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

26. We have heard the Ld. Representative of the parties and perused the records. It is observed that before the Ld. CIT(A) it was vehemently argued by the assessee duly supported by judicial pronouncements that disallowance cannot exceed the amount of exempt income earned during the year. The Ld. CIT(A) has accepted this argument of the assessee

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

26. We have heard the Ld. Representative of the parties and perused the records. It is observed that before the Ld. CIT(A) it was vehemently argued by the assessee duly supported by judicial pronouncements that disallowance cannot exceed the amount of exempt income earned during the year. The Ld. CIT(A) has accepted this argument of the assessee

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

26. We have heard the Ld. Representative of the parties and perused the records. It is observed that before the Ld. CIT(A) it was vehemently argued by the assessee duly supported by judicial pronouncements that disallowance cannot exceed the amount of exempt income earned during the year. The Ld. CIT(A) has accepted this argument of the assessee

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

26. We have heard the Ld. Representative of the parties and perused the records. It is observed that before the Ld. CIT(A) it was vehemently argued by the assessee duly supported by judicial pronouncements that disallowance cannot exceed the amount of exempt income earned during the year. The Ld. CIT(A) has accepted this argument of the assessee

HALDIA COKE AND CHEMICALS PVT. LTD.,CHENNAI vs. DCIT CIRCLE 11(1), NEW DELHI

In the result, the appeal filed by the assessee is allowed for statistical purposes only

Bench: Shri C.M. Garg & Dr. B.R.R. Kumarassessment Year: 2015-16 Haldia Code & Chemicals Pvt. Ltd., Vs. Dcit, No.18/3, Sigapi Achi Building, Circle-11(1), 4Th Floor, Rukmini Lakshmipathi Road, New Delhi. Egmore, Chennai, Tamilnadu – 600 004. Pan: Aabch5389P (Appellant) (Respondent) Assessee By : Shri R. Sivaraman, Advocate Revenue By : Shri Anuj Garg, Sr. Dr Date Of Hearing : 08.02.2023 Date Of Pronouncement : 13.02.2023 Order

section 14A of the Income-tax Act, 1961 (for short ‘the Act’) and without prejudice to the above, justify the interest payment u/s 36(1)(iii). Assessee responded that assessee has made investment in the subsidiary companies; that investment in mutual funds of Rs.3,00,000/- has also been done; that assessee has not received any dividend income during

M/S. MENORA DEVELOPERS & INFRASTRUCTURES PVT. LTD.,,NEW DELHI vs. ITO, NEW DELHI

In the result appeal of the assessee as well as of the revenue are dismissed

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishiito, Vs. Menora Developers & Ward-16(4), Infrastructure Pvt. Ltd, Room No. 304, Cr Building, A-60, Naraina Industrial Ip Estate, New Delhi Area-I, New Delhi Pan: Aafcm9587Q (Appellant) (Respondent) Menora Developers & Vs. Ito, Infrastructure Pvt. Ltd, Ward-16(4), A-60, Naraina Industrial Area-I, Room No. 304, Cr Building, New Delhi Ip Estate, New Delhi Pan: Aafcm9587Q (Appellant) (Respondent)

disallowed. If the plea of the assessee is accepted that the interest-free advances made to the sister concerns for non-business purposes was out of its own funds in the form of capital introduced in business, that again will show a camouflage by the assessee as at the time of raising of loan, the assessee will show the figures

ITO, NEW DELHI vs. M/S. MENORA DEVELOPERS & INFRASTRUCTURE PVT. LTD., NEW DELHI

In the result appeal of the assessee as well as of the revenue are dismissed

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishiito, Vs. Menora Developers & Ward-16(4), Infrastructure Pvt. Ltd, Room No. 304, Cr Building, A-60, Naraina Industrial Ip Estate, New Delhi Area-I, New Delhi Pan: Aafcm9587Q (Appellant) (Respondent) Menora Developers & Vs. Ito, Infrastructure Pvt. Ltd, Ward-16(4), A-60, Naraina Industrial Area-I, Room No. 304, Cr Building, New Delhi Ip Estate, New Delhi Pan: Aafcm9587Q (Appellant) (Respondent)

disallowed. If the plea of the assessee is accepted that the interest-free advances made to the sister concerns for non-business purposes was out of its own funds in the form of capital introduced in business, that again will show a camouflage by the assessee as at the time of raising of loan, the assessee will show the figures

