DCIT, NEW DELHI vs. M/S. GUJARAT GUARDIAN LTD., NEW DELHI

In the result, appeal filed by the revenue against the direction of the Ld

Bench: Shri S.K.Yadav & Shri Prashant Maharishim/S. Guajarat Guardian Ltd, Vs. Dcit, 4-7/C, Dda Shopping Centre, Circle-12(1), (Now Circle- New Friends Colony, 10(2), New Delhi Cr Building, Ip Estate, Pan: Aaacg1622K New Delhi (Appellant) (Respondent) Dcit, Vs. M/S. Guajarat Guardian Ltd, Circle-12(1), (Now Circle-10(2), 4-7/C, Dda Shopping Cr Building, Ip Estate, Centre, New Delhi New Friends Colony, New Delhi Pan: Aaacg1622K (Appellant) (Respondent)

disallowed the same treating the same as capital expenditure. The Ld. DRP also held that entire amount of Rs. 5 853 5098 to be capital in nature and observed that the appellant had claimed depreciation at the rate of 15% amounting to Rs. 81,94,914/– on the said expenditure. The Ld. DRP did not noticed that assessee had bifurcated

DCIT, CIRCLE-20(1), NEW DELHI vs. PRIAPUS DEVELOPERS PRIVATE LIMITED, NEW DELHI

Bench: Shri Challa Nagendra Prasad & Shri Pradip Kumar Kedia

Section 14A of the Act, the assessee submitted that it has however suo motu disallowed an estimated amount of Rs.38,70,249

PERNOD RICARD INDIA PVT. LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result, the recalled matter of the appeal in ITA No

Bench: Shri Amit Shukla & Shri O.P. Kant

disallowance has already been the restored to the file of the Assessing Officer and this alternative claim may also be filed before the Assessing Officer and there is no requirement to raise this issue by way of additional ground before the Tribunal. 5.2 We have heard the rival submission and perused the relevant metal on record. As all the facts

PERNOD RICARD INDIA PVT. LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result, the recalled matter of the appeal in ITA No

Bench: Shri Amit Shukla & Shri O.P. Kant

disallowance has already been the restored to the file of the Assessing Officer and this alternative claim may also be filed before the Assessing Officer and there is no requirement to raise this issue by way of additional ground before the Tribunal. 5.2 We have heard the rival submission and perused the relevant metal on record. As all the facts

PERNOD RICARD INDIA PVT. LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result, the recalled matter of the appeal in ITA No

Bench: Shri Amit Shukla & Shri O.P. Kant

disallowance has already been the restored to the file of the Assessing Officer and this alternative claim may also be filed before the Assessing Officer and there is no requirement to raise this issue by way of additional ground before the Tribunal. 5.2 We have heard the rival submission and perused the relevant metal on record. As all the facts

MUFG BANK LTD,NEW DELHI vs. ACIT (INTERNATIONAL TAXATION) CIRCLE-2(2)(1), NEW DELHI

In the result appeal of the assessee is partly allowed

Bench: Shri Amit Shukla & Shri Prashant Maharishi(Through Video Conferencing) Mufg Bank Ltd, Vs. Acit (International Taxation), 5Th Floor, Worldmark 2, Asset 8, Circle-2(2)(1), Aerocity, Nh-8, New Delhi New Delhi Pan: Aabct3880D (Appellant) (Respondent)

disallowance is called for under that Section. Accordingly, made by the learned assessing officer u/s 14A of the income tax act of ₹ 22,521,366/– is unwarranted. Further, as the assessee is granted relief on the first argument that Section 14 A is not applicable in case of bank when the investments are held as stock in trade, other arguments

THE PR. COMMISSIONER OF INCOME TAX -CENTRAL -1 vs. R.J. CORP. LTD.

The appeal of the assessee is allowed

Bench: HON'BLE MR. JUSTICE V. KAMESWAR RAO,HON'BLE MR. JUSTICE VINOD KUMAR

disallowance under the said section shall apply and shall be deemed to have always applied even in a case where the Signed By:PRAMOD KUMAR VATS Signing Date:17.12.2025 17:49:40 Signature Not Verified ITA 743/2025 Page 14 of 18 exempt income has not accrued or arisen or has not been received during a particular year. The amendments which

DCIT, NEW DELHI vs. M/S. RIVIERA HOME FURNISHING (P) LTD., DELHI

In the result, the appeal of the assessee is partly allowed and the appeal of the Revenue is dismissed

Bench: Sh. H.S. Sidhu & Sh. O.P. Kantassessment Year: 2009-10 M/S. Riviera Home Furnishings Vs. Acit, Range-15, New Delhi Pvt. Ltd., 501, 5Th Floor, Aggarwal Corporate Heights, Netaji Subhash Place, District Centre, Wazirpur, Delhi Pan : Aaacr4448J (Appellant) (Respondent) & Assessment Year: 2009-10 Vs. M/S. Riviera Home Furnishings Dcit, Circle-15(1), Room No. Pvt. Ltd., 501, 5Th Floor, 412, C.R. Building, I.P. Estate, New Delhi Aggarwal Corporate Heights, Netaji Subhash Place, District Centre, Wazirpur, Delhi Pan : Aaacr4448J (Appellant) (Respondent) Assessee By Sh. Ved Jain, Advocate, Sh. Ashish Goel, Ca & Sh. Ashish Chadha, Ca Department By Sh. F.R. Meena, Sr. Dr Date Of Hearing 22.08.2016 Date Of Pronouncement 21.10.2016 Order

