CAIRN ENERGY HYDROCARBONS LTD.,GURGAON vs. DDIT, NEW DELHI

In the result, the appeals of the assessee are partly allowed and the appeals of the revenue are dismissed

Bench: Sh. Saktijit Deydr. B. R. R. Kumarita No. 6357/Del/2013: Asstt. Year : 2010-11 Dcit, Vs Cairn Energy Hydrocarbon Ltd., C/O. Cairn India Ltd., 3Rd & 4Th Circle-3(2), International Taxation, Floor, Vipul Plaza, Suncity, Sector- New Delhi 54, Gurgaon (Appellant) (Respondent) Pan No. Aaccc3279J

section 40A and 44C of the Income Tax Act, 1961, shall apply.” 48. The disallowance is called for only where

DDIT, NEW DELHI vs. M/S. CAIRN ENERGY HYDROCARBONS LTD., GURGAON

In the result, the appeals of the assessee are partly allowed and the appeals of the revenue are dismissed

Bench: Sh. Saktijit Deydr. B. R. R. Kumarita No. 6357/Del/2013: Asstt. Year : 2010-11 Dcit, Vs Cairn Energy Hydrocarbon Ltd., C/O. Cairn India Ltd., 3Rd & 4Th Circle-3(2), International Taxation, Floor, Vipul Plaza, Suncity, Sector- New Delhi 54, Gurgaon (Appellant) (Respondent) Pan No. Aaccc3279J

section 40A and 44C of the Income Tax Act, 1961, shall apply.” 48. The disallowance is called for only where

DCIT, INTL. TAXATION, CIRCLE, GURGAON vs. CAIRN ENERGY HYDROCARBON LTD. , GURGAON

In the result, the appeals of the assessee are partly allowed and the appeals of the revenue are dismissed

Bench: Sh. Saktijit Deydr. B. R. R. Kumarita No. 6357/Del/2013: Asstt. Year : 2010-11 Dcit, Vs Cairn Energy Hydrocarbon Ltd., C/O. Cairn India Ltd., 3Rd & 4Th Circle-3(2), International Taxation, Floor, Vipul Plaza, Suncity, Sector- New Delhi 54, Gurgaon (Appellant) (Respondent) Pan No. Aaccc3279J

section 40A and 44C of the Income Tax Act, 1961, shall apply.” 48. The disallowance is called for only where

DCIT, INTL. TAXATION, CIRCLE, GURGAON vs. CAIRN ENERGY HYDROCARBON LTD. , GURGAON

In the result, the appeals of the assessee are partly allowed and the appeals of the revenue are dismissed

Bench: Sh. Saktijit Deydr. B. R. R. Kumarita No. 6357/Del/2013: Asstt. Year : 2010-11 Dcit, Vs Cairn Energy Hydrocarbon Ltd., C/O. Cairn India Ltd., 3Rd & 4Th Circle-3(2), International Taxation, Floor, Vipul Plaza, Suncity, Sector- New Delhi 54, Gurgaon (Appellant) (Respondent) Pan No. Aaccc3279J

section 40A and 44C of the Income Tax Act, 1961, shall apply.” 48. The disallowance is called for only where

CAIRN ENERGY HYDROCARBON LTD. ,GURGAON vs. DCIT, INTL. TAXATION, CIRCLE, GURGAON

In the result, the appeals of the assessee are partly allowed and the appeals of the revenue are dismissed

Bench: Sh. Saktijit Deydr. B. R. R. Kumarita No. 6357/Del/2013: Asstt. Year : 2010-11 Dcit, Vs Cairn Energy Hydrocarbon Ltd., C/O. Cairn India Ltd., 3Rd & 4Th Circle-3(2), International Taxation, Floor, Vipul Plaza, Suncity, Sector- New Delhi 54, Gurgaon (Appellant) (Respondent) Pan No. Aaccc3279J

section 40A and 44C of the Income Tax Act, 1961, shall apply.” 48. The disallowance is called for only where

CAIRN ENERGY HYDROCARBON LTD. ,GURGAON vs. JCIT,(OSD) INTL. TAXATION, CIRCLE, GURGAON

In the result, all the appeals preferred by the assessee as well as the Revenue

Bench: Shri Kul Bharat & Shri M. Balaganesh[A.Y.: 2015-16] & [A.Y.: 2016-17]

section 44C and has simply disallowed these expenses on the basis of the stand taken by the Assessing Officer in earlier

DCIT, INT. TAX. CIRCLE, GURGAON vs. CAIRN ENERGY HYDROCARBONS LIMITED, GURGAON

In the result, all the appeals preferred by the assessee as well as the Revenue

Bench: Shri Kul Bharat & Shri M. Balaganesh[A.Y.: 2015-16] & [A.Y.: 2016-17]

section 44C and has simply disallowed these expenses on the basis of the stand taken by the Assessing Officer in earlier

TRAVELPORT INTERNATIONAL OPERATIONS LIMITED ,BERKSHIRE vs. ACIT CIRCLE-3(1)(1) INTERNATIONAL TAXATION-3, NEW DELHI

In the result, the appeals are partly allowed

Bench: Shri G.S. Pannu, Hon’Ble & Shri Saktijit Dey

disallowance for non-deduction of taxes cannot be made u/s 40(a)(i) 8.3 That on the facts and in the circumstances of the case and without prejudice to the Appellant's claim of full deduction of distribution fees, the Ld. AO and the Ld. DRP has erred in not allowing deduction of 70% as per section

