PRABHU SARAN GARG CHARITABLE TRUST,NEW DELHI vs. JCIT, GHAZIABAD

In the result, the appeal of the assessee is allowed

Bench: Dr. B. R. R. Kumarsh. Yogesh Kumar Usita No. 3558/Del/2015 : Asstt. Year 2010-11 Prabhu Saran Garg Charitable Vs. Jcit, Trust, C/O M/S O.P. Sapra & Range-2, Associates, C-763, New Friends Ghaziabad Colony, New Delhi-110025 (Appellant) (Respondent) Pan No. Aaatp9634M Assessee By : Sh. Akhilesh Kumar, Adv. Revenue By : Sh. Girish Kumar Kohali, Sr. Dr Date Of Hearing: 26.07.2022 Date Of Pronouncement: 11.08.2022

disallowing exemption claimed. 2. That, learned commissioner of income tax (Appeals) manifestly erred in rejecting the contention that alleged advances made to three 2 Prabhu Saran Garg Charitable Trust unrelated parties are not ‘investment or deposit’ so as to hit by provisions of S. 13(1)(d) of Act as per the settled law. 3. That, learned commissioner of income

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

Appeal of the Revenue is dismissed

Bench: Shri Narendra Kumar Billaiya & Shri Kul Bharat

17,767/- under section 40(a)(ia) of the Act. Further, the assessing officer held that the entire total trade discount of Rs. 56,90,94,045 given to dealers on sales invoice at the time of sale while alleging that the same was based on achievement of turnover targets which represented commission on which TDS under section 194H

ACIT, CIRCLE- 21(1), NEW DELHI vs. RELIGARE FINVEST LTD.,, NEW DELHI

In the result, -Appeal in ITA No

Bench: Dr. B. R. R. Kumar & Shri Yogesh Kumar U.S.

Section 14A of the Act read with Rule 8D of the Rules, of Rs. 77,45,598/-. The Ld. A.O. made disallowance of Rs. 17,50,04,535/-. The Ld. CIT(A), however, restricted the disallowance to Rs. 6,40,98,834/- being the amount of exempt income earned during the year. As against restriction of disallowance the Revenue

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

In the result, -Appeal in ITA No

Bench: Dr. B. R. R. Kumar & Shri Yogesh Kumar U.S.

Section 14A of the Act read with Rule 8D of the Rules, of Rs. 77,45,598/-. The Ld. A.O. made disallowance of Rs. 17,50,04,535/-. The Ld. CIT(A), however, restricted the disallowance to Rs. 6,40,98,834/- being the amount of exempt income earned during the year. As against restriction of disallowance the Revenue

RELIGARE FINVEST LTD.,NEW DELHI vs. ACIT, CIRCLE- 21(1), NEW DELHI

In the result, -Appeal in ITA No

Bench: Dr. B. R. R. Kumar & Shri Yogesh Kumar U.S.

Section 14A of the Act read with Rule 8D of the Rules, of Rs. 77,45,598/-. The Ld. A.O. made disallowance of Rs. 17,50,04,535/-. The Ld. CIT(A), however, restricted the disallowance to Rs. 6,40,98,834/- being the amount of exempt income earned during the year. As against restriction of disallowance the Revenue

ACIT (OSD), CIRCLE- 21(1), NEW DELHI vs. RELIGARE FINVEST LTD., NEW DELHI

In the result, -Appeal in ITA No

Bench: Dr. B. R. R. Kumar & Shri Yogesh Kumar U.S.

Section 14A of the Act read with Rule 8D of the Rules, of Rs. 77,45,598/-. The Ld. A.O. made disallowance of Rs. 17,50,04,535/-. The Ld. CIT(A), however, restricted the disallowance to Rs. 6,40,98,834/- being the amount of exempt income earned during the year. As against restriction of disallowance the Revenue

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

In the result, -Appeal in ITA No

Bench: Dr. B. R. R. Kumar & Shri Yogesh Kumar U.S.

Section 14A of the Act read with Rule 8D of the Rules, of Rs. 77,45,598/-. The Ld. A.O. made disallowance of Rs. 17,50,04,535/-. The Ld. CIT(A), however, restricted the disallowance to Rs. 6,40,98,834/- being the amount of exempt income earned during the year. As against restriction of disallowance the Revenue

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

In the result, -Appeal in ITA No

Bench: Dr. B. R. R. Kumar & Shri Yogesh Kumar U.S.

Section 14A of the Act read with Rule 8D of the Rules, of Rs. 77,45,598/-. The Ld. A.O. made disallowance of Rs. 17,50,04,535/-. The Ld. CIT(A), however, restricted the disallowance to Rs. 6,40,98,834/- being the amount of exempt income earned during the year. As against restriction of disallowance the Revenue

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

In the result, -Appeal in ITA No

Bench: Dr. B. R. R. Kumar & Shri Yogesh Kumar U.S.

