CIT V vs. NASA FINELEASE P LTD.

d) to Section 43 (5) of the Act. The loss was disallowed. 5. CIT (Appeals) observed that Section 43(5

PCL FOODS PVT. LTD.,GURGAON vs. ADDI CIT, NATIONAL E- ASSESMENT CENTRE, NEW DELHI

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

Bench: Ms. Madhumita Roy & Shri Brajesh Kumar Singh[Assessment Year: 2016-17] Pcl Foods Private Limited, Additional / Joint/ Unit No.-219, Plot No. 2, Deputy/Assistant Vardhman Crown Mall, Lsc, Vs Commissioner Of Income Sector 19, Dwarka, New Tax/ Income Tax Officer, Delhi-110075. National E-Assessment Centre, Delhi. Pan- Aahcp3493L Assessee Revenue

disallowing loss 3,69,12,311/- and brokerage and commission expense 36,49,338/- in respect of Currency Derivatives aggregating 4,05,61,649/-by- a. Holding that transactions done in currency derivatives do not fall in clause (d) of proviso to section 43(5

VISHNU KUMAR AGGARWAL,DELHI vs. ITO WARD 46(5), NEW DELHI

In the result, the appeal filed by the assessee is dismissed

Bench: Shri C.M. Gargassessment Year: 2015-16 Vishnu Kumar Aggarwal, Vs. Ito, 3762/64, Chawri Bazar, Ward-46(5), New Delhi. New Delhi. Pan: Aarpk3173D (Appellant) (Respondent) Assessee By : None Revenue By : Shri Om Prakash, Sr. Dr Date Of Hearing : 02.05.2022 Date Of Pronouncement : 18.05.2022 Order

d) of the proviso to Section 43(5) of the Act and the said case relates to assessment year 2006-07, However, in the present case, as mentioned earlier, provisions of clause (e) of the proviso to Section 43(5) did not exist during the period when the assessee carried out the transactions. In view of above discussion, I hold

MANKIND PHARMA LIMITED,DELHI vs. DCIT, CIRCLE-1(1)(1), MEERUT

In the result, the additional Ground No

Bench: Shri Challa Nagendra Prasad & Shri Pradip Kumar Kedia

43. Ground no. 3 is thus allowed for statistical purposes. 44. Ground No.4 concerns disallowance of deduction under Section 80G of the Act amounting to Rs.6,38,13,601/-. 45. The AO observed that the assessee has claimed deduction to the extent of Rs.6,38,13,601/- under Section 80G of the Act. The AO noted that the assessee

YOSHIO KUBO vs. COMMISSIONER OF INCOME TAX

The appeals are disposed of accordingly

disallowed. We do not think that the language of Sub-section (5) of Section 40A of the Act provides for or permits such a course. Sub-section (5) applies where an assessee claims a certain deduction saying that he has spent that money in providing, directly or indirectly, either as salary to an employee or in the provision of perquisite

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

D. Disallowance=A*B/C 31.84 (iii) ½% of average value of 132.94 investments [0.5%x3,32,90,205] Total disallowance 164.78 Less: Suo moto disallowance made in the return 67.03 Net disallowance made in the assessment order 97.75 The assessing officer has alternately proposed to disallow interest expenditure to the extent of Rs.31.84 lacs under section 36(l)(iii) and amount

COMMISSIONER OF INCOME TAX vs. INDIA PVT. LTD.

The appeal is dismissed

5) of the Income Tax Act 1922 while interpreting the expression “actual cost.” The Supreme Court held (ITR, p. 173): “as the expression actual cost has not been defined, it should, in our opinion, be construed in the sense which no commercial man would misunderstand. For this purpose it would be necessary to ascertain the connotation of the above expression

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

disallowance under Section 14A read with Rule 8D at 3,20,962/- and levied penalty of 99,177/-. Since the facts are identical, for the detailed discussion in the earlier part of this order, we cancel the penalty levied under Section 271(1)(c). x) ITA No. 5481/D/2019 dated 2.8.2024 Rukmani Wires Pvt. Ltd. vs. DCIT 11. Since, we have

MARUTI SUZUKI INDIA LTD.,NEW DELHI vs. DCIT, NEW DELHI

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

Bench: Shri Shamim Yahya & Shri Kul Bharat[Assessment Year : 2010-11] Maruti Suzuki India Ltd., Vs Dcit, Plot No.1, Nelson Mandela Road, Circle-16(1), Vasant Kunj, New Delhi-110070. New Delhi. Pan-Aaacm0829Q Appellant Respondent [Assessment Year : 2010-11] Dcit, Vs Maruti Suzuki India Ltd., Circle-16(1), Plot No.1, Nelson Mandela Road, New Delhi. Vasant Kunj, New Delhi-110070. Pan-Aaacm0829Q Appellant Respondent Appellant By Shri Ajay Vohra, Sr.Adv., Shri Neeraj Jain, Adv. & Ms. Tejasvi Jain & Ms. Somya Jain, Ca Respondent By Shri G.C.Srivastava, Adv., Shri Kalrav Mehrotra, Adv. & Shri Mayank Patawari, Ca Date Of Hearing 11.11.2022 Date Of Pronouncement 09.02.2023

section 14A of the Act. 5.6. Without prejudice, the assessing officer erred in computing the disallowance u/s 14A read with Rule 8D of the Income Tax Rules. 6. That the Assessing Officer/ DRP erred on facts and in law in disallowing expenditure of Rs.444,43,46,454/- (Net of depreciation for the year) incurred on account of royalty (both lumpsum

