COMMISSIONER OF INCOME TAX

disallowed. The Assessing officer observed that printing machines were highly sophisticated and computerized and could be operated and managed without employing more than two or three persons. The expenses incurred by the assessee with regard to Unit Nos. 2 & 3 were mainly payments made for purchase of ink and consumables. The workers employed in operating Unit Nos. 2 & 3 were

VAKS MULTIPLE SERVICE PRIVATE LIMITED,FARIDABAD vs. ACIT, FARIDABAD

In the result, Miscellaneous Application of the Revenue is dismissed

Bench: S. Rifaur Rahman & Shri Yogesh Kumar U.S.Vaks Multiple Service Vs Acit Plot No. 58-59, D L F Main Cgo Complex, Nh 4, Market, Sector-11, Faridabad, Nit, Faridabad, Haryana Haryana Pan: Aaecv4819M Appellant Respondent Assessee By Sh. Ankit Gupta, Ca Revenue By Sh. Dheeraj Kumar Jain, Sr. Dr Date Of Hearing 03/09/2025 Date Of Pronouncement 17/09/2025 Order Per Yogesh Kumar, U.S. Jm: The Present Appeal Is Filed By The Assessee Against The Order Of Ld. Commissioner Of Income Tax (Appeals/ National Faceless Appeal Centre (‘Ld. Cit(A)/Nfac’ For Short), New Delhi Dated 17/03/2025 For The Assessment Year 2019-20. 2. Brief Facts Of The Case Are That, The Assessee Filed Its Return Of Income For The A.Y.2019-20 Having Gross Total Income Of Rs. 79,44,337/-. During The Processing Of Itr U/S. 143(1)(A), The Cpc Had Disallowed Rs. 33,02,357/- On Account Of Delay In Payment Of Employees Share Of Esi & Pf. Being Aggrieved With The Aforesaid Disallowance Of Rs. 33,02,357/-, The Assessee Filed An Appeal Before National Faceless Appeal Centre (Nfac). The Cit (Nfac) Vide Order Vaks Multiple Service Pvt. Ltd. Vs. Acit

Section 254(2). Admittedly, when the judgment of the Tribunal was passed, it was based on the law binding on the Tribunal and authorities below by series of judgments of the Hon’ble Jurisdictional High Court and other High Courts as noted above. Thus the decision of the Tribunal was rendered, prior to the judgment of the Hon’ble Supreme

TELETUBE ELECTRONICS LTD

The appeal of the Assessee is allowed

254(2) of the Act before the ITAT praying for some directions to the AO while computing capital gains as directed in the judgement of the ITAT. In the application, 2015:DHC:8039-DB ITA Nos. 38 of 2002 & 132 of 2002 Page 12 of 32 the Assessee contended that the value of the business was determined

TELETUBE ELECTRONICS LTD

The appeal of the Assessee is allowed

254(2) of the Act before the ITAT praying for some directions to the AO while computing capital gains as directed in the judgement of the ITAT. In the application, 2015:DHC:8039-DB ITA Nos. 38 of 2002 & 132 of 2002 Page 12 of 32 the Assessee contended that the value of the business was determined

HL MALHOTRA AND COMPANY PVT. LTD.

The appeal is disposed of

Section 254(2) of the Act, it would not be proper for this Court to hear and decide the present appeal till the Tribunal decides the rectification application. 10. He further submits that the appellant’s application for production of additional evidence before the Tribunal was not maintainable as the conditions precedent mentioned in Rule 29 of the ITAT Rules

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

2) of the Income Tax Act, 1922 [which was pari materia with the section 37(1) of Income tax Act, 1961....... .......... PTC India Financial Services Ltd. vs. ACIT, ACIT vs. PTC India Financial Services Ltd. & Addl.CIT vs. PTC India Financial Services Ltd. 5.9 Exchange rate is dynamic and fluctuates virtually on day-to-day basis. Hence, if there is gain

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

2) of the Income Tax Act, 1922 [which was pari materia with the section 37(1) of Income tax Act, 1961....... .......... PTC India Financial Services Ltd. vs. ACIT, ACIT vs. PTC India Financial Services Ltd. & Addl.CIT vs. PTC India Financial Services Ltd. 5.9 Exchange rate is dynamic and fluctuates virtually on day-to-day basis. Hence, if there is gain

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

2) of the Income Tax Act, 1922 [which was pari materia with the section 37(1) of Income tax Act, 1961....... .......... PTC India Financial Services Ltd. vs. ACIT, ACIT vs. PTC India Financial Services Ltd. & Addl.CIT vs. PTC India Financial Services Ltd. 5.9 Exchange rate is dynamic and fluctuates virtually on day-to-day basis. Hence, if there is gain

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

2) of the Income Tax Act, 1922 [which was pari materia with the section 37(1) of Income tax Act, 1961....... .......... PTC India Financial Services Ltd. vs. ACIT, ACIT vs. PTC India Financial Services Ltd. & Addl.CIT vs. PTC India Financial Services Ltd. 5.9 Exchange rate is dynamic and fluctuates virtually on day-to-day basis. Hence, if there is gain

