DCIT, NEW DELHI vs. M/S SAHARA INDIA MASS COMMUNICATION LTD., MUMBAI

In the result, appeals filed by the Revenue are partly allowed

Bench: Shri S. Rifaur Rahman & Shri Vimal Kumar

Section 37 of the LT. Act applies the test of "wholly and exclusively for the purposes of business" to all assessee-types, including companies. Where a company maintains vehicles or telephones that are partly for personal use by directors/officers, the personal-use component is not laid out "wholly and exclusively for the purposes of business" and is hence disallowable. Established

DCIT, NEW DELHI vs. M/S SAHARA INDIA MASS COMMUNICATION LTD., MUMBAI

In the result, appeals filed by the Revenue are partly allowed

Bench: Shri S. Rifaur Rahman & Shri Vimal Kumar

Section 37 of the LT. Act applies the test of "wholly and exclusively for the purposes of business" to all assessee-types, including companies. Where a company maintains vehicles or telephones that are partly for personal use by directors/officers, the personal-use component is not laid out "wholly and exclusively for the purposes of business" and is hence disallowable. Established

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

disallowance of deduction of Rs. 46,00,000/- under section 80IC made by the AO with respect to inter-unit transfer of goods/items from non-eligible units to eligible units. 19

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

In the result, for assessment year 2007-08 the appeal of the assessee as well as Revenue are dismissed

Bench: Shri O.P. Kant & Shri Kuldip Singh, Judicialmember

disallowance of ₹ 11,95,19,889/-in terms of section 14A of the Act read with Rule 8D of the ‘Rules

M/S RELIGARE FINVEST LTD.,,NEW DELHI vs. DCIT, NEW DELHI

In the result, for assessment year 2007-08 the appeal of the assessee as well as Revenue are dismissed

Bench: Shri O.P. Kant & Shri Kuldip Singh, Judicialmember

disallowance of ₹ 11,95,19,889/-in terms of section 14A of the Act read with Rule 8D of the ‘Rules

ACIT,, NEW DELHI vs. M/S RELIGARE FINVEST LTD.,, NEW DELHI

In the result, for assessment year 2007-08 the appeal of the assessee as well as Revenue are dismissed

Bench: Shri O.P. Kant & Shri Kuldip Singh, Judicialmember

disallowance of ₹ 11,95,19,889/-in terms of section 14A of the Act read with Rule 8D of the ‘Rules

RELIGARE FINVEST LTD,NEW DELHI vs. ADDL.CIY, RANGE-21, NEW DELHI

In the result, for assessment year 2007-08 the appeal of the assessee as well as Revenue are dismissed

Bench: Shri O.P. Kant & Shri Kuldip Singh, Judicialmember

disallowance of ₹ 11,95,19,889/-in terms of section 14A of the Act read with Rule 8D of the ‘Rules

HERO MOTO CORP LTD.,NEW DELHI vs. NEAC, DELHI

Bench: Shri Kul Bharat & Shri Prashant Maharishi(Through Video Conferencing)

19. That the assessing officer erred on facts and in law in disallowing depreciation to the extent of Rs.6,25,17,452, out of total depreciation of Rs. 10,71,72,776 claimed on computer software at the rate of 60% on the ground that such Software was an intangible asset eligible for depreciation at normal rate of 25% applicable

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 32 of the Act. Re: Ad-hoc disallowance of support service fees and reimbursement of expenses 3. That the CIT(A) erred on facts and in law in upholding ad-hoc disallowance to the extent :: Rs. 19

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 32 of the Act. Re: Ad-hoc disallowance of support service fees and reimbursement of expenses 3. That the CIT(A) erred on facts and in law in upholding ad-hoc disallowance to the extent :: Rs. 19

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 32 of the Act. Re: Ad-hoc disallowance of support service fees and reimbursement of expenses 3. That the CIT(A) erred on facts and in law in upholding ad-hoc disallowance to the extent :: Rs. 19

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 32 of the Act. Re: Ad-hoc disallowance of support service fees and reimbursement of expenses 3. That the CIT(A) erred on facts and in law in upholding ad-hoc disallowance to the extent :: Rs. 19

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 32 of the Act. Re: Ad-hoc disallowance of support service fees and reimbursement of expenses 3. That the CIT(A) erred on facts and in law in upholding ad-hoc disallowance to the extent :: Rs. 19

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 32 of the Act. Re: Ad-hoc disallowance of support service fees and reimbursement of expenses 3. That the CIT(A) erred on facts and in law in upholding ad-hoc disallowance to the extent :: Rs. 19

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 32 of the Act. Re: Ad-hoc disallowance of support service fees and reimbursement of expenses 3. That the CIT(A) erred on facts and in law in upholding ad-hoc disallowance to the extent :: Rs. 19

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

section 36(i)(viii) and being satisfied with the submissions made by the assessee allowed the claim. He placed on record documents in support. The Ld. AR also stated that no such disallowance has been made by the Ld. AO in his assessment order for AY 2018-19 and copy of that order was submitted before us. 19

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

section 36(i)(viii) and being satisfied with the submissions made by the assessee allowed the claim. He placed on record documents in support. The Ld. AR also stated that no such disallowance has been made by the Ld. AO in his assessment order for AY 2018-19 and copy of that order was submitted before us. 19

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

section 36(i)(viii) and being satisfied with the submissions made by the assessee allowed the claim. He placed on record documents in support. The Ld. AR also stated that no such disallowance has been made by the Ld. AO in his assessment order for AY 2018-19 and copy of that order was submitted before us. 19