, NOIDA vs. APPLE COMMODITIES LTD, NOIDA

In the result, the appeal of the assessee in ITA Nos

Bench: Shri G.S. Pannu, Hon’Ble & Shri Challa Nagendra Prasadआ.अ.सं/.I.T.A Nos.2239 & 2240/Del/2019 िनधा"रणवष"/Assessment Years:2009-10 & 2010-11 बनाम Dcit Apple Commodities Ltd., 701-A, 7Th Floor, Vs. Central Circle-Ii, 2Nd Floor, Arto Complex, Gd-Itl Tower, Plot No.B- Sector-33, Noida, 08, Uttar Pradesh. Netaji Subhash Place, Pitampura, New Delhi. Pan No.Aadca0300K अपीलाथ" Appellant ""यथ"/Respondent & Cross Objection Nos. 122 & 123/Del/2019 (In Ita Nos. 2239 To 2240/Del/2019) Assessment Years: 2009-10 & 2010-11 बनाम Apple Commodities Ltd., Dcit 701-A, 7Th Floor, Vs. Central Circle-Ii, 2Nd Floor, Arto Complex, Gd-Itl Tower, Plot No.B-08, Netaji Subhash Place, Sector-33, Noida, Pitampura, New Delhi. Uttar Pradesh. Pan No. Aadca0300K अपीलाथ" Appellant ""यथ"/Respondent

disallowance of interest and enhancement of gross profit or unexplained foreign remittances. However, AO has not discussed or mentioned any incriminating seized document, which is found and seized, as a result of search and belonging to the appellant company for making such additions in the assessment orders. It is evident from the assessment order that all the additions made