ACIT, NEW DELHI vs. M/S. PTC INDIA FINANCIAL SERVICES LTD., NEW DELHI

In the result, the appeals of the assessee for AY 2013-14 and 2014-15

Bench: Shri N.K. Billaiya & Ms. Astha Chandraasstt. Year 2013-14 & Asstt. Year 2014-15

19 The Ld. CIT-DR relied upon the order of Ld. AO/CIT(A). 20. We have carefully considered the rival submissions and perused the records. It is not in dispute that the assessee is eligible for deduction under section 36(1)(viii) of the Act. The dispute is in a very narrow compass i.e. whether taking cognizance of timeline prescribed

PTC INDIA FINANCIAL SERVICES LTD.,NEW DELHI vs. DCIT, CIRCLE- 19(2), NEW DELHI

In the result, the appeals of the assessee for AY 2013-14 and 2014-15

Bench: Shri N.K. Billaiya & Ms. Astha Chandraasstt. Year 2013-14 & Asstt. Year 2014-15

19 The Ld. CIT-DR relied upon the order of Ld. AO/CIT(A). 20. We have carefully considered the rival submissions and perused the records. It is not in dispute that the assessee is eligible for deduction under section 36(1)(viii) of the Act. The dispute is in a very narrow compass i.e. whether taking cognizance of timeline prescribed

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

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

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)

155 of CLPB II): “This court in the above case held that rule IBB shall be applicable even prior to the enforcement of the rule holding that the said rule merely provides a choice amongst well- known and well-settled modes of valuation. It was held that even in the absence of rule IBB, it would not have been objectionable

TECHNOLOGIES LTD) vs. ACIT

Appeals are allowed

155 ITR 120, where it is observed if any wrong has been committed, same should not be perpetuated. The relevant observations of the Hon‟ble Supreme Court are reproduced as under: “28. But, even if, in our view, the decision in Cloth Traders' case (supra) is erroneous, the question still remains whether we should overturn it. Ordinarily, we would

TECHNOLOGIES LTD) vs. ACIT

Appeals are allowed

155 ITR 120, where it is observed if any wrong has been committed, same should not be perpetuated. The relevant observations of the Hon‟ble Supreme Court are reproduced as under: “28. But, even if, in our view, the decision in Cloth Traders' case (supra) is erroneous, the question still remains whether we should overturn it. Ordinarily, we would

TECHNOLOGIES LTD) vs. ACIT

Appeals are allowed

155 ITR 120, where it is observed if any wrong has been committed, same should not be perpetuated. The relevant observations of the Hon‟ble Supreme Court are reproduced as under: “28. But, even if, in our view, the decision in Cloth Traders' case (supra) is erroneous, the question still remains whether we should overturn it. Ordinarily, we would

CHEMINVEST LIMITED vs. COMMISSIONER OF INCOME TAX-VI

The appeal is allowed in the above terms

155 is shown under the sub-head „unquoted-trade-long term‟. This figure has remained unchanged over the previous year. In the computation filed for the 2015:DHC:7226-DB ITA No. 749 of 2014 Page 4 of 14 purposes of the income tax return, the details of investments have been shown in two broad categories of „capital assets

ITO, NEW DELHI vs. M/S ANSAL HOUSING & CONSTRUCTION LTD., NEW DELHI

In the result, the cross-objection filed by the assessee is dismissed

Bench: Shri G.S.Pannu & Shri Kul Bharat[Assessment Year : 2007-08] Dcit, Vs Ansal Housing & Construction Ltd., Central Circle-20, Ugf-15, Indraprastha Building, 21, New Delhi. Barakhamba Road, New Delhi. Pan-Aaaca0377R Appellant Respondent

19 SOT 251 (Del.)(Further appeal dismissed by the High Court) • Ms. Priyananki Singh Sood v. ACIT: [2019] 174 ITD 371 (Delhi - Trib.) • ITO v. Metaoxide (P.) Ltd. - [2018] 170 ITD 235 (Mumbai - Trib.) • Raj Landmark (P.) Ltd. v. ITO - [2018] 172 ITD 339 (Jaipur ITAT) • Sachin R. Tendulkar v. 172 ITD 266 (Mumbai - Trib.) • Sonu Realtors

