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

disallowance.” 30. Respectfully following the decision of the coordinate Bench (supra), we allow ground nos.8 to 8.2. 31. With regard to Ground Nos.9 to 9.4 regarding income from trading in mutual funds/shares treated as business income and not as long term/short term capital gain, ld. AR of the assessee submitted as under :- “The appellant, as a consistent practice, has been

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

disallowance.”\n30. Respectfully following the decision of the coordinate Bench (supra), we allow ground\nnos.8 to 8.2.\n\n23\n31. With regard to Ground Nos.9 to 9.4 regarding income from trading in mutual\nfunds/shares treated as business income and not as long term/short term capital gain,\nld. AR of the assessee submitted as under :-\n“The appellant, as a consistent

PR. COMMISSIONER OF INCOME TAX -7 vs. TV TODAY NETWORK LTD.

Appeal is dismissed

264/-. Disallowance u/s 36(1)(va) of the Act on account of late deposit of 2022:DHC:2951-DB ITA 227/2022 Page 10 of 21 employee's contribution to PF 30. With respect to the disallowance of Rs. 43,14,198/- made by AO under Section

SUNBEAM AUTO LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result, the appeal of the assessee in ITA No

Bench: Shri G.S. Pannu, Hon’Dble & Ms. Astha Chandraassessment Year: 2011-12 Sunbeam Auto Ltd. Vs. Addl. Cit, S-323, Panchsheel Park, Range-9, New Delhi 110 017 New Delhi. Pan Aabcs2948F (Appellant) (Respondent) Assessment Year: 2011-12 Addl. Cit Vs. Sunbeam Auto Ltd. Special Range-8, S-323, Panchsheel Park, Room No. 199A, New Delhi 110 017 C.R. Building, Pan Aabcs2948F New Delhi. (Appellant) (Respondent) Assessment Year: 2013-14 Sunbeam Auto Ltd. Vs. Dcit, S-323, Panchsheel Park, Circle-24(2) New Delhi 110 017 New Delhi. Pan Aabcs2948F (Appellant) (Respondent)

264 of the Act in the case of the assessee pertaining to AY 2007-08 to 2010- 11 wherein he held that the subsidy was liable to be reduced from the cost of the assets in terms of Explanation to section 43 stands set aside by the decision of Hon’ble Delhi High Court rendered on 07.12.2017 (copy at page

SUNBEAM AUTO LTD.,NEW DELHI vs. ADDL. CIT, NEW DELHI

In the result, the appeal of the assessee in ITA No

Bench: Shri G.S. Pannu, Hon’Dble & Ms. Astha Chandraassessment Year: 2011-12 Sunbeam Auto Ltd. Vs. Addl. Cit, S-323, Panchsheel Park, Range-9, New Delhi 110 017 New Delhi. Pan Aabcs2948F (Appellant) (Respondent) Assessment Year: 2011-12 Addl. Cit Vs. Sunbeam Auto Ltd. Special Range-8, S-323, Panchsheel Park, Room No. 199A, New Delhi 110 017 C.R. Building, Pan Aabcs2948F New Delhi. (Appellant) (Respondent) Assessment Year: 2013-14 Sunbeam Auto Ltd. Vs. Dcit, S-323, Panchsheel Park, Circle-24(2) New Delhi 110 017 New Delhi. Pan Aabcs2948F (Appellant) (Respondent)

264 of the Act in the case of the assessee pertaining to AY 2007-08 to 2010- 11 wherein he held that the subsidy was liable to be reduced from the cost of the assets in terms of Explanation to section 43 stands set aside by the decision of Hon’ble Delhi High Court rendered on 07.12.2017 (copy at page