249/- from one of the unit eligible under section 10B of the Act. The Assessing Officer further observed that the assessee made investment in shares and earned dividend income of Rs.4,49,521/, which was claimed as exempt under section 10(33) of the Act. The Assessing Officer also observed that the assessee made investment in the unit eligible under

PUNJAB NATIONAL BANK,NEW DELHI vs. ADDL. CIT, NEW DELHI

In the result, assessee’s appeals, namely, ITA Nos

Bench: Shri Prashant Maharishi & Shri K.Narasimha Chary

disallowance under section 14A of the Act in respect of the dividend earned on the shares held as stock in trade, because such shares were held during the business activity of the assessee and it is only by a quirk of fate that when the investee company declared dividend, those shares were held by the assessee, though the assessee

PUNJAB NATIONAL BANK,NEW DELHI vs. ADDL. CIT, NEW DELHI

In the result, assessee’s appeals, namely, ITA Nos

Bench: Shri Prashant Maharishi & Shri K.Narasimha Chary

disallowance under section 14A of the Act in respect of the dividend earned on the shares held as stock in trade, because such shares were held during the business activity of the assessee and it is only by a quirk of fate that when the investee company declared dividend, those shares were held by the assessee, though the assessee

PUNJAB NATIONAL BANK,NEW DELHI vs. ADDL. CIT, NEW DELHI

In the result, assessee’s appeals, namely, ITA Nos

Bench: Shri Prashant Maharishi & Shri K.Narasimha Chary

disallowance under section 14A of the Act in respect of the dividend earned on the shares held as stock in trade, because such shares were held during the business activity of the assessee and it is only by a quirk of fate that when the investee company declared dividend, those shares were held by the assessee, though the assessee

M/S. PUNJAB NATIONAL BANK,NEW DELHI vs. ADDL.CIT, NEW DELHI

In the result, assessee’s appeals, namely, ITA Nos

Bench: Shri Prashant Maharishi & Shri K.Narasimha Chary

disallowance under section 14A of the Act in respect of the dividend earned on the shares held as stock in trade, because such shares were held during the business activity of the assessee and it is only by a quirk of fate that when the investee company declared dividend, those shares were held by the assessee, though the assessee

ACIT, NEW DELHI vs. PUNJAB NATIONAL BANK, NEW DELHI

In the result, assessee’s appeals, namely, ITA Nos

Bench: Shri Prashant Maharishi & Shri K.Narasimha Chary

disallowance under section 14A of the Act in respect of the dividend earned on the shares held as stock in trade, because such shares were held during the business activity of the assessee and it is only by a quirk of fate that when the investee company declared dividend, those shares were held by the assessee, though the assessee

ACIT, NEW DELHI vs. M/S. PUNJAB NATIONAL BANK, NEW DELHI

In the result, assessee’s appeals, namely, ITA Nos

Bench: Shri Prashant Maharishi & Shri K.Narasimha Chary

disallowance under section 14A of the Act in respect of the dividend earned on the shares held as stock in trade, because such shares were held during the business activity of the assessee and it is only by a quirk of fate that when the investee company declared dividend, those shares were held by the assessee, though the assessee

PUNJAB NATIONAL BANK,NEW DELHI vs. ACIT, NEW DELHI

In the result, assessee’s appeals, namely, ITA Nos

Bench: Shri Prashant Maharishi & Shri K.Narasimha Chary

disallowance under section 14A of the Act in respect of the dividend earned on the shares held as stock in trade, because such shares were held during the business activity of the assessee and it is only by a quirk of fate that when the investee company declared dividend, those shares were held by the assessee, though the assessee

PUNJAB NATIONAL BANK,NEW DELHI vs. ACIT, NEW DELHI

In the result, assessee’s appeals, namely, ITA Nos

Bench: Shri Prashant Maharishi & Shri K.Narasimha Chary

disallowance under section 14A of the Act in respect of the dividend earned on the shares held as stock in trade, because such shares were held during the business activity of the assessee and it is only by a quirk of fate that when the investee company declared dividend, those shares were held by the assessee, though the assessee

DCIT, NEW DELHI vs. M/S. PUNJAB NATIONAL BANK, NEW DELHI

In the result, assessee’s appeals, namely, ITA Nos

Bench: Shri Prashant Maharishi & Shri K.Narasimha Chary

disallowance under section 14A of the Act in respect of the dividend earned on the shares held as stock in trade, because such shares were held during the business activity of the assessee and it is only by a quirk of fate that when the investee company declared dividend, those shares were held by the assessee, though the assessee

JINDAL STAINLESS LTD.,HISAR vs. DCIT, NEW DELHI

Accordingly, ground number 2 of the appeal of the learned AO for 2007 – 08 is dismissed

Bench: Smt Diva Singh & Shri Prashant Maharishi

Disallowance of interest decapitalisation [ Ground no 3 of appeal of AO for Ay 2007-08] 30. In appeals of the assessee, Ground number 1 for assessment year 2007 – 08 and ground number 1 and 2 for assessment year 2008 – 09 are challenging the various additions/adjustment made by the learned assessing officer/Transfer Pricing Officer which are also independently challenged

DCIT, NEW DELHI vs. M/S JSL LTD.,, HISAR

Accordingly, ground number 2 of the appeal of the learned AO for 2007 – 08 is dismissed

Bench: Smt Diva Singh & Shri Prashant Maharishi

Disallowance of interest decapitalisation [ Ground no 3 of appeal of AO for Ay 2007-08] 30. In appeals of the assessee, Ground number 1 for assessment year 2007 – 08 and ground number 1 and 2 for assessment year 2008 – 09 are challenging the various additions/adjustment made by the learned assessing officer/Transfer Pricing Officer which are also independently challenged