A2Z MAINTENANCE & ENGINEERING SERVICES LTD.,GURGAON vs. DCIT, CENTRAL CIRCLE-II, FARIDABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Pradip Kumar Kedia & Shri Anubhav Sharma

disallowance without arriving at a prima facie satisfaction with respect to infraction by the assessee of clause (c) of sub-section (1) of Section 271 of the Act. A requirement which is mandated by the provision itself. 15.7 Learned ASG also sought to place reliance on the Memorandum as well as Clause 48 of the Notes on Clauses appended

A2Z INFRA ENGINEERING LIMITED,GURGAON vs. DCIT CC-2 , FARIDABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Pradip Kumar Kedia & Shri Anubhav Sharma

disallowance without arriving at a prima facie satisfaction with respect to infraction by the assessee of clause (c) of sub-section (1) of Section 271 of the Act. A requirement which is mandated by the provision itself. 15.7 Learned ASG also sought to place reliance on the Memorandum as well as Clause 48 of the Notes on Clauses appended

DCIT-CENTRAL CIRCLE-2, FARIDABAD vs. A2Z INFRA ENGINEERS LTD., GURGAON

In the result, the appeal of the assessee is allowed

Bench: Shri Pradip Kumar Kedia & Shri Anubhav Sharma

disallowance without arriving at a prima facie satisfaction with respect to infraction by the assessee of clause (c) of sub-section (1) of Section 271 of the Act. A requirement which is mandated by the provision itself. 15.7 Learned ASG also sought to place reliance on the Memorandum as well as Clause 48 of the Notes on Clauses appended

DCIT CC-2 , FARIDABAD vs. A2Z MAINTENANCE AND ENGINEERING SERVICES LTD., GURGAON

In the result, the appeal of the assessee is allowed

Bench: Shri Pradip Kumar Kedia & Shri Anubhav Sharma

disallowance without arriving at a prima facie satisfaction with respect to infraction by the assessee of clause (c) of sub-section (1) of Section 271 of the Act. A requirement which is mandated by the provision itself. 15.7 Learned ASG also sought to place reliance on the Memorandum as well as Clause 48 of the Notes on Clauses appended

A2Z INFRA ENGINEERING LIMITED,GURGAON vs. CCIT- CENTRAL CIRCLE-2, FARIDABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Pradip Kumar Kedia & Shri Anubhav Sharma

disallowance without arriving at a prima facie satisfaction with respect to infraction by the assessee of clause (c) of sub-section (1) of Section 271 of the Act. A requirement which is mandated by the provision itself. 15.7 Learned ASG also sought to place reliance on the Memorandum as well as Clause 48 of the Notes on Clauses appended

INFRA ENGINEERS LTD.,GURGAON vs. DCIT, CC-2, FARIDABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Pradip Kumar Kedia & Shri Anubhav Sharma

disallowance without arriving at a prima facie satisfaction with respect to infraction by the assessee of clause (c) of sub-section (1) of Section 271 of the Act. A requirement which is mandated by the provision itself. 15.7 Learned ASG also sought to place reliance on the Memorandum as well as Clause 48 of the Notes on Clauses appended

NATIONAL HOUSING BANK,NEW DELHI vs. JCIT, SPECIAL RANGE-6, NEW DELHI

In the result, the appeals in ITA No

5A, 4th Floor Delhi India Habitat Centre, Lodhi Road, New Delhi – 110 003 PAN No. AABCN 2600 H (APPELLANT) (RESPONDENT) Assessee by Shri Kamal Bansal, C.A. Revenue by Shri Arvind Bansal, Sr. D.R. Date of hearing: 13.03.2023 Date of Pronouncement: 16.03.2023 ORDER PER ANIL CHATURVEDI, AM: This appeal filed by the assessee is directed against the order dated 13.08.2021 passed

THE COMMISSIONER OF INCOME TAX-V vs. P M ELECTRONICS LTD

5A) read with Section 2(24)(x) and Section 43B. Consequently, the Assessing Officer disallowed the deduction and added a sum of Rs 17,94,042/- towards

SANJEEV CHOUDHARY,SIRSA vs. DCIT CENTRAL CIRCLE, GHAZIABAD

In the result, the appeal of the assessee is dismissed

Bench: Sh. M. Balaganesh & Sh. Sudhir Kumarassessment Year: 2009-10 Sanjeev Choudhary Vs. Dcit C/O Sudhindra Jain & Co. Central Circle 113/7A, Indra Jit Jian Marg, Ghaziabad Swaroop Nagar, Kanpur 208002 Pan No.Aeypc5911Q (Appellant) (Respondent)

5A to Section 271(1)(c) of the Income Tax Act, 1961 was discharged by him, therefore, the penalty imposed was not sustainable in law and on facts. 6. That the Ld. CIT(Appeals)-4, Kanpur has erred in law and on facts in sustaining the penalty imposed under section 271(1)(c) of the Income Tax Act, 1961 therefore

FASHION GROUP INTERNATIONAL,PANIPAT vs. ACIT, CIRCLE, PANIPAT

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

disallowance was made @1/5 of the expenditure most arbitrarily, without there being any basis for the same. 3. The learned counsel has submitted return synopsis, for the sake of completeness the same is being reproduced below:- 1. The main issue in this appeal filed by the assessee is an addition of Rs.1,58,56,968/- made by the Ld. Assessing

GREEN INFRA WIND FARM ASSET LTD.,GURUGRAM vs. ACIT, CIRCLE 10(2), NEW DELHI

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

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Assessment Year : 2016-17] Green Infra Wind Farm Asset Ltd., Vs Acit, 5Th Floor, Tower C, Building No.8, Circle-10(2), Dlf Cyber City, Gurugram, New Delhi. Haryana-122002. Pan-Aaecg4080H Appellant Respondent Appellant By Shri Vartik Chokshi, Ca & Shri Biren Shah, Ca Respondent By Shri Rajesh Kumar Dhanesta, Sr.Dr Date Of Hearing 23.04.2025 Date Of Pronouncement 04.07.2025 Order

5A)The provisions of this section shall not apply to,— (i)any income accruing or arising to a company from life insurance business referred to in section 115B; (ii)a person who has exercised the option referred to under section 115BAA or section 115BAB. (6)The provisions of this section shall not apply to the income accrued or arising

ACIT,CIRCLE-19(1), NEW DELHI vs. ONGC VIDESH LIMITED, NEW DELHI

Bench: Sh. N.K.Billaiya & Sh. Anubhav Sharmaacit, Vs. Ongc Videsh Limited Circle-19(1), Tower-B5, Nelson Mandela New Delhi Marg, Vasant Kinj, New Delhi Pan : Aaaco1230F (Appellant) (Respondent)

section 42, and the product sharing agreement is binding on the assessee. Accordingly, the claim of pre-acquisition expenses u/s 37(1) to the extent of Rs. 17,39,14,853 is not proper as the same is eligible u/s 42 as per the terms of the agreement in such years as defined in the agreement. 4. Whether

DCIT, NEW DELHI vs. M/S. ONGC VIDESH LTD., NEW DELHI

In the result, the appeals of the Revenue stand dismissed

section 42 agreement are binding on the assessee as the same are special provisions sanctioned by Parliament and have overriding effect. 11. On the facts and circumstances of the case and in law, the Ld.CIT(A) is erred in deleting the disallowance of claim of pre- acquisition expenses amounting to Rs.79,18,87,613/- by ignoring the fact there cannot

DCIT, NEW DELHI vs. M