ASIA SATELLITE TELECOMMUNICATIONS CO. LTD. vs. DIRECTOR OF INCOME TAX

The appeal of the Revenue is dismissed

disallowing provisions thereof would be inapplicable. 23. As regards the levy of interest under Sections 234A and 234B was concerned, the Tribunal held that the appellant would be liable to pay interest under Section 234A. However, with regard to levy of interest under Section 234B, the Tribunal held that if the receipt of income by the appellant was of such

HALDIA COKE AND CHEMICALS PVT. LTD.,CHENNAI vs. ADDL. CIT, RANGE- 11, NEW DELHI

In the result, the appeal of the assessee is allowed for statistical purposes

section 14A of the Income-tax Act, 1961 (for short ‘the Act’) and without prejudice to the above, justify the interest payment u/s 36(1)(iii). Assessee responded that assessee has made investment in the subsidiary companies; that investment in mutual funds of Rs.3,00,000/- has also been done; that assessee has not received any dividend income during

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)

disallowances have been made contrary to the dictum laid down by various Courts. 12. Each of the aforesaid contention is briefly elaborated hereunder: Re (a): Assessment completed without issuance of show cause notice cum draft assessment order prior to draft order passed under section 144C(1) of the Act and without providing opportunity of hearing

SMT. DEEPTI AGARWAL,NEW DELHI vs. ACIT, NEW DELHI

In the result, the appeal filed by the assessees is partly allowed

Bench: Shri R.K. Panda & Shri Kuldip Singhassessment Year: 2011-12 Deepti Agarwal, Vs Acit, C/O M/S Pra Taxindia, Circle-53(1), D-28, South Extension, Part-I, New Delhi. New Delhi. Pan: Aampa0573C (Appellant) (Respondent) Assessee By : Shri Rakesh Gupta & Shri Somil Aggarwal, Advocates Revenue By : Ms Ashima Neb, Sr. Dr Date Of Hearing : 17.07.2019 Date Of Pronouncement : 25.07.2019 Order Per R.K. Panda, Am: This Appeal Filed By The Assessee Is Directed Against The Order Dated 18Th July, 2016 Of The Cit(A)-18, New Delhi, Relating To Assessment Year 2011-12. 2. The Grounds Of Appeal No.1 & 2 Raised By The Assessee Read As Under:-

disallowance could be made u/s 36(1)(iii) on account of the said investment in the industrial plot in view of the decision of the Hon'ble Bombay High Court in the case of Reliance Utilities & Power Ltd. (supra). The grounds of appeal No.1 and 2 by the assessee are, therefore, allowed. 15. The ld. counsel for the assessee

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

iii. Assessee to reimburse the sum of operating cost of the JVC. Thus, according to the aforesaid terms of the MOU, the assessee made the following payment: (i) retainership fees of Rs. 3.3 crores to Percept Finserve P Ltd.(unrelated party), for media management and marketing services. (ii) reimbursed the operating expenses of SIEMCL amounting to Rs.49,32,507/-. Assessing

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

iii. Assessee to reimburse the sum of operating cost of the JVC. Thus, according to the aforesaid terms of the MOU, the assessee made the following payment: (i) retainership fees of Rs. 3.3 crores to Percept Finserve P Ltd.(unrelated party), for media management and marketing services. (ii) reimbursed the operating expenses of SIEMCL amounting to Rs.49,32,507/-. Assessing

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

iii. Assessee to reimburse the sum of operating cost of the JVC. Thus, according to the aforesaid terms of the MOU, the assessee made the following payment: (i) retainership fees of Rs. 3.3 crores to Percept Finserve P Ltd.(unrelated party), for media management and marketing services. (ii) reimbursed the operating expenses of SIEMCL amounting to Rs.49,32,507/-. Assessing

RICHMOND EDUCATIONAL SOCIETY,NOIDA vs. DCIT/ACIT CENTRAL CIRCLE, GHAZIABAD, GHAZIABAD

In the result, the appeal of the Assessee is allowed

disallowance of income would not arise. In other words, once\nthe registration is withdrawn, then the expression provided in Section\n13(1)(c) of the Act that such part of the diverted income shall get\ntaxed becomes otiose. That situation would never arise since the entire\nexemption would be denied once the registration is cancelled. Hence we\nare convinced that

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 of Rs 1

DCIT, NEW DELHI vs. M/S NIRALA HOUSING PVT. LTD.,, 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 of Rs 1

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 of Rs 1

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 of Rs 1