DCIT, CIRCLE-3(2), NEW DELHI vs. ASIAN CONSOLIDATED INDS.LTD), REWARI

In the result, all the 03 appeals filed by the Revenue stand dismissed in the aforesaid manner

Bench: Shri Anubhav Sharma & Shri Krinwant Sahay, Accoutant Member Ita No. 6218/Del/2017 (Asstt. Year 1994-95) & Dcit, Circle-3(2), New Delhi Vs. M/S Asian Consolidated Industries Ltd., 96Th Mile Stone, Delhi-Jaipur Highway, Village-Bawal, Distt.- Rewari, Haryana (Pan: Aaaca5887A) (Appellant) (Respondent) Assessee By : Sh. Ved Jain, Adv. & Sh. Ayush Garg, Ca Department By : Ms. Monika Singh, Cit-Dr Date Of Hearing 20.08.2025 Date Of Pronouncement 27.08.2025 Order Per Krinwant Sahay, Am:

section 80HH and 80l of the Act. For the same reasoning, these grounds no 3 and 4 of the Revenue are dismissed. 43. Ground No. 5 is relating to Disallowance of Administrative, selling and distribution expenses of Rs. 1,61,97,155/-. AO has disallowed administration, selling and distribution expenses by computing a proportionate rate of 81.18% on the basis

ACIT, CIRCLE-3(2), NEW DELHI vs. ASIAN CONSOLIDATED INDS.LTD), REWARI

In the result, all the 03 appeals filed by the Revenue stand dismissed in the aforesaid manner

Bench: Shri Anubhav Sharma & Shri Krinwant Sahay, Accoutant Member Ita No. 6218/Del/2017 (Asstt. Year 1994-95) & Dcit, Circle-3(2), New Delhi Vs. M/S Asian Consolidated Industries Ltd., 96Th Mile Stone, Delhi-Jaipur Highway, Village-Bawal, Distt.- Rewari, Haryana (Pan: Aaaca5887A) (Appellant) (Respondent) Assessee By : Sh. Ved Jain, Adv. & Sh. Ayush Garg, Ca Department By : Ms. Monika Singh, Cit-Dr Date Of Hearing 20.08.2025 Date Of Pronouncement 27.08.2025 Order Per Krinwant Sahay, Am:

section 80HH and 80l of the Act. For the same reasoning, these grounds no 3 and 4 of the Revenue are dismissed. 43. Ground No. 5 is relating to Disallowance of Administrative, selling and distribution expenses of Rs. 1,61,97,155/-. AO has disallowed administration, selling and distribution expenses by computing a proportionate rate of 81.18% on the basis

DCIT, CIRCLE-3(2), NEW DELHI vs. ASIAN CONSOLIDATED INDS.LTD), REWARI

In the result, all the 03 appeals filed by the Revenue stand dismissed in the aforesaid manner

Bench: Shri Anubhav Sharma & Shri Krinwant Sahay, Accoutant Member Ita No. 6218/Del/2017 (Asstt. Year 1994-95) & Dcit, Circle-3(2), New Delhi Vs. M/S Asian Consolidated Industries Ltd., 96Th Mile Stone, Delhi-Jaipur Highway, Village-Bawal, Distt.- Rewari, Haryana (Pan: Aaaca5887A) (Appellant) (Respondent) Assessee By : Sh. Ved Jain, Adv. & Sh. Ayush Garg, Ca Department By : Ms. Monika Singh, Cit-Dr Date Of Hearing 20.08.2025 Date Of Pronouncement 27.08.2025 Order Per Krinwant Sahay, Am:

section 80HH and 80l of the Act. For the same reasoning, these grounds no 3 and 4 of the Revenue are dismissed. 43. Ground No. 5 is relating to Disallowance of Administrative, selling and distribution expenses of Rs. 1,61,97,155/-. AO has disallowed administration, selling and distribution expenses by computing a proportionate rate of 81.18% on the basis

LT FOODS LTD.,NEW DELHI vs. DCIT, NEW DELHI

The appeal of the assessee is partly allowed

Bench: Shri N.K. Billaiya & Shri Yogesh Kumar U.S

disallowed under section 40a(ia) to the tune of Rs 2,66,21,033/- (Rs.7,26,890/- + Rs. 2,58,94,143/-) and the addition of Rs. 3,15,46,346/- has been made. 9.1 That the DRP has in view of the facts and circumstances of the case has erred in law and on facts in holding that identical

