M/S. NIRALA HOUSING PVT. LTD.,,NEW DELHI vs. DCIT, NEW DELHI

In the result, all the five appeals are dismissed

Bench: Shri S.K. Yadav & Shri Anadee Nath Misshra

disallowance u/s 14A. He also initiated penalty proceedings u/s 271AAA and 271(l)(c). While adjudicating the appeal filed by the appellant against the assessment order, the additions of Rs 3,75,387 and Rs 10,65,117 were deleted. It is a matter of record that no appeal was filed in respect of the addition

M/S. NIRALA HOUSING PVT. LTD.,,NEW DELHI vs. DCIT, NEW DELHI

In the result, all the five appeals are dismissed

Bench: Shri S.K. Yadav & Shri Anadee Nath Misshra

disallowance u/s 14A. He also initiated penalty proceedings u/s 271AAA and 271(l)(c). While adjudicating the appeal filed by the appellant against the assessment order, the additions of Rs 3,75,387 and Rs 10,65,117 were deleted. It is a matter of record that no appeal was filed in respect of the addition

M/S. NIRALA HOUSING PVT. LTD.,,NEW DELHI vs. DCIT, NEW DELHI

In the result, all the five appeals are dismissed

Bench: Shri S.K. Yadav & Shri Anadee Nath Misshra

disallowance u/s 14A. He also initiated penalty proceedings u/s 271AAA and 271(l)(c). While adjudicating the appeal filed by the appellant against the assessment order, the additions of Rs 3,75,387 and Rs 10,65,117 were deleted. It is a matter of record that no appeal was filed in respect of the addition

INDIA TODAY ONLINE PVT. LTD.,NEW DELHI vs. ITO, WARD- 12(2), NEW DELHI

In the result both the appeals of the assessee are allowed

Bench: Shri Amit Shukla & Shri L.P. Sahuita Nos. 6453 & 6454/Del/2018 Assessment Years 2013-14 & 2014-15

251 ITR 864, holding that CIT(A) has no power to enhance by discovering new source of income not considered by the AO. However, in the present case the income sought to be enhanced was inextricably linked to the issue under consideration. Therefore, it cannot be said that enhancement is being considered by discovering any new source of income

INDIA TODAY ONLINE PVT. LTD.,NEW DELHI vs. ITO, WARD- 12(2), NEW DELHI

In the result both the appeals of the assessee are allowed

Bench: Shri Amit Shukla & Shri L.P. Sahuita Nos. 6453 & 6454/Del/2018 Assessment Years 2013-14 & 2014-15

251 ITR 864, holding that CIT(A) has no power to enhance by discovering new source of income not considered by the AO. However, in the present case the income sought to be enhanced was inextricably linked to the issue under consideration. Therefore, it cannot be said that enhancement is being considered by discovering any new source of income

TRIVENI TURBINE LTD,NOIDA vs. ACIT, CIRCLE 5(3)(1), NOIDA

In the result, the appeal of the assessee is dismissed

Bench: Shri Anubhav Sharma & Shri Krinwant Sahay[Assessment Year: 2018-19]

2,50,000 Unlimited Plus Action (CUPA) 4. Dharithree Trust 12,70,000 50% 6,35,000 5. Tirth Ram Shah 99,49,500 50% 49,74,750 Charitable Trust Total 1,61,58,810 95,76,405 3. The assessing officer and CIT(A) disallowed the deduction claimed by the appellant holding that donations forming part of CSR expenditure

COMMISSIONER OF INCOME TAX vs. HARKARAN DAS VED PAL

The appeal is dismissed

2) of the said Act. 15. The learned counsel for the assessee referred to the decision of the Supreme Court in the case of Sir Shadilal Sugar and General 2008:DHC:3032-DB submit that where a surrender has been made voluntarily and bonafide prior to detection by the department, no penalty under Section 271 (1) (c) would be leviable

HERO MOTOCORP LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result appeal No. 2424/Del/ 2015 filed by the revenue in assessment year 2010-11 is partly allowed

Bench: Shri R. K. Panda & Ms Suchitra Kamble

disallowance made u/s 40(a)(ia) is to be deleted. 14.96. It would be pertinent to point that section 194C was amended by the Finance (2) Act, 2009 w.e.f. 1.10.2009, whereby the definition of “work” was enlarged to include contract for manufacturing or supplying a product according to the requirement or specification of a customer by using material purchased from

HERO MOTOCORP LTD.,,NEW DELHI vs. ADDL.CIT, RANGE-11, NEW DELHI

In the result ground No

Bench: Shri R. K. Panda & Ms Suchitra Kamblei.T.A. No. 6990/Del/2017 (A.Y 2013-14)

2 - Grant of License and Exclusivity ii) ARTICLE 3-No sublicense iii) ARTICLE 9 - Use and Disclosure of Technical Information iv) ARTICLE 13 - Terms of agreement (upto 30.06.2007) v) ARTICLE 21/22 Termination/Effect of Expiry and Termination vi) ARTICLE 25/26 Certain Prohibitions/Maintenance of Secrecy To the same effect are the following clauses placing restrictions on use of knowhow by the assessee

HV METAL ARC PVT. LTD.,NOIDA vs. ACIT, CIRCLE- 11(1), NEW DELHI

In the result, Appeal of the Assessee is treated as partly allowed for statistical purposes

Bench: Shri H.S. Sidhu & Shri Anadee Nath Misshra

disallowance of 2% out of the total expenses of Rs. 37,90,33,493/-, amounting to Rs. 75,80,669/-, was made. (2.1) Aggrieved, the assessee filed an appeal before Ld. CIT(A), who, vide aforesaid order dated 29.12.2017 dismissed the Assessee’s appeal, on the ground that no compliance was made to notices of hearings issued