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

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

Bench: Shri Shamim Yahya & Shri Kul Bharat[Assessment Year : 2010-11] Maruti Suzuki India Ltd., Vs Dcit, Plot No.1, Nelson Mandela Road, Circle-16(1), Vasant Kunj, New Delhi-110070. New Delhi. Pan-Aaacm0829Q Appellant Respondent [Assessment Year : 2010-11] Dcit, Vs Maruti Suzuki India Ltd., Circle-16(1), Plot No.1, Nelson Mandela Road, New Delhi. Vasant Kunj, New Delhi-110070. Pan-Aaacm0829Q Appellant Respondent Appellant By Shri Ajay Vohra, Sr.Adv., Shri Neeraj Jain, Adv. & Ms. Tejasvi Jain & Ms. Somya Jain, Ca Respondent By Shri G.C.Srivastava, Adv., Shri Kalrav Mehrotra, Adv. & Shri Mayank Patawari, Ca Date Of Hearing 11.11.2022 Date Of Pronouncement 09.02.2023

section 14A of the Act. 5.6. Without prejudice, the assessing officer erred in computing the disallowance u/s 14A read with Rule 8D of the Income Tax Rules. 6. That the Assessing Officer/ DRP erred on facts and in law in disallowing expenditure of Rs.444,43,46,454/- (Net of depreciation for the year) incurred on account of royalty (both lumpsum

TECHNOLOGIES LTD) vs. ACIT

Appeals are allowed

43,88,624/- was claimed under Section 10B of the Income Tax Act, 1961 [in short “Act”]. 3.1. The assessment concerning the appellant/assessee was framed under Section 143(3) of the Act. An order to that effect was passed on 30.12.2010, wherein the appellant/assessee‟s taxable income was assessed at Rs. 36,28,88,570/-. The assessing officer [in short

TECHNOLOGIES LTD) vs. ACIT

Appeals are allowed

43,88,624/- was claimed under Section 10B of the Income Tax Act, 1961 [in short “Act”]. 3.1. The assessment concerning the appellant/assessee was framed under Section 143(3) of the Act. An order to that effect was passed on 30.12.2010, wherein the appellant/assessee‟s taxable income was assessed at Rs. 36,28,88,570/-. The assessing officer [in short

TECHNOLOGIES LTD) vs. ACIT

Appeals are allowed

43,88,624/- was claimed under Section 10B of the Income Tax Act, 1961 [in short “Act”]. 3.1. The assessment concerning the appellant/assessee was framed under Section 143(3) of the Act. An order to that effect was passed on 30.12.2010, wherein the appellant/assessee‟s taxable income was assessed at Rs. 36,28,88,570/-. The assessing officer [in short

B & B SHARECOM PVT LTD.,,HISAR vs. DCIT, CIRCLE, HISAR

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

Bench: Shri Challa Nagendra Prasad & Shris.Rifaur Rahmanb & B Sharecom Pvt. Ltd., Vs. Dcit, Circle, 133, 1St Floor, Parijat Complex, Hisar. Hisar – 125 001. (Pan :Aagcb1363A) (Appellant) (Respondent) Assessee By : Shri K. Sampath, Advocate Shri V Rajakumar, Advocate Revenue By : Shri Abhishek Deavel, Sr. Dr Date Of Hearing : 22.08.2025 Date Of Order : 24.09.2025 O R D E R

d) and (e) of Sec.43(5) of the Act. 19. Accordingly, he submitted that in this way, the order of the Authorities below disallowing a set-off of loss Rs.3,53,89,637/- against the profit of Rs.4,42,20,153/- is incorrect on facts and unsustainable in law. 20. On the other hand, ld. DR of the Revenue relied

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

ACIT, CENTRAL CIRCLE- 27, NEW DELHI vs. UFLEX LTD., NEW DELHI

In the result, appeals of the assessee for AY 2011-12 and subsequent

Bench: N.K. Billaiya & Ms. Astha Chandra

D E R PER ASTHA CHANDRA, JM These cross appeals filed by the assessee and the Revenue arise out of the order of the Ld. Commissioner of Income Tax, (Appeals)-29, New Uflex Ltd. Vs ACIT & ACIT vs. Uflex Ltd. 2 Delhi (“CIT(A)”) dated 29.01.2018 pertaining to Assessment Year (“AY”) 2011-12 and orders dated 30.01.2018 pertaining to Assessment

UFLEX LTD.,NEW DELHI vs. ACIT, CENTRAL CIRCLE- 27, NEW DELHI

In the result, appeals of the assessee for AY 2011-12 and subsequent

Bench: N.K. Billaiya & Ms. Astha Chandra

D E R PER ASTHA CHANDRA, JM These cross appeals filed by the assessee and the Revenue arise out of the order of the Ld. Commissioner of Income Tax, (Appeals)-29, New Uflex Ltd. Vs ACIT & ACIT vs. Uflex Ltd. 2 Delhi (“CIT(A)”) dated 29.01.2018 pertaining to Assessment Year (“AY”) 2011-12 and orders dated 30.01.2018 pertaining to Assessment

UFLEX LTD.,NEW DELHI vs. ACIT, CENTRAL CIRCLE- 27, NEW DELHI

In the result, appeals of the assessee for AY 2011-12 and subsequent

Bench: N.K. Billaiya & Ms. Astha Chandra

D E R PER ASTHA CHANDRA, JM These cross appeals filed by the assessee and the Revenue arise out of the order of the Ld. Commissioner of Income Tax, (Appeals)-29, New Uflex Ltd. Vs ACIT & ACIT vs. Uflex Ltd. 2 Delhi (“CIT(A)”) dated 29.01.2018 pertaining to Assessment Year (“AY”) 2011-12 and orders dated 30.01.2018 pertaining to Assessment