MODI RUBBER LTD.,NEW DELHI vs. ACIT, CIRCLE- 17(1), NEW DELHI

In the result, Ground no.2 is partly allowed

Bench: Shri Saktijit Dey- & Shri Pradip Kumar Kedia-

disallowance under Section 14A of the Act. The CIT(A) thus declined to interfere. 7.3 The CIT(A) however reversed the addition made to the book profit under Section 115JB of the Act in the light of the decision rendered by the Special Bench in the case of ACIT vs. Vireet Investment Pvt. Ltd., [2017] 82 taxmann.com 415. 8. Further

ACIT, CIRCLE- 10(2), NEW DELHI vs. GROZ ENGINEERING TOOLS PVT. LTD., NEW DELHI

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

Bench: Shri G.S. Pannu, Hon’Ble & Shri Anubhav Sharmaassessment Year: 2015-16 Acit, Vs Groz Engineering Tools Pvt. Ltd., Circle-10(2), C-717, New Friends Colony, New Delhi. New Delhi. Pan: Aabcg4017H (Appellant) (Respondent) Assessee By : Shri Ved Jain, Advocate & Shri Aman Garg, Ca Revenue By : Shri Amit Katoch, Sr. Dr Date Of Hearing : 27.03.2024 Date Of Pronouncement : 30.05.2024 Order Per Anubhav Sharma, Jm:

19, 2022. 7.2 Ld.CIT(A) has restricted the addition under section 14A r.w.r 8D(iii) to Rs. Rs. 5,41,887/- holding that exempt income of Rs. 1,61,45,211/- has been received as profit of share of M/s AP Tools. In this regard Ld. Counsel has submitted that the partnership firm is an independent entity and requires

ACIT,, NEW DELHI vs. M/S KANTI COMMERCIAL (P) LTD.,, NEW DELHI

In the result, the appeal of the Revenue is partly allowed for statistical purposes

Bench: Shri G.S.Pannu & Shri Kul Bharat[Assessment Year : 2012-13] Acit, Vs Kanti Commercial (P.) Ltd., Central Circle-13, No.1, Zamrudpur Community Centre, New Delhi-110001. Kailash Colony Extension, New Delhi-110001 Pan-Aacck1191P Appellant Respondent Appellant By Shri S.S.Nagar, Ca Respondent By Shri Umesh Takyar, Sr. Dr Date Of Hearing 01.04.2022 Date Of Pronouncement 29.04.2022

155/- made by the A.O under Section 14A of the Act is deleted.” 14. We do not see any infirmity in the above finding of Ld.CIT(A) as the Revenue has not disputed the fact that the assessee has not earned any exempt income during the year under consideration. Therefore, Ld.CIT(A) 6 | P a g e has rightly followed

SPICEJET LIMITED,HARYANA vs. DCIT CIRCLE-24(1), DELHI

In the result, appeal of the assessee for AY 2011-12 is partly

Bench: Shri Narendra Kumar Billaiya & Shri Challa Nagendra Prasadआ.अ.सं/.I.T.A No.5181/Del/2016 िनधा"रणवष"/Assessment Year:2011-12 बनाम Spice Jet Limited, Addl. Cit 319, Udyog Vihar, Phase-Iv, Vs. Range-9, Gurgaon, Haryana. New Delhi. Pan No. Aaccr1459F अपीलाथ" Appellant ""यथ"/Respondent आ.अ.सं/.I.T.A No.5153/Del/2016 िनधा"रणवष"/Assessment Year:2011-12 बनाम Acit Spice Jet Ltd., Circle-24(1), Vs. 319, Udyog Vihar, Phase-Iv, Room No.163, Gurgaon, Haryana. C.R. Building, New Delhi. Pan No. Aaccr1459F अपीलाथ" Appellant ""यथ"/Respondent आ.अ.सं/.I.T.A No.879/Del/2022 िनधा"रणवष"/Assessment Year:2012-13 बनाम Dcit Spice Jet Ltd., Central Circle-01, Vs. 319, Udyog Vihar, Phase-Iv, Room No.334, E-2, Gurgaon, Haryana. Ara Centre, Jhandewalan Extension, New Delhi. Pan No. Aaccr1459F अपीलाथ" Appellant ""यथ"/Respondent

