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

Disallowance on Remaining Amount (Rs. 4,41,315):Even if the Rs. 9,72,000 is accepted as a group company payment and excluded, the balance amount (Rs. 14,13,315 - Rs. 9,72,000 = Rs. 4,41,315) does attract TDS under section

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

Disallowance on Remaining Amount (Rs. 4,41,315):Even if the Rs. 9,72,000 is accepted as a group company payment and excluded, the balance amount (Rs. 14,13,315 - Rs. 9,72,000 = Rs. 4,41,315) does attract TDS under section

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 14A of the Act. 41 Reliance in this regard is placed on the decision of the Delhi High Court in the case of PCIT v. Bhushan Steel Ltd.: ITA No. 593/2015, dated 29.09.2015, wherein, the Court upheld the decision of the Tribunal that disallowance

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

41,153/-; disallowance of notional loss of Rs.18,64,61,000/- booked under the head foreign exchange loss; disallowance of Rs. 59,58,893/- for non-deduction of TDS; disallowance of Rs. 1,13,55,875/- under section

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

41,153/-; disallowance of notional loss of Rs.18,64,61,000/- booked under the head foreign exchange loss; disallowance of Rs. 59,58,893/- for non-deduction of TDS; disallowance of Rs. 1,13,55,875/- under section

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

41,153/-; disallowance of notional loss of Rs.18,64,61,000/- booked under the head foreign exchange loss; disallowance of Rs. 59,58,893/- for non-deduction of TDS; disallowance of Rs. 1,13,55,875/- under section

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

41,153/-; disallowance of notional loss of Rs.18,64,61,000/- booked under the head foreign exchange loss; disallowance of Rs. 59,58,893/- for non-deduction of TDS; disallowance of Rs. 1,13,55,875/- under section

HERO MOTO CORP LTD.,NEW DELHI vs. NEAC, DELHI

Bench: Shri Kul Bharat & Shri Prashant Maharishi(Through Video Conferencing)

section 14A and made further disallowance of Rs. 289.94lacs invoking provisions of Rule 8D of the Rules after reducing the suo moto disallowance of Rs. 66.88 lacs made by the appellant in the return of income. 41

M.J. INTERNATIONAL PVT. LTD.,UTTAR PRADESH vs. ITO, NEW DELHI

Bench: Shri R.K. Panda & Shri Kuldip Singh

section 41 (1) of the Income Tax Act, 1961 are not attracted to the facts of the case and that the entire basis of the addition is illegal, arbitrary and misconceived. 5. That the Ld. CIT (A) was not justified in upholding the disallowance

ITO, NEW DELHI vs. M/S. M.J. ENTERPRISES PVT. LTD., UTTAR PRADESH

Bench: Shri R.K. Panda & Shri Kuldip Singh

section 41 (1) of the Income Tax Act, 1961 are not attracted to the facts of the case and that the entire basis of the addition is illegal, arbitrary and misconceived. 5. That the Ld. CIT (A) was not justified in upholding the disallowance

ITO, NEW DELHI vs. M/S. M.J. INTERNATIONAL PVT. LTD., UTTAR PRADESH

Bench: Shri R.K. Panda & Shri Kuldip Singh

section 41 (1) of the Income Tax Act, 1961 are not attracted to the facts of the case and that the entire basis of the addition is illegal, arbitrary and misconceived. 5. That the Ld. CIT (A) was not justified in upholding the disallowance

M.J. GLOBAL PVT. LTD.,UTTAR PRADESH vs. ITO, NEW DELHI

Bench: Shri R.K. Panda & Shri Kuldip Singh

section 41 (1) of the Income Tax Act, 1961 are not attracted to the facts of the case and that the entire basis of the addition is illegal, arbitrary and misconceived. 5. That the Ld. CIT (A) was not justified in upholding the disallowance