ADDL. CIT, NEW DELHI vs. M/S. SUNBEAM AUTO PVT. LTD., NEW DELHI

In the result, the appeal of the assessee in ITA No

Bench: Shri G.S. Pannu, Hon’Dble & Ms. Astha Chandraassessment Year: 2011-12 Sunbeam Auto Ltd. Vs. Addl. Cit, S-323, Panchsheel Park, Range-9, New Delhi 110 017 New Delhi. Pan Aabcs2948F (Appellant) (Respondent) Assessment Year: 2011-12 Addl. Cit Vs. Sunbeam Auto Ltd. Special Range-8, S-323, Panchsheel Park, Room No. 199A, New Delhi 110 017 C.R. Building, Pan Aabcs2948F New Delhi. (Appellant) (Respondent) Assessment Year: 2013-14 Sunbeam Auto Ltd. Vs. Dcit, S-323, Panchsheel Park, Circle-24(2) New Delhi 110 017 New Delhi. Pan Aabcs2948F (Appellant) (Respondent)

264 of the Act in the case of the assessee pertaining to AY 2007-08 to 2010- 11 wherein he held that the subsidy was liable to be reduced from the cost of the assets in terms of Explanation to section 43 stands set aside by the decision of Hon’ble Delhi High Court rendered on 07.12.2017 (copy at page

MODI RUBBER LTD.,NEW DELHI vs. ACIT, CIRCLE- 17(1), NEW DELHI

In the result, Ground no.2 is partly allowed

Bench: Shri Saktijit Dey- & Shri Pradip Kumar Kedia-

disallowance under Section 14A of the Act. The CIT(A) thus declined to interfere. 7.3 The CIT(A) however reversed the addition made to the book profit under Section 115JB of the Act in the light of the decision rendered by the Special Bench in the case of ACIT vs. Vireet Investment Pvt. Ltd., [2017] 82 taxmann.com 415. 8. Further

JCIT, NEW DELHI vs. M/S. DAAWAT FOODS LTD., NEW DELHI

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

Bench: Shri G. S. Pannua N D Shri Challa Nagendra Prasad

Section 14A of the Act. The investments was made out of own funds and not borrowed funds and therefore, the assessee has not made any disallowance out of interest expenditure. The Ld. AR's contentions that under Rule 8D (2)(), what is disallowable is an amount equal to V2 percentage of the average value of investment, the income from which

DAWAT FOODS LTD.,GURGAON vs. ACIT, NEW DELHI

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

Bench: Shri G. S. Pannua N D Shri Challa Nagendra Prasad

Section 14A of the Act. The investments was made out of own funds and not borrowed funds and therefore, the assessee has not made any disallowance out of interest expenditure. The Ld. AR's contentions that under Rule 8D (2)(), what is disallowable is an amount equal to V2 percentage of the average value of investment, the income from which

LIVING MEDIA INDIA LTD.,NEW DELHI vs. ACIT, CIRCLE-15(2), NEW DELHI

The appeal is allowed and the consequences shall follow

Bench: Sh. G. S. Pannu, Hon’Ble & Sh. Anubhav Sharmam/S. Living Media India Ltd. Vs. Acit, K-9, Connaught Circus, Circle-15(2), New Delhi-110001 New Delhi Pan : Aaacl0087H (Appellant) (Respondent)

disallowance under Section 14A of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) directed to be set aside, is erroneous. The assessee had offered Rs. 10,46,264

DCIT CIRCLE-24(2), NEW DELHI vs. SUNBEAM AUTO PVT LTD., NEW DELHI

In the result, the appeal of the assessee in ITA No

Bench: Shri Shamim Yahya & Shri Challa Nagendra Prasada.Yr. : 2012-13 Sunbeam Lightweighting Vs. Dcit, Circle 24(2), Solutions Pvt. Ltd. New Delhi – 110002 (Formerly: Sunbeam Auto Pvt. Ltd), 38/6, K.M. Stone, Delhi-Jaipur Highway, Narsingpur, Gurgaon-122001 (Pan: Aafcn8583K) (Appellant) (Respondent) & Ay 2012-13 Dcit, Circle 24(2), Sunbeam Auto Pvt. Ltd, Room No. 328, Cr Building, Vs. S-323, Panchsheel Park, Ip Estate, New Delhi – 110 017 New Delhi – 2 (Pan: Aaabcs2948F) (Respondent) (Appellant) Assessee By : Ms. Sashi Kapila, Adv., Sh. Sushil Kumar, Adv. & Sh. Parvesh Kumar, Adv. Department By : Sh. Anuj Garg, Sr. Dr. Date Of Hearing : 20.12.2023 Date Of Pronouncement : 27.12.2023 Order Per Shamim Yahya, Am : The Assessee As Well As Revenue Has Filed The Cross Appeals Against The Order Of The Ld. Cit(A)-8, New Delhi Relating To Assessment Year 2012-13 On The Following Grounds:-