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

2. Interest expenditure not directly attributable to any particular income 36,85,740 3. ½% of average investments 62,11,454 Total 98,97,195 Less: Suo motu disallowance by appellant/assessee 7,79,063 DISALLOWANCE 91,18,132 4.3. This propelled the appellant/assessee to carry the matter further, and accordingly, an appeal was preferred with the Tribunal. The Tribunal

TECHNOLOGIES LTD) vs. ACIT

Appeals are allowed

2. Interest expenditure not directly attributable to any particular income 36,85,740 3. ½% of average investments 62,11,454 Total 98,97,195 Less: Suo motu disallowance by appellant/assessee 7,79,063 DISALLOWANCE 91,18,132 4.3. This propelled the appellant/assessee to carry the matter further, and accordingly, an appeal was preferred with the Tribunal. The Tribunal

TECHNOLOGIES LTD) vs. ACIT

Appeals are allowed

2. Interest expenditure not directly attributable to any particular income 36,85,740 3. ½% of average investments 62,11,454 Total 98,97,195 Less: Suo motu disallowance by appellant/assessee 7,79,063 DISALLOWANCE 91,18,132 4.3. This propelled the appellant/assessee to carry the matter further, and accordingly, an appeal was preferred with the Tribunal. The Tribunal

E FACTOR ADVENTURE TOURISM PRIVATE LIMITED,DELHI vs. THE DCIT, CC-13, DELHI

In the result, appeal of the assessee is partly allowed

Bench: Shri Vikas Awasthy& Shri Brajesh Kumar Singhआअसं.3006/धिल्ली/2025(नि.व. 2017-18) E Factor Adventure Tourism P. Ltd., 101 A, Kundan Kutir, Hari Nagar, Ashram, New Delhi 110014 ...... अपीलार्थी/Appellant Pan: Aabce-7871-R बिाम Vs. Deputy Commissioner Of Income Tax, .....प्रनिवादी/Respondent Central Circle-13, New Delhi 110055 अपीलार्थी द्वारा/ Appellant By: Shri S.K Chaturvedi, Chartered Accountant प्रधििािीद्वारा/Respondent By: Shri Om Prakash, Sr. Dr सुिवाई की निथर्थ/ Date Of Hearing : 03/02/2026 घोषणा की निथर्थ/ Date Of Pronouncement : 03/02/2026 आदेश/Order Per Vikas Awasthy, Jm: This Appeal By The Assessee Is Directed Against The Order Of Commissioner Of Income Tax-26, New Delhi [In Short ‘The Cit(A)’] Dated 06.03.2025, For Ay 2017-18 In Proceedings U/S.154 Of The Income Tax Act,1961(Hereinafter Referred To As ‘The Act’).

2 of appeal, has assailed action of the AO u/s.154 of the Act for making disallowance of the amounts of PF/ESI deposited by the assessee beyond due date specified under respective Acts, on the basis of judgment rendered in the case of Checkmate Services P. Ltd. vs. CIT (supra) passed by Hon’ble Supreme Court of India much after completion

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

2)(ii). Therefore, we are inclined to allow the grounds relating to this aspect. 12. With regard to disallowance on the administrative cost, we direct the AO to consider the disallowance only by considering those investments which had actually earned dividend income and we direct accordingly. We respectfully follow the decision of Hon’ble Delhi HC in the case

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

2)(ii). Therefore, we are inclined to allow the grounds relating to this aspect. 12. With regard to disallowance on the administrative cost, we direct the AO to consider the disallowance only by considering those investments which had actually earned dividend income and we direct accordingly. We respectfully follow the decision of Hon’ble Delhi HC in the case

M/S. SHIVALIK PRINTS LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result, assessees’ appeals in ITA nos

Bench: Shri Kul Bharat & Shri Avdhesh Kumar Mishraassessment Year: 2011-12 & Assessment Year: 2012-13

disallowance u/s 80 JJAA of the Act is a legal issue and can be raised at any stage. He submitted that the learned CIT(A) failed to appreciate the fact in right perspective. Further, he reiterated the submissions as made in the brief synopsis. For the sake of clarity the Brief Synopsis is reproduced herein below: “BRIEF SYNOPSIS

SHIVALIK PRINTS LTD.,NEW DELHI vs. JCIT, SPECIAL RANGE-8, NEW DELHI

In the result, assessees’ appeals in ITA nos

Bench: Shri Kul Bharat & Shri Avdhesh Kumar Mishraassessment Year: 2011-12 & Assessment Year: 2012-13

disallowance u/s 80 JJAA of the Act is a legal issue and can be raised at any stage. He submitted that the learned CIT(A) failed to appreciate the fact in right perspective. Further, he reiterated the submissions as made in the brief synopsis. For the sake of clarity the Brief Synopsis is reproduced herein below: “BRIEF SYNOPSIS