HERO MOTOCORP LIMITED,NEW DELHI vs. JCIT, NEW DELHI

In the result appeal of the assessee in ITA No

Bench: Sh. I. C. Sudhir & Shri Prashant Maharishihero Motocorp Limited, Jcit, 34, Basant Lok, Vasant Range-1, New Delhi Vs. Vihar, New Delhi Pan: Aaach0812J (Appellant) (Respondent) Dcit, M/S. Hero Moto Corp. Circle-11(1), Ltd., 34, Community Vs. New Delhi Centre, Basant Lok, Vasant Vihar, New Delhi-110057 (Appellant) (Respondent) Dcit, M/S. Hero Moto Corp. Circle-11(1), Ltd., 34, Community

section 37(1) of the Act. 41. That the assessing officer erred on facts and in law in making ad hoc addition of Rs. 20,10,00,000, being 10% of additions made to plant and machinery and land and building during the year, on the ground that assessee failed to provide requisite information in the prescribed format. 41.1 That

DCIT, CIRCLE- 21(1), NEW DELHI vs. RELIGARE ENTERPRISES LTD.,, NEW DELHI

In the result, revenue’s appeal is dismissed and cross-objection

Bench: Shri Saktijit Dey & Shri Pradip Kumar Kedia:Assessment Year: 2014-15 Deputy Commissioner Of Vs. M/S. Religare Enterprises Income-Tax, Circle-21(1), Ltd., 2Nd Floor, Rajlok New Delhi Building, 24-Nehru Place, New Delhi-110019 Pan :Aaacv5888N (Appellant) (Respondent)

section 14A vide Finance Act, 2022 are prospective in nature i.e., are applicable from assessment year 2022-23 onwards and are not applicable to the present assessment year 2014-15. 41. Alternatively and strictly without prejudice to the aforesaid, the legal position that disallowance

ACIT, CIRCLE- 21(1), NEW DELHI vs. RELIGARE FINVEST LTD.,, NEW DELHI

In the result, -Appeal in ITA No

Bench: Dr. B. R. R. Kumar & Shri Yogesh Kumar U.S.

section 37(1) of the IT Act. The Court held that the debenture when issued is a debt, and therefore, whether it is convertible or non-convertible does not militate against the nature of the debenture. The relevant extracts from the judgment is reproduced hereunder: 35 ITA Nos. 4796/Del/2017 & ors. M/s Religare Finvest Ltd. Vs. DCIT "At this stage

DCIT, CIRCLE- 21(1), NEW DELHI vs. RELIGARE FINVEST LTD., NEW DELHI

In the result, -Appeal in ITA No

Bench: Dr. B. R. R. Kumar & Shri Yogesh Kumar U.S.

section 37(1) of the IT Act. The Court held that the debenture when issued is a debt, and therefore, whether it is convertible or non-convertible does not militate against the nature of the debenture. The relevant extracts from the judgment is reproduced hereunder: 35 ITA Nos. 4796/Del/2017 & ors. M/s Religare Finvest Ltd. Vs. DCIT "At this stage

RELIGARE FINVEST LTD.,NEW DELHI vs. DCIT, CIRCLE- 21(1), NEW DELHI

In the result, -Appeal in ITA No

Bench: Dr. B. R. R. Kumar & Shri Yogesh Kumar U.S.

section 37(1) of the IT Act. The Court held that the debenture when issued is a debt, and therefore, whether it is convertible or non-convertible does not militate against the nature of the debenture. The relevant extracts from the judgment is reproduced hereunder: 35 ITA Nos. 4796/Del/2017 & ors. M/s Religare Finvest Ltd. Vs. DCIT "At this stage

RELIGARE FINVEST LTD.,NEW DELHI vs. DCIT, CIRCLE- 21(1), NEW DELHI

In the result, -Appeal in ITA No

Bench: Dr. B. R. R. Kumar & Shri Yogesh Kumar U.S.

section 37(1) of the IT Act. The Court held that the debenture when issued is a debt, and therefore, whether it is convertible or non-convertible does not militate against the nature of the debenture. The relevant extracts from the judgment is reproduced hereunder: 35 ITA Nos. 4796/Del/2017 & ors. M/s Religare Finvest Ltd. Vs. DCIT "At this stage