264 of the Act in the case of the assessee pertaining to AY 2007-08 to 2010-11 wherein he held that the subsidy was liable to be reduced from the cost of the assets in terms of Explanation to section 43 stands set aside by the decision of Hon’ble Delhi High Court rendered on 07.12.2017 (copy at page

SUNBEAM LIGHTWEIGHTING SOLUTIONS PVT LTD (FORMELY SUNBEAM AUTO PVT LTD),GURGAON vs. DCIT CIRCLE-24(2), NEW DELHI

In the result, the appeal of the assessee in ITA No

Bench: Shri Shamim Yahya & Shri Challa Nagendra Prasada.Yr. : 2012-13 Sunbeam Lightweighting Vs. Dcit, Circle 24(2), Solutions Pvt. Ltd. New Delhi – 110002 (Formerly: Sunbeam Auto Pvt. Ltd), 38/6, K.M. Stone, Delhi-Jaipur Highway, Narsingpur, Gurgaon-122001 (Pan: Aafcn8583K) (Appellant) (Respondent) & Ay 2012-13 Dcit, Circle 24(2), Sunbeam Auto Pvt. Ltd, Room No. 328, Cr Building, Vs. S-323, Panchsheel Park, Ip Estate, New Delhi – 110 017 New Delhi – 2 (Pan: Aaabcs2948F) (Respondent) (Appellant) Assessee By : Ms. Sashi Kapila, Adv., Sh. Sushil Kumar, Adv. & Sh. Parvesh Kumar, Adv. Department By : Sh. Anuj Garg, Sr. Dr. Date Of Hearing : 20.12.2023 Date Of Pronouncement : 27.12.2023 Order Per Shamim Yahya, Am : The Assessee As Well As Revenue Has Filed The Cross Appeals Against The Order Of The Ld. Cit(A)-8, New Delhi Relating To Assessment Year 2012-13 On The Following Grounds:-

264 of the Act in the case of the assessee pertaining to AY 2007-08 to 2010-11 wherein he held that the subsidy was liable to be reduced from the cost of the assets in terms of Explanation to section 43 stands set aside by the decision of Hon’ble Delhi High Court rendered on 07.12.2017 (copy at page

SUNIL KUMAR,ALWAR RAJASTHAN vs. ITO WARD 3, REWARI

In the result, the appeal is allowed to the extent indicated above leaving the parties to bear their own cost(s)

Bench: Sh. Satbeer Singh Godaraita No. 7634/Del/2025 : Asstt. Year: 2019-20 Sunil Kumar, Vs Income Tax Officer, Hill View Apartment, K-001, Ward-3, Neemrana, Behror, Alwar, Rewari, Rajasthan-301707 Haryana-123401 (Appellant) (Respondent) Pan No. Ccmpk7200C Assessee By: None Revenue By : Sh. Amit Shukla, Sr. Dr Date Of Hearing: 23.12.2025 Date Of Pronouncement: 23.12.2025 Order This Assessee’S Appeal For Assessment Year 2019-20 Arises Against The Addl./Jcit(A), Panaji’S Din & Order No. Itba/Apl/S/250/2025-26/1081206915(1) Dated 26.09.2025, In Proceedings U/S 143(1) R.W.S. 264 Of The Income Tax Act, 1961 (In Short “The Act”).

