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

1) of the Act.” 3.17. Accordingly, it is submitted that the facts in instant case are similar to those in case of Woodword Governor (Supra) and thus are distinguishable with the judgment of Indian Molasses Company (supra). Non-Applicability of Instructions No. 3/2010 3.18. Ld. AO placed reliance on the Instruction No. 3/2010 dated 23-03-2010 issued by CBDT

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

1) of the Act.” 3.17. Accordingly, it is submitted that the facts in instant case are similar to those in case of Woodword Governor (Supra) and thus are distinguishable with the judgment of Indian Molasses Company (supra). Non-Applicability of Instructions No. 3/2010 3.18. Ld. AO placed reliance on the Instruction No. 3/2010 dated 23-03-2010 issued by CBDT

EBRO INDIA PVT.LTD. ,DELHI vs. ACIT CIRCLE-7(1), DELHI

In the result, the ground no 4 raised by the assessee is allowed

Bench: SHRI S.RIFAUR RAHMAN (Accountant Member), SHRI YOGESH KUMAR U.S. (Accountant Member)

1) of the Act proceeded to treat the aforesaid sum of Rs.134.99 crores as unexplained credit under section 68 of the Act. While making the said addition, the NFAC vaguely alleged that the assessee has not filed the requisite details/ documentary evidence to establish the nature and source of credit in the form of share capital, nor it is proved

LENIENT CONSULTANTS PVT LTD,DELHI vs. DCIT,CENTRAL CIRCLE-2, NOIDA

In the result, the appeal of the Assessee is partly allowed\nas indicated above

254\n5.\nHon'ble Delhi High Court in case of PCIT vs. MDLR Hotels Pvt. Ltd.\nITA 593/2023 (30.07.2024) approving ITAT impugned order on sec.\n153D.\n6.\nHon'ble Delhi High Court in case of Vinod Solanki vs. ACIT W.P.\n(C) 4196/2002 (14.08.2024) on issue of quality of\nsanction/approval u/s 151 and sec. 153D.\n7.\nHon'ble Delhi High

DIRECTOR OF INCOME TAX (EXEMPTION) vs. AIPECCS SOCIETY

section 10(23C)(vi) of the Act, we must also add that the prescribed authority would also necessarily have to examine the manner in which the affairs of the university or an educational institution have been conducted in the past for the purposes of considering whether the Assessee qualifies the threshold requirement of Section

TECHNOLOGIES LTD) vs. ACIT

Appeals are allowed

1,03,47,200/-, it claimed a deduction of the aforementioned lease rent i.e. Rs. 77,98,042/-, as revenue expenditure. 5.4. The AO, vide order dated 30.12.2010, passed under Section 143(3) of the Act, assessed the appellant/assessee‟s taxable income at Rs. 36,28,88,570/-, and while doing so, he disallowed the deduction claimed towards lease rent

TECHNOLOGIES LTD) vs. ACIT

Appeals are allowed

1,03,47,200/-, it claimed a deduction of the aforementioned lease rent i.e. Rs. 77,98,042/-, as revenue expenditure. 5.4. The AO, vide order dated 30.12.2010, passed under Section 143(3) of the Act, assessed the appellant/assessee‟s taxable income at Rs. 36,28,88,570/-, and while doing so, he disallowed the deduction claimed towards lease rent

TECHNOLOGIES LTD) vs. ACIT

Appeals are allowed

1,03,47,200/-, it claimed a deduction of the aforementioned lease rent i.e. Rs. 77,98,042/-, as revenue expenditure. 5.4. The AO, vide order dated 30.12.2010, passed under Section 143(3) of the Act, assessed the appellant/assessee‟s taxable income at Rs. 36,28,88,570/-, and while doing so, he disallowed the deduction claimed towards lease rent

MARUTI SUZUKI INDIA LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result, all the three appeals of the assessee are allowed as indicated above and the appeal of Revenue is partly allowed

Bench: Shris.Rifaur Rahman & Shri Vimal Kumar

254 (SC)  Rotork Controls India (P) Ltd. vs CIT: 314 ITR 62 (SC)  Calcutta Discount Co. Ltd.: 37 ITR 1 (SC)  Metal Box (P) Limited (1969): 73 ITR 53 (SC)  United Commercial Bank vs. CIT 240 ITR 355 (SC)  Bharat Earth Movers: 245 ITR 428 (SC)  Kelvinator of India Ltd. reported in 256 ITR 1 confirmed

