DEPUTY COMMISSIONER OF INCOME TAX, DELHI vs. M/S VESTIGE MARKETING PRIVATE LIMITED, DELHI

Bench: Shri Before Shri Satbeer Singh Godarabefore Shri Before Shri Satbeer Singh Godarasatbeer Singh Godara & Satbeer Singh Godara & And & Shri Naveen Chandra Shri Naveen Chandra, , , Shri Naveen Chandra Shri Naveen Chandra

disallowance is primarily based on:  A statement recorded under Section 132(4) during search; and  An inference that payments made

DEPUTY COMMISSIONER OF INCOME TAX, DELHI vs. M/S VESTIGE MARKETING PRIVATE LIMITED, DELHI

Bench: Shri Before Shri Satbeer Singh Godarabefore Shri Before Shri Satbeer Singh Godarasatbeer Singh Godara & Satbeer Singh Godara & And & Shri Naveen Chandra Shri Naveen Chandra, , , Shri Naveen Chandra Shri Naveen Chandra

disallowance is primarily based on:  A statement recorded under Section 132(4) during search; and  An inference that payments made

BSC C&C JV,NEW DELHI vs. NEAC, NEW DELHI

In the result, the appeal of the assessee is partly allowed as

Bench: Shri G.S. Pannu, Hon’Ble & Shri Challa Nagendra Prasadआ.अ.सं/.I.T.A No.705/Del/2021 िनधा"रणवष"/Assessment Year: 2016-17 बनाम Bsc C&C Jv Assessing Officer, 74, Hemkunt Colony, Vs. National E-Assessment New Delhi. Centre, Delhi. Pan No. Aadfb8115G अपीलाथ" Appellant ""यथ"/Respondent

4. Ground no. 3 of grounds of appeal of the assessee is in respect of disallowance of deduction claimed u/s 80IA of the Act. 5. Briefly stated the facts are that the assessee BSC C&C Joint Venture (JV) is a Joint Venture between two Infrastructure Companies namely BSCPL Infrastructure Ltd. and C&C Constructions Ltd. The assessee

DCIT,C-11(1), NEW DELHI vs. HERO MOTOCORP LTD.,, NEW DELHI

Appeal of the Revenue is dismissed

Bench: Shri Narendra Kumar Billaiya & Shri Kul Bharat

section 115 JB of the Act. In view of the above, the addition/disallowance made by the assessing officer was rightly deleted by the CIT(A). Ground no. 4: Disallowance

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

In the result, the appeal of the Assessee is allowed

4) of the Act. We find that post Finance\nAct, 2022, the provisions of section 13(1)(c) of the Act very clearly mention\nthat if there is a benefit extended to specified persons referred to section\n13(3) of the Act either directly or indirectly, then only such part of the\nincome so diverted would be subjected

MOTHERSON SUMI SYSTEMS LIMITED,NEW DELHI vs. DCIT, NEW DELHI

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

Bench: Shri Shamim Yahya & Ms. Astha Chandraasstt. Year: 2010-11

4,209,878 9 Receipt of Interest on loans 546,809 10 Reimbursement of expenses received 1,886,087 3 Motherson Sumi Systems Limited vs. DCIT The Ld. Assessing Officer (“AO”) in the draft assessment order 3.2 proposed an addition of Rs. 56,13,895/- on account of disallowance of exemption under section

BSC C&C JOINT VENTURE,NEW DELHI vs. DCIT CIRCLE-61(1),, NEW DELHI

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

Bench: Shri M Balaganesh & Ms. Astha Chandraasstt. Year: 2017-18

Disallowance under section 36(1)(va) Rs. 1,42,72,897/- r.w. section 2(24)(x) Total assessed income Rs. 46,09,79,383/- Rounded off to- Rs. 46,09,79,380/- 3.2 The Ld. FAO negatived the claim of deduction under section 801A(4

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

disallowance holding that deduction under section 36(i)(viii) is available only to those entities which commenced operations after 01.04.1993 or 1.4.1999. The Ld. CIT(A) held that deduction related to undertaking who started its operations before the earliest prescribed date under section 80IA(4