19. Heard rival submissions, perused the orders of the authorities below. 20. On perusal of the order of the Tribunal in assessee’s own case for the assessment years 2006-07 to 2010-11 which is placed at pages 1 to 41 of the Paper Book we observe that the Tribunal by order dated 28.12.2022 decided the issue in favour

SPICEJET LIMITED,HARYANA vs. DCIT CIRCLE-24(1), DELHI

In the result, appeal of the assessee for AY 2011-12 is partly

Bench: Shri Narendra Kumar Billaiya & Shri Challa Nagendra Prasadआ.अ.सं/.I.T.A No.5181/Del/2016 िनधा"रणवष"/Assessment Year:2011-12 बनाम Spice Jet Limited, Addl. Cit 319, Udyog Vihar, Phase-Iv, Vs. Range-9, Gurgaon, Haryana. New Delhi. Pan No. Aaccr1459F अपीलाथ" Appellant ""यथ"/Respondent आ.अ.सं/.I.T.A No.5153/Del/2016 िनधा"रणवष"/Assessment Year:2011-12 बनाम Acit Spice Jet Ltd., Circle-24(1), Vs. 319, Udyog Vihar, Phase-Iv, Room No.163, Gurgaon, Haryana. C.R. Building, New Delhi. Pan No. Aaccr1459F अपीलाथ" Appellant ""यथ"/Respondent आ.अ.सं/.I.T.A No.879/Del/2022 िनधा"रणवष"/Assessment Year:2012-13 बनाम Dcit Spice Jet Ltd., Central Circle-01, Vs. 319, Udyog Vihar, Phase-Iv, Room No.334, E-2, Gurgaon, Haryana. Ara Centre, Jhandewalan Extension, New Delhi. Pan No. Aaccr1459F अपीलाथ" Appellant ""यथ"/Respondent

19. Heard rival submissions, perused the orders of the authorities below. 20. On perusal of the order of the Tribunal in assessee’s own case for the assessment years 2006-07 to 2010-11 which is placed at pages 1 to 41 of the Paper Book we observe that the Tribunal by order dated 28.12.2022 decided the issue in favour

M/S. SPICEJET LTD.,GURGAON vs. ADDL. CIT, NEW DELHI

In the result, appeal of the assessee for AY 2011-12 is partly

Bench: Shri Narendra Kumar Billaiya & Shri Challa Nagendra Prasadआ.अ.सं/.I.T.A No.5181/Del/2016 िनधा"रणवष"/Assessment Year:2011-12 बनाम Spice Jet Limited, Addl. Cit 319, Udyog Vihar, Phase-Iv, Vs. Range-9, Gurgaon, Haryana. New Delhi. Pan No. Aaccr1459F अपीलाथ" Appellant ""यथ"/Respondent आ.अ.सं/.I.T.A No.5153/Del/2016 िनधा"रणवष"/Assessment Year:2011-12 बनाम Acit Spice Jet Ltd., Circle-24(1), Vs. 319, Udyog Vihar, Phase-Iv, Room No.163, Gurgaon, Haryana. C.R. Building, New Delhi. Pan No. Aaccr1459F अपीलाथ" Appellant ""यथ"/Respondent आ.अ.सं/.I.T.A No.879/Del/2022 िनधा"रणवष"/Assessment Year:2012-13 बनाम Dcit Spice Jet Ltd., Central Circle-01, Vs. 319, Udyog Vihar, Phase-Iv, Room No.334, E-2, Gurgaon, Haryana. Ara Centre, Jhandewalan Extension, New Delhi. Pan No. Aaccr1459F अपीलाथ" Appellant ""यथ"/Respondent

19. Heard rival submissions, perused the orders of the authorities below. 20. On perusal of the order of the Tribunal in assessee’s own case for the assessment years 2006-07 to 2010-11 which is placed at pages 1 to 41 of the Paper Book we observe that the Tribunal by order dated 28.12.2022 decided the issue in favour