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

Sections 206AB & 206CCA implying that the supplier has duly filed the return of income for the AY 2021-22 and hence the very pretext on which the disallowance has been made is not correct. The appellant has also submitted that the input tax credit claimed against these purchases already stand allowed proving that the supplier is regularly filing

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, 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

M/S. BHARTI AIRTEL LTD.,NEW DELHI vs. ADDL. CIT, NEW DELHI

In the result appeal of the assessee with respect to ground No

Bench: Shri I.C.Sudhir & Shri Prashant Maharishibharti Airtel Ltd, Addl Cit, Bharti Crescent, 1, Vs. Range-2, Cr Building, Ip Nelson Mandela Road, Vasant Estate, New Delhi Kunj, New Delhi Pan:Aaacb2894G (Appellant) (Respondent) Bharti Airtel Ltd, Addl Cit, Bharti Crescent, 1, Vs. Range-2, Cr Building, Ip Nelson Mandela Road, Vaxant Estate, New Delhi Kunj, New Delhi Pan:Aaacb2894G (Appellant) (Respondent)

4,2 014 is not applicable to A.YITA No. 880/Del/2014 2009-10. But in view of proposition rendered by the Hon'ble High Court of Delhi, it is settled that the proviso to section 40(a)(ia) of the Act being declaratory and curative is applicable from 1.4.2005 which is (lie date of insertion of sub-section (ia) of section

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 to 7 of grounds of appeal of the assessee is in respect of Transfer Pricing Adjustment of Rs.1,01,87,884/- made by the AO/TPO on account of interest receivables on advance given to I.T.A.No.705/Del/2021 M/s BSE C&C JV Nepal Pvt. Ltd. and TP Adjustment of Rs.37,71,124/- on account of interest paid

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

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 under section 14A read with Rule 8D could not be added while computing book profits as per section 115JB

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

Bench: Shri Challa Nagendra Prasad & Shri M. Balaganesh

41, Noida b) The Sriram Millennium School, Sector 135, Noida and c) The Millennium School, Meerut 4. A search and seizure operation under section 132 of the Act was conducted on 11-07-2023 in the case of PTC group companies. A consequential search was also carried out in the case of the Assessee Society. The claim 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

4. The Ld. AO completed the assessment under section 143(3) of the Income Tax Act, 1961 (the “Act”) on total income of Rs. 1,53,74,00,120/- on 19.01.2016 for AY 2013-14 including therein disallowance of depreciation of Rs. 57,05,766/- on investment made in windmills; disallowance of Rs. 20,54,47,894/- being notional loss

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

4. The Ld. AO completed the assessment under section 143(3) of the Income Tax Act, 1961 (the “Act”) on total income of Rs. 1,53,74,00,120/- on 19.01.2016 for AY 2013-14 including therein disallowance of depreciation of Rs. 57,05,766/- on investment made in windmills; disallowance of Rs. 20,54,47,894/- being notional loss

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

4. The Ld. AO completed the assessment under section 143(3) of the Income Tax Act, 1961 (the “Act”) on total income of Rs. 1,53,74,00,120/- on 19.01.2016 for AY 2013-14 including therein disallowance of depreciation of Rs. 57,05,766/- on investment made in windmills; disallowance of Rs. 20,54,47,894/- being notional loss

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

4. The Ld. AO completed the assessment under section 143(3) of the Income Tax Act, 1961 (the “Act”) on total income of Rs. 1,53,74,00,120/- on 19.01.2016 for AY 2013-14 including therein disallowance of depreciation of Rs. 57,05,766/- on investment made in windmills; disallowance of Rs. 20,54,47,894/- being notional loss

M/S. NEW DELHI TELEVISION LTD.,NEW DELHI vs. ACIT, NEW DELHI

Bench: Shri H. S. Sidhu & Shri Prashant Maharishinew Delhi Television Ltd, Vs. Acit, 207, Okhla Industrial Estate, Phase- Circle-13(1), Iii, New Delhi New Delhi Pan: Aaacn0865D (Appellant) (Respondent) Acit, Vs. New Delhi Television Ltd, Circle-13(1), 207, Okhla Industrial Estate, New Delhi Phase-Iii, New Delhi Pan: Aaacn0865D (Appellant) (Respondent)

4 5,53,30,999/– under section 40 (a) (ia) of the act. As the appellant earns income through sale of advertisement time on its various channels, this advertisement time is sold generally through advertisement agencies. These advertisement agencies in turn sales this advertisement time to the advertisers. The appellant assessee raises invoice on such advertisement agencies after allowing

DCIT, NEW DELHI vs. M/S. NEW DELHI TELEVISION LTD., NEW DELHI

Bench: Shri H. S. Sidhu & Shri Prashant Maharishinew Delhi Television Ltd, Vs. Acit, 207, Okhla Industrial Estate, Phase- Circle-13(1), Iii, New Delhi New Delhi Pan: Aaacn0865D (Appellant) (Respondent) Acit, Vs. New Delhi Television Ltd, Circle-13(1), 207, Okhla Industrial Estate, New Delhi Phase-Iii, New Delhi Pan: Aaacn0865D (Appellant) (Respondent)

4 5,53,30,999/– under section 40 (a) (ia) of the act. As the appellant earns income through sale of advertisement time on its various channels, this advertisement time is sold generally through advertisement agencies. These advertisement agencies in turn sales this advertisement time to the advertisers. The appellant assessee raises invoice on such advertisement agencies after allowing

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 of expenses under section Rs. 38,91,45,842/- 40(a)(ia) and Education Cess (Rs. 38,34,16,688/- + Rs. 57,29,154/-)  Adjustment, after giving effect to direction of Rs. 41,72,717/- Ld. DRP to the order of TPO 4

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

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

41,579/-. Further supporting documents in the form of Ledger Account, Invoice copies & Goods Receipt Notes, E-way Bills & Transportation Receipts and Bank Statements highlighting payments have been filed. The appellant has also submitted Income Tax Portal screenshot confirming that MRG Enterprises is not a "Specified Person" under Sections 206AB & 206CCA implying that the supplier has duly filed the return

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

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

41,579/-. Further supporting documents in the form of Ledger Account, Invoice copies & Goods Receipt Notes, E-way Bills & Transportation Receipts and Bank Statements highlighting payments have been filed. The appellant has also submitted Income Tax Portal screenshot confirming that MRG Enterprises is not a "Specified Person" under Sections 206AB & 206CCA implying that the supplier has duly filed the return

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

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

disallowance of Rs.88.95 lakh out of total purchases of Rs.5.73 crore made by the A.O. and allow the Ground No. 6 of the Assessee. (iii) Asstt. Commissioner of Income Tax Range-5(3) v/s M/s. Radiant Shipping Ltd./ ITA no.1540/Mum. /2011/ (Assessment Year: 2001-02) dated 27.05.2016 " 23. We have considered the submissions of the parties and perused the material