DCIT, NEW DELHI vs. M/S. MARUTI SUZUKI INDIA LTD., NEW DELHI

In the result, all the three appeals of the assessee are allowed as indicated above and the appeal of Revenue is partly allowed

Bench: Shris.Rifaur Rahman & Shri Vimal Kumar

254 (SC)  Rotork Controls India (P) Ltd. vs CIT: 314 ITR 62 (SC)  Calcutta Discount Co. Ltd.: 37 ITR 1 (SC)  Metal Box (P) Limited (1969): 73 ITR 53 (SC)  United Commercial Bank vs. CIT 240 ITR 355 (SC)  Bharat Earth Movers: 245 ITR 428 (SC)  Kelvinator of India Ltd. reported in 256 ITR 1 confirmed

NEW HOLLAND TRACTORS (INDIA) PRIVATE LIMITED

254, CIT versus Bilahari Investment (P) Limited, (2008) 299 ITR 1 and JK Industries versus Union of India, (2008) 297 ITR 176 on the matching concept. 10. When we apply the aforesaid legal principles to the factual matrix of the present case, it has to be held that the decision of the Tribunal affirming the orders of the tax authorities

RATIONAL BUSINESS CORPORATION PVT LTD,SONIPAT vs. DCIT,CIRCLE-19(1), DELHI

Appeals are hereby dismissed

Bench: Shrimahavir Singh, Hon’Ble & Shrisanjay Awasthiआ.अ.सं/.I.T.A Nos.4402 & 4403/Del/2025 िनधा"रणवष"/Assessment Years: 2018-19 & 2019-20 बनाम Rational Business Corporation Dcit, Private Limited, Vs. Circle 19(1), C.R. Building, Bahalgarh Chowk, Delhi, Sonepat Road, I.P. Estate, New Delhi. Bahalgarh (73), Sonipat. Pan No.Aadcr1837J अपीलाथ" Appellant ""यथ"/Respondent

disallowance of the deduction, even if the payment was made before the due date for filing the ROI. We need to remind ourselves that this is exactly the case in the present appeal. The judgment reinforced the distinction between employer and employee contributions. While an employer’s contributions could be governed by section 43B of the Act, employees’ contributions

RATIONAL BUSINESS CORPORATION PVT LTD,SONIPAT vs. DCIT CIRCLE-19(1), DELHI

Appeals are hereby dismissed

Bench: Shrimahavir Singh, Hon’Ble & Shrisanjay Awasthiआ.अ.सं/.I.T.A Nos.4402 & 4403/Del/2025 िनधा"रणवष"/Assessment Years: 2018-19 & 2019-20 बनाम Rational Business Corporation Dcit, Private Limited, Vs. Circle 19(1), C.R. Building, Bahalgarh Chowk, Delhi, Sonepat Road, I.P. Estate, New Delhi. Bahalgarh (73), Sonipat. Pan No.Aadcr1837J अपीलाथ" Appellant ""यथ"/Respondent

disallowance of the deduction, even if the payment was made before the due date for filing the ROI. We need to remind ourselves that this is exactly the case in the present appeal. The judgment reinforced the distinction between employer and employee contributions. While an employer’s contributions could be governed by section 43B of the Act, employees’ contributions

PRAGATI POWER CORPORATION LTD,NEW DELHI vs. ACIT, CIRCLE 20(1), NEW DELHI

In the result, the appeal filed by the assessee is partly allowed as indicated above

Bench: SHRI S.RIFAUR RAHMAN (Accountant Member), SHRI SUDHIR PAREEK (Judicial Member)

disallowance of deduction claimed u/s 80IA of the Act by the assessing officer is not proper. Accordingly, the ground raised by the assessee is allowed. 31. With regard to ground No.7 the relevant facts are, during the assessment proceeding, Assessing Officer vide notice dated 17.03.2021 issued u/s 142(1) of the Act observed that the net loss on account

ADDL.CIT, SPECIAL RANGE-7, NEW DELHI vs. PTC INDIA FINANCIAL SERVICES LTD., NEW DELHI

In the result, appeal is dismissed

Bench: Shri Saktijit Dey, Vice- & Shri N.K. Billaiyaassessment Year: 2015-16 With Assessment Year: 2016-17 Ptc India Financial Services Vs. Addl. Cit, Ltd., Special Range-7, Telephone Exchange Building, New Delhi 8, Bikaji Cama Place, Delhi-110066 Pan :Aaecp0501C (Appellant) (Respondent) With Assessment Year: 2015-16 With Assessment Year: 2016-17 Addl. Cit, Vs. Ptc India Financial Services Special Range-7, Ltd., New Delhi 2Nd Floor, Nbcc Tower, 15, Bikaji Cama Place, Delhi-110066 Pan :Aaecp0501C (Appellant) (Respondent)