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

disallowance holding that deduction under section 36(i)(viii) is available only to those entities which commenced operations after 01.04.1993 or 1.4.1999. The Ld. CIT(A) held that deduction related to undertaking who started its operations before the earliest prescribed date under section 80IA(4

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

disallowance holding that deduction under section 36(i)(viii) is available only to those entities which commenced operations after 01.04.1993 or 1.4.1999. The Ld. CIT(A) held that deduction related to undertaking who started its operations before the earliest prescribed date under section 80IA(4

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

disallowance holding that deduction under section 36(i)(viii) is available only to those entities which commenced operations after 01.04.1993 or 1.4.1999. The Ld. CIT(A) held that deduction related to undertaking who started its operations before the earliest prescribed date under section 80IA(4

BSC C&C JOINT VENTURE,NEW DELHI vs. DCIT, CIRCLE-61(1), NEW DELHI

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

Bench: SHRI G.S. PANNU (Vice President), SHRI ANUBHAV SHARMA (Judicial Member)

Disallowance under section 36(1)(va) Rs. 1,08,85,080/- r.w. section 2(24)(x) Total assessed income Rs. 30,92,31,440/- 4.1 The AO negatived the claim of deduction under section 801A(4

DY. COMMISSIONER OF INCOME TAX, CIRCLE, HISAR vs. SYNERGY WASTE MANAGEMENT PRIVATE LIMITED, HISAR

Appeal is dismissed in above terms

Bench: Sh. Satbeer Singh Godara & Sh. S. Rifaur Rahmanita No. 3557/Del/2023 : Asstt. Year : 2017-18 Dcit, Vs Synergy Waste Management Pvt. Circle, Ltd., #168, Sector-27-28, Hisar, Hisar, Haryana-125001 Haryana-125001 (Appellant) (Respondent) Pan No. Aaics9088H Assessee By : Sh. S. K. Gupta, Ca Revenue By : Sh. Sahil Kumar Bansal, Sr. Dr Date Of Hearing: 12.12.2024 Date Of Pronouncement: 20.12.2024 Order Per Satbeer Singh Godara: This Revenue’S Appeal For Assessment Year 2017-18, Arises Against The Cit(A)/Nfac, Delhi’S Din & Order No. Itba/Nfac/S/250/2023-24/105727025(1) Dated 20.10.2023, In Proceedings U/S 143(3) Of The Income Tax Act, 1961 (In Short “The Act”).

Section 80IA(4) deduction which was disallowed by the Assessing Officer in his assessment order dated 27.12.2019 to the tune

LSL TOOLS (P) LTD,GURUGRAM vs. ACIT , CENTRAL CIRCLE-1, FARIDABAD

In the result, both the appeals are allowed

Bench: Shri S. Rifaur Rahman & Shri Anubhav Sharma

4. That the learned Commissioner of Income Tax (Appeals) has also erred both in law and on facts in sustaining a disallowance of Rs.44,10,000/- representing salary paid by the appellant company to its director Smt. PritiSingla by invoking section

LSL TOOLS (P) LTD.,GURGAON vs. ACIT, CC-1, FARIDABAD

In the result, both the appeals are allowed

Bench: Shri S. Rifaur Rahman & Shri Anubhav Sharma

4. That the learned Commissioner of Income Tax (Appeals) has also erred both in law and on facts in sustaining a disallowance of Rs.44,10,000/- representing salary paid by the appellant company to its director Smt. PritiSingla by invoking section

VESTIGE MARKETING PVT LTD,DELHI vs. DCIT CENTRAL CIRCLE-05, DELHI

disallowance is primarily based on:\nA statement recorded under Section 132(4) during search; and\nAn inference that payments made

DEPUTY COMMISSIONER OF INCOME TAX, DELHI vs. M/S VESTIGE MARKETING PRIVATE LIMITED, DELHI

disallowance is primarily based on:\nA statement recorded under Section 132(4) during search; and\nAn inference that payments made

DEPUTY COMMISSIONER OF INCOME TAX, DELHI vs. M/S VESTIGE MARKETING PRIVATE LIMITED, DELHI

disallowance is primarily based on:\nA statement recorded under Section 132(4) during search; and\nAn inference that payments made