UMAR DARAJ,MEERUT vs. ITO WARD-1(2)(4), MEERUT

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

Bench: Shri S.Rifaur Rahman & Shri Yogesh Kumar U.S.Umar Daraj, Vs. Ito, Ward 1(2)(4), 153/1, Hapur Road, Meerut. Umar Nagar, Meerut – 250 001 (Uttar Pradesh). (Pan : Ainpd8766H) (Appellant) (Respondent) Assessee By : Shri Sumit Lal Chandani, Advocate Revenue By : Shri Dayainder Singh Sidhu, Citdr Date Of Hearing : 17.09.2025 Date Of Order : 10.12.2025 O R D E R Per S. Rifaur Rahman:

1. That the notice dated 30.03.2021 issued under Section 148 of the Income Tax Act, 1961 ('the Act') and the assessment order dated 10.03.2022 passed are illegal, bad in law, without jurisdiction and not in accordance with the provisions of the Act. 2. That the order dated 14.02.2025 passed under Section 250 of the Act by CIT(A) confirming legality

(Now known as Sony India Limited)

Sections (1) and (2) to Section 92C are applicable to the assessed, as well as the Assessing Officer invoking power under Sub-Section (3) to Section 92C of the Act. As noted above, sub-section (2) to Section 92C stipulates that most appropriate method, out of the methods specified in sub-section (1) shall be applied to determine

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 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 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

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

disallowance of deduction claimed under section 10B of the Act.  Said final assessment order was accompanied by notice of demand issued under section 156 and notice issued under section 274 read with section 271(1)(c) of the Act for initiating penalty proceedings. provided to the Petitioner to file objections before the DRP, even though the Respondent was mandated

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

disallowance of deduction claimed under section 10B of the Act.  Said final assessment order was accompanied by notice of demand issued under section 156 and notice issued under section 274 read with section 271(1)(c) of the Act for initiating penalty proceedings. provided to the Petitioner to file objections before the DRP, even though the Respondent was mandated

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

disallowance of deduction claimed under section 10B of the Act.  Said final assessment order was accompanied by notice of demand issued under section 156 and notice issued under section 274 read with section 271(1)(c) of the Act for initiating penalty proceedings. provided to the Petitioner to file objections before the DRP, even though the Respondent was mandated

ADIT, DEHRADUN vs. M/S. HALLIBURTON OFFSHORE SERVICES INC., DEHRADUN

Bench: Shri I.C.Sudhir & Shri Prashant Maharishiadit, Halliburton Offshore Services International Taxation, Inc. , Vs. 13-A,Subhash Road, C/O. Nangia & Company, Ca, Aayakar Bhawan, 75/7, Rajpur Road, Dehradun Dehradun Pan:Aaach5154M (Appellant) (Respondent) Halliburton Offshore Services Addl. Cit, Inc. , International Taxation, Vs. C/O. Nangia & Company, Ca, Subhash Road, Suite-4A, Plaza M-6, Jasola, Dehradun New Delhi Pan:Aaach5154M (Appellant) (Respondent) Halliburton Offshore Services Inc. , Adit, C/O. Nangia & Company, Ca, International Taxation, Vs. Suite-4A, Plaza M-6, Jasola, 13-A,Subhash Road, New Delhi Aayakar Bhawan, Pan:Aaach5154M Dehradun (Appellant) (Respondent) Halliburton Offshore Services Inc. Vs Ddit (International Taxation)

151, Hon'ble Supreme Court had observed that "(t)he binding effect of a decision of this Court does not depend upon whether a particular argument was considered or not, provided the point with the reference to which the argument is advanced subsequently was actually decided in the earlier decision " In view of these discussions, we see no reason

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

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

MOHAIR INVESTMENT AND TRADING COMPANY (P) LTD.,,NEW DELHI vs. DCIT, NEW DELHI

In the result the appeal of the assessee is allowed

Bench: Shri A.T. Varkey & Shri O.P. Kant

151 wherein it was held that even if the main activity of the company was to make investments in holding company for retaining control over the group companies, the disallowance under section 14A can be made irrespective of the fact that dividend earnings were only incidental in nature. On the other hand, the assessee had relied on the decision

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-19, DELHI, NEW DELHI vs. M/S JKM INFRA PROJECTS LTD., NOIDA, UTTAR PRADESH

In the result, the appeal of the revenue is dismissed and Cross

Bench: Shri M. Balaganesh & Shri Sudhir Kumaracit, Vs. M/S. Jkm Infra Projects Ltd, Central Circle-19, Sector-9, Noida Delhi Maharishinagar, Maharishi Nagar, So Gautam Budh Nagar, Up 201304 (Appellant) (Respondent) Pan: Aabcj3577H Co 132/Del/2025 (In Ita No. 3031/Del/2025) (Assessment Year: 2013-14) M/S. Jkm Infra Projects Ltd, Vs. Acit, Sector-9, Noida Central Circle-19, Maharishinagar, Maharishi Delhi Nagar, So Gautam Budh Nagar, Up 201304 (Appellant) (Respondent) Pan: Aabcj3577H

151 and section 153, in the case of a person where a search is initiated under section 132 or books of account, other documents or any assets are requisitioned under section 132A after the 31st day of May, 2003 [but on or before the 31st day of March, 2021], the Assessing Officer shall— (a) issue notice to such person requiring

ANAND JAIN HUF,NEW DELHI vs. DCIT, CENTRAL CIRCLE- 25, NEW DELHI

In the result, the appeal of the assessee is allowed

Bench: Shri H.S. Sidhu & Shri B.R.R. Kumar

151 and section 153, where the Assessing Officer is satisfied that,— (a) any money, bullion, jewellery or other valuable article or thing, seized or requisitioned, belongs to; or (b) any books of account or documents, seized or requisitioned, pertains or pertain to, or any information contained therein, relates to, a person other than the person referred to in section 153A