264 of the Income Tax Act, 1961 (in short “the Act”). 2. Case called twice. None appears at the assessee’s behest. He is accordingly proceeded ex-parte. 3. I note at the outset that there arises the first and foremost issue of validity of the CPC’s impugned section 143(1) “processing” itself dated 21.02.2020 disallowing

SCV & CO. LLP,NEW DELHI vs. DCIT CPC, BANGALORE

The appeal is allowed

Bench: Sh. Anil Chaturvedi & Sh. Anubhav Sharmaita No.1756/Del/2020, A.Y. 2017-18 Scv & Llp Vs. Dcit, B-41, Lower Ground Floor Cpc Panchsheel Enclave New Delhi Pan : Aabfs5902N (Appellant) (Respondent)

disallowance of such expenditure under section 143(1)(a) or 154 without giving proper opportunity to the assessee is against the principles of SCV & Co. LLP, New Delhi 5 Natural Justice. Information contained in tax audit report does not enable Assessing Officer to make any prima facie adjustments under section 143(1)(a) of the Act and reliance was placed

ADDL.CIT, SPECIAL RANGE-2, NEW DELHI vs. BEUMER TECHNOLOGY INDIA P.LTD, MUMBAI

In the result, the appeal is dismissed

Bench: Shri Saktijit Dey & Dr. B.R.R. Kumarassessment Year: 2013-14

section 143(3) of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’) on 17.03.2016 determining the total income of Rs.21,02,47,264/-. While completing the assessment, the Assessing Officer made disallowance

DEPUTY COMMISSIONER OF INCOME TAX, GURGAON vs. HAYS BUSINESS SOLUTIONS PRIVATE LIMITED, GURGAON

The appeal of the Revenue is dismissed

Bench: SHRI MAHAVIR SINGH (Vice President), SHRI MANISH AGARWAL (Accountant Member)

disallowance u/s 40(a)(ia) cannot be made because the payment is not taxable under India-UK DTAA and in view of the provision of section 90(2) of the act, it is not taxable at all. Hence the assessee was not required to deduct TDS while making payment of management charges. The ld. AR further filed detailed written submission

THE COMMISSIONER OF INCOME TAX - INTERNATIONAL TAXATION -3 vs. STANDARD CHARTERED GRINDLAYS PTY LTD.(FORMERELY ANZ GRINDLAYS BANK),

264/- (ii) Disallowance of provision under Rs. 4,35,35,093/- Digitally Signed By:TARUN RANA Signing Date:30.10.2023 17:48:50 Signature Not Verified ITA 567/2023 Page 3 of 4 Section

BRIJ GOPAL CONSTRUCTION COMPANY (P) LTD.,NEW DELHI vs. ACIT, CENTRAL CIRCLE-3, DELHI

In the result, assessee’s appeal is allowed

Bench: Shri M Balaganesh & Ms. Madhumita Royassessment Year: 2017-18

264 CTR 502 (Karn) CIT v. MWP Ltd. SLP dismissed by Apex Court in CC No. 7485/2014 vi) 370 ITR 475 (AP) CIT v. Lotus Constructions vii) 237 Taxman 702 (Kar) Safina Hotels (P) Ltd. v. CIT 9. THAT PENALTY PROCEEDINGS AND QUANTUM PROCEEDINGS ARE QUANTUM INDEPENDENT AND THAT FINDINGS IN THE PROCEEDINGS, THOUGH RELEVANT, ARE NOT CONCLUSIVE OR DETERMINATIVE

MITHILA AND MITHILA ENTERPRISE,NEW DELHI vs. WARD- 49(4), NEW DELHI

In the result, all the three appeals filed by the assessee are allowed

Bench: Shri Challa Nagendra Prasad, A N D Shri Pradip Kumar Kedia(Through Video Conferencing) आ.अ.सं./ I.T.A Nos. 1904, 1905 & 1906/Del/2021 िनधा"रणवष"/Assessment Years: 2017-18, 2018-19 & 2019-20 Mithila & Mithila Enterprises, Assessing Officer, C-22, New Krishna Park, बनाम Ward : 49 (4), Vikas Puri, Vs. New Delhi. New Delhi – 110 018. Pan No. Aasfm1647F अपीलाथ"/Appellant ""यथ"/Respondent

264 (Cal). 5. The ld. Counsel for the assessee further submits that no disallowance can be made under Section 36(1)(viia