Section 14A of the Act read with Rule 8D of the Rules, of Rs. 77,45,598/-. The Ld. A.O. made disallowance of Rs. 17,50,04,535/-. The Ld. CIT(A), however, restricted the disallowance to Rs. 6,40,98,834/- being the amount of exempt income earned during the year. As against restriction of disallowance the Revenue

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)

disallowance under section 14A of the Act cannot exceed the actual exempt dividend income. 2. Each of the aforesaid contentions are elaborated hereunder: Re (a): Amendment in section 14A - prospective and not retrospective 3. Kind attention is, at the outset, invited to the provisions of section 14A of the Act, as amended by the Finance Act, 2022, w.e.f

ADDL. CIT, SPECIAL RANGE- 7, NEW DELHI vs. 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

d) The appellant craves to be allowed to add any fresh ground(s) of appeal and/or delete or amend any of the ground(s) of appeal Assessee’s Grounds of Appeal- AY 2014-15 “1. That the additions/disallowances made and sustained by the Commissioner of Income Tax (Appeals) are illegal and bad in law. 2. That in view

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

d) The appellant craves to be allowed to add any fresh ground(s) of appeal and/or delete or amend any of the ground(s) of appeal Assessee’s Grounds of Appeal- AY 2014-15 “1. That the additions/disallowances made and sustained by the Commissioner of Income Tax (Appeals) are illegal and bad in law. 2. That in view

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

d) The appellant craves to be allowed to add any fresh ground(s) of appeal and/or delete or amend any of the ground(s) of appeal Assessee’s Grounds of Appeal- AY 2014-15 “1. That the additions/disallowances made and sustained by the Commissioner of Income Tax (Appeals) are illegal and bad in law. 2. That in view

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

d) The appellant craves to be allowed to add any fresh ground(s) of appeal and/or delete or amend any of the ground(s) of appeal Assessee’s Grounds of Appeal- AY 2014-15 “1. That the additions/disallowances made and sustained by the Commissioner of Income Tax (Appeals) are illegal and bad in law. 2. That in view

TECHNOLOGIES LTD) vs. ACIT

Appeals are allowed

D. Agarwal, Advocates. versus ACIT .....Respondent Through: Mr. Shailender Singh, Senior Standing Counsel. CORAM: HON'BLE MR. JUSTICE RAJIV SHAKDHER HON'BLE MR. JUSTICE TALWANT SINGH RAJIV SHAKDHER, J: Table of Contents Background facts: - .................................................................................................................... 2 ITA 213/2020 ......................................................................................................................... 3 ITA 214/2020 ......................................................................................................................... 5 ITA 215/2020 ......................................................................................................................... 7 Submissions on behalf of the appellant/assessee: -.................................................................... 8 Submissions advanced on behalf of the revenue: - .................................................................. 10 Analysis

TECHNOLOGIES LTD) vs. ACIT

Appeals are allowed

D. Agarwal, Advocates. versus ACIT .....Respondent Through: Mr. Shailender Singh, Senior Standing Counsel. CORAM: HON'BLE MR. JUSTICE RAJIV SHAKDHER HON'BLE MR. JUSTICE TALWANT SINGH RAJIV SHAKDHER, J: Table of Contents Background facts: - .................................................................................................................... 2 ITA 213/2020 ......................................................................................................................... 3 ITA 214/2020 ......................................................................................................................... 5 ITA 215/2020 ......................................................................................................................... 7 Submissions on behalf of the appellant/assessee: -.................................................................... 8 Submissions advanced on behalf of the revenue: - .................................................................. 10 Analysis

TECHNOLOGIES LTD) vs. ACIT

Appeals are allowed

D. Agarwal, Advocates. versus ACIT .....Respondent Through: Mr. Shailender Singh, Senior Standing Counsel. CORAM: HON'BLE MR. JUSTICE RAJIV SHAKDHER HON'BLE MR. JUSTICE TALWANT SINGH RAJIV SHAKDHER, J: Table of Contents Background facts: - .................................................................................................................... 2 ITA 213/2020 ......................................................................................................................... 3 ITA 214/2020 ......................................................................................................................... 5 ITA 215/2020 ......................................................................................................................... 7 Submissions on behalf of the appellant/assessee: -.................................................................... 8 Submissions advanced on behalf of the revenue: - .................................................................. 10 Analysis

PCL FOODS PVT. LTD.,GURGAON vs. ADDI CIT, NATIONAL E- ASSESMENT CENTRE, NEW DELHI

In the result, this appeal of the assessee is partly allowed

Bench: Ms. Madhumita Roy & Shri Brajesh Kumar Singh[Assessment Year: 2016-17] Pcl Foods Private Limited, Additional / Joint/ Unit No.-219, Plot No. 2, Deputy/Assistant Vardhman Crown Mall, Lsc, Vs Commissioner Of Income Sector 19, Dwarka, New Tax/ Income Tax Officer, Delhi-110075. National E-Assessment Centre, Delhi. Pan- Aahcp3493L Assessee Revenue

disallowing loss 3,69,12,311/- and brokerage and commission expense 36,49,338/- in respect of Currency Derivatives aggregating 4,05,61,649/-by- a. Holding that transactions done in currency derivatives do not fall in clause (d) of proviso to section 43(5) and hence are speculative transactions. b Currency derivative does not fall under the definition