TRAVELPORT INTERNATIONAL OPERATIONS LIMITED,BERKSHIRE vs. ACIT CIRCLE-3(1)(1),INTERNATIONAL TAXATION-3, NEW DELHI

In the result, the appeals are partly allowed

Bench: Shri G.S. Pannu, Hon’Ble & Shri Saktijit Dey

disallowance for non-deduction of taxes cannot be made u/s 40(a)(i) 8.3 That on the facts and in the circumstances of the case and without prejudice to the Appellant's claim of full deduction of distribution fees, the Ld. AO and the Ld. DRP has erred in not allowing deduction of 70% as per section

M/S. THE BANK OF TOKYO-MITSUBISHI, UFJ LTD.,NEW DELHI vs. DDIT, NEW DELHI

44C was allowable\nto the assessee.\"\n\n4.\nWe start with the assessee's former twin substantive grounds seeking to\nreverse both the lower authorities' action disallowing its salary paid overseas to\nexpatriates working in India by the Head Office and the Indian tax paid thereupon\nby the Head Office of Rs.127,955,895 and applicability of Section

DCIT, INTL. TAXATION, CIRCLE, GURGAON vs. CAIRN ENERGY HYDROCARBON LTD. , GURGAON

In the result, the appeal is partly allowed

Bench: Shri G.S. Pannu, Hon’Ble & Shri Saktijit Dey, Hon’Ble

section 44C for the Rajasthan block. 27. Briefly the facts are, while examining the claim of the assessee, the Assessing Officer held that the expenditure claimed is purely on estimate basis without any supporting evidence. Accordingly, he disallowed

M/S. CAIRN ENERGY HYDROCARBONS LTD.,GURGAON vs. ADDL. CIT (INTERNATIONAL TAXATION), NEW DELHI

In the result, the appeal is partly allowed

Bench: Shri G.S. Pannu, Hon’Ble & Shri Saktijit Dey, Hon’Ble

section 44C for the Rajasthan block. 27. Briefly the facts are, while examining the claim of the assessee, the Assessing Officer held that the expenditure claimed is purely on estimate basis without any supporting evidence. Accordingly, he disallowed

DCIT (INTERNATIONAL TAXATION), GURGAON vs. M/S CARIN ENERGY HYDROCARBON LTD.,, GURGAON

In the result, the appeal is partly allowed

Bench: Shri G.S. Pannu, Hon’Ble & Shri Saktijit Dey, Hon’Ble

section 44C for the Rajasthan block. 27. Briefly the facts are, while examining the claim of the assessee, the Assessing Officer held that the expenditure claimed is purely on estimate basis without any supporting evidence. Accordingly, he disallowed

CAIRN ENERGY HYDROCARBON LTD. ,GURGAON vs. DCIT, INTL. TAXATION, CIRCLE, GURGAON

In the result, the appeal is partly allowed

Bench: Shri G.S. Pannu, Hon’Ble & Shri Saktijit Dey, Hon’Ble

section 44C for the Rajasthan block. 27. Briefly the facts are, while examining the claim of the assessee, the Assessing Officer held that the expenditure claimed is purely on estimate basis without any supporting evidence. Accordingly, he disallowed

STANDARD CHARTERED GRINDLAYS LTD.,NEW DELHI vs. ACIT(INTERNATIONAL TAXATION), CIRCLE-3, NEW DELHI

In the result, the appeal of the assessee is allowed

Bench: Sh. Saktijit Deydr. B. R. R. Kumarita No. 21/Del/2019 : Asstt. Year : 2003-04 Standard Chartered Grindlays Ltd., Vs Acit(Intl. Taxation), 4, Todar Mal Lane, Bengali Market, Circle-3, New Delhi-110001 New Delhi (Appellant) (Respondent) Pan No. Aahcs3880Q Assessee By : Ms. Shashi M. Kapila, Adv. & Sh. Pravesh Sharma, Adv. Revenue By : Ms. Sapna Bhatia, Cit Dr Date Of Hearing: 29.06.2022 Date Of Pronouncement: 01.08.2022

disallowed the expenses which were incurred only for the Indian business outside India on the grounds that these are general head office & administrative expenses which fall under section 44C

KNAUF INDIA PVT LTD (EARLIER KNOW AS USG BORAL BUILDING PRODUCTS (INDIA) PVT LTD),GURGAON vs. ITO,WARD-14(3), NEW DELHI

In the result, the appeal filed by the assessee being ITA

Bench: Shri S.Rifaur Rahman & Shri Vimal Kumar

44C(8) of the Act and thus, the final assessment order passed for the relevant A Y is bad in law. Transfer Pricing Grounds: A. Erroneous adjustment of INR 73,389,756 relating to transfer pricing with respect to international transaction pertaining to Purchase of Finished Goods 3. On the facts and in the circumstances of the case

KNAUF INDIA PVT LTD (EARLIER KNOW AS USG BORAL BUILDING PRODUCTS (INDIA) PVT LTD),HARYANA vs. ITO,WARD 14 (3) , NEW DELHI

In the result, the appeal filed by the assessee being ITA

Bench: Shri S.Rifaur Rahman & Shri Vimal Kumar

44C(8) of the Act and thus, the final assessment order passed for the relevant A Y is bad in law. Transfer Pricing Grounds: A. Erroneous adjustment of INR 73,389,756 relating to transfer pricing with respect to international transaction pertaining to Purchase of Finished Goods 3. On the facts and in the circumstances of the case

DDIT, NEW DELHI vs. M/S. THE BANK OF TOKYO MITSUBISHI UFJ LTD., NEW DELHI

Appeal is dismissed

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahmanasstt. Yr.: 2006-07

44C was allowable to the assessee.” 4. We start with the assessee’s former twin substantive grounds seeking to reverse both the lower authorities’ action disallowing its salary paid overseas to expatriates working in India by the Head Office and the Indian tax paid thereupon by the Head Office of Rs. 127,955,895 and applicability of Section