HERO MOTOCORP LIMITED,NEW DELHI vs. JCIT, NEW DELHI

In the result appeal of the assessee in ITA No

Bench: Sh. I. C. Sudhir & Shri Prashant Maharishihero Motocorp Limited, Jcit, 34, Basant Lok, Vasant Range-1, New Delhi Vs. Vihar, New Delhi Pan: Aaach0812J (Appellant) (Respondent) Dcit, M/S. Hero Moto Corp. Circle-11(1), Ltd., 34, Community Vs. New Delhi Centre, Basant Lok, Vasant Vihar, New Delhi-110057 (Appellant) (Respondent) Dcit, M/S. Hero Moto Corp. Circle-11(1), Ltd., 34, Community

disallowed on the ground of the same being contingent in nature. He further submitted that similar provision for increase in prices as at the end of the year was accepted and allowed in Hero MotoCorp Limited Vs. JCIT & DCIT Vs. Hero MotoCorp Ltd. ITA Nos. 1545/Del/2015 and 2424/Del/2015 (AY 2010-11) ITA No. 1609/Del/2016 and 914/Del/2016 (AY 2011-12) Page

ASHISH DHAM,DELHI vs. DCIT, NEW DELHI

In the result, Assessee’s appeal is treated as partly allowed for statistical

Bench: Shri H.S. Sidhu & Shri Anadee Nath Misshra

2 ld. Assessing Officer without appreciating the correct facts of the case and giving proper opportunity of being heard is not justified in law and facts and circumstances of the case in making the addition of Rs. 12,52,000/- Page 3 of 11 ITA No.-1953/Del/2016. Ashish Dham. under section 69 of the I.T. Act on account

HERO FINCORP LIMITED,NEW DELHI vs. ACIT, CIRCLE 11(1), DELHI, C.R. BUILDING

Bench: Shri Mahavir Singh, Vice Presdient (), Shri Satbeer Singh Godara & Shri Brajesh Kumar Singhआ.अ.सं/.I.T.A No.2542/Del/2024 निर्धारणवर्ष/Assessment Year:2017-18 Hero Fincop Ltd., 34 Community Centre, Basant Lok, Vasant Vihar, New Delhi-110057 बनाम Vs. Assistant Commissioner Of Income Tax, Circle-11(1) C. R. Building, New Delhi-110002 अपीलार्थी Appellant प्रत्यर्थी/Respondent Pan:Aaach0157J Assessee By Shri Rohit Jain, Adv., Shri Deepesh Jain, Adv. & Shri Himanshu Aggarwal Adv. Revenue By Ms. Pooja Swaroop, Cit(Dr) सुनवाईकीतारीख / Date Of Hearing: 14.01.2026 उद्घोषणाकीतारीख/Pronouncement On 16.01.2026 आदेश /Order Per Brajesh Kumar Singh, Am, The Assessee Is Engaged In The Business Of ‘Hire Purchase Leasing & Finance'. This Appeal Is Filed By The Assessee Against The Order Of National Faceless Appeal Center (Nfac)/(First Appellate Authority Hereinafter Referred As “Faa”), Delhi Dated 27.03.2024 Arising Out Of Assessment Order U/S 143(3) Of The Act Dated 29.12.2019For The Assessment Year 2017-18. 2. The Assessee Has Raised Following Grounds Of Appeal: “Disallowance Of Provision For Collection Charges -Rs. 9,75,00,000/-

disallowance of provision for collection charges amounting to Rs.9.75,00,000 as not adjudicated', thereby abdicating the statutory mandate of section 251(1) of the Income tax Act, 1961 ("the Act"). 2

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 made under Rule – 8D(2)(ii) is bad as the assessee had enough interest free funds available. Each of the aforesaid contention is explained in detail below. Section 14A is not applicable in case of bank when the investments are held as stock-in-trade: It is submitted that the investment in PTCs is made by the assessee

INTERGLOBE TECHNOLOGY QUOTIENT PRIVATE LIMITED,NEW DELHI vs. ASSISTANT COMMISSIONER CIRCLE 10(1), NEW DELHI

Bench: Shri M. Balaganesh & Shri Anubhav Sharma[Assessment Year: 2020-21

251(2) of the Act. 1.3. That the CIT(A) erred in not quashing the assessment order dated 22.09.2022 passed without providing opportunity of personal hearing, in violation of mandatory scheme of section 144B of the Act and in gross violation of principles of natural justice. Re: Disallowance

DLF LTD.,NEW DELHI vs. ADDL. CIT, NEW DELHI

Bench: Shri A.T. Varkey & Shri Prashant Maharishi

section 14A can be invoked for disallowance of expenditure. In that decision special bench of ITAT has considered all the arguments advanced before us and therefore in view of this decision these arguments are rejected. However, admittedly some expenditure is required to be disallowed as assesse himself has stated and made on its own some disallowance

ACIT, NEW DELHI vs. M/S DLF LTD., NEW DELHI

Bench: Shri A.T. Varkey & Shri Prashant Maharishi

section 14A can be invoked for disallowance of expenditure. In that decision special bench of ITAT has considered all the arguments advanced before us and therefore in view of this decision these arguments are rejected. However, admittedly some expenditure is required to be disallowed as assesse himself has stated and made on its own some disallowance

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)

251 CTR 290 In view of the above, it is submitted that since deduction under sections 80IA of the Act is a deduction admissible for a certain term, the question whether or not the statutory conditions precedent to the admissibility thereof (including the question separate books of accounts are maintained and the basis of computing sales) are fulfilled