1) of the Act.” 3.17. Accordingly, it is submitted that the facts in instant case are similar to those in case of Woodword Governor (Supra) and thus are distinguishable with the judgment of Indian Molasses Company (supra). Non-Applicability of Instructions No. 3/2010 3.18. Ld. AO placed reliance on the Instruction No. 3/2010 dated 23-03-2010 issued by CBDT

ADDL. CIT, SPECIAL RANGE- 7, NEW DELHI vs. PTC INDIA FINANCIAL SERVICES LTD, NEW DELHI

In the result, appeal is dismissed

Bench: Shri Saktijit Dey, Vice- & Shri N.K. Billaiyaassessment Year: 2015-16 With Assessment Year: 2016-17 Ptc India Financial Services Vs. Addl. Cit, Ltd., Special Range-7, Telephone Exchange Building, New Delhi 8, Bikaji Cama Place, Delhi-110066 Pan :Aaecp0501C (Appellant) (Respondent) With Assessment Year: 2015-16 With Assessment Year: 2016-17 Addl. Cit, Vs. Ptc India Financial Services Special Range-7, Ltd., New Delhi 2Nd Floor, Nbcc Tower, 15, Bikaji Cama Place, Delhi-110066 Pan :Aaecp0501C (Appellant) (Respondent)

1) of the Act.” 3.17. Accordingly, it is submitted that the facts in instant case are similar to those in case of Woodword Governor (Supra) and thus are distinguishable with the judgment of Indian Molasses Company (supra). Non-Applicability of Instructions No. 3/2010 3.18. Ld. AO placed reliance on the Instruction No. 3/2010 dated 23-03-2010 issued by CBDT

PTC INDIA FINANCIAL SERVICES LTD.,NEW DELHI vs. ADDL.CIT, SPECIAL RANGE-7, NEW DELHI

In the result, appeal is dismissed

Bench: Shri Saktijit Dey, Vice- & Shri N.K. Billaiyaassessment Year: 2015-16 With Assessment Year: 2016-17 Ptc India Financial Services Vs. Addl. Cit, Ltd., Special Range-7, Telephone Exchange Building, New Delhi 8, Bikaji Cama Place, Delhi-110066 Pan :Aaecp0501C (Appellant) (Respondent) With Assessment Year: 2015-16 With Assessment Year: 2016-17 Addl. Cit, Vs. Ptc India Financial Services Special Range-7, Ltd., New Delhi 2Nd Floor, Nbcc Tower, 15, Bikaji Cama Place, Delhi-110066 Pan :Aaecp0501C (Appellant) (Respondent)

1) of the Act.” 3.17. Accordingly, it is submitted that the facts in instant case are similar to those in case of Woodword Governor (Supra) and thus are distinguishable with the judgment of Indian Molasses Company (supra). Non-Applicability of Instructions No. 3/2010 3.18. Ld. AO placed reliance on the Instruction No. 3/2010 dated 23-03-2010 issued by CBDT

PTC INDIA FINANCIAL SERVICES LTD,NEW DELHI vs. ADDL. CIT, SPECIAL RANGE- 7, NEW DELHI

In the result, appeal is dismissed

Bench: Shri Saktijit Dey, Vice- & Shri N.K. Billaiyaassessment Year: 2015-16 With Assessment Year: 2016-17 Ptc India Financial Services Vs. Addl. Cit, Ltd., Special Range-7, Telephone Exchange Building, New Delhi 8, Bikaji Cama Place, Delhi-110066 Pan :Aaecp0501C (Appellant) (Respondent) With Assessment Year: 2015-16 With Assessment Year: 2016-17 Addl. Cit, Vs. Ptc India Financial Services Special Range-7, Ltd., New Delhi 2Nd Floor, Nbcc Tower, 15, Bikaji Cama Place, Delhi-110066 Pan :Aaecp0501C (Appellant) (Respondent)

1) of the Act.” 3.17. Accordingly, it is submitted that the facts in instant case are similar to those in case of Woodword Governor (Supra) and thus are distinguishable with the judgment of Indian Molasses Company (supra). Non-Applicability of Instructions No. 3/2010 3.18. Ld. AO placed reliance on the Instruction No. 3/2010 dated 23-03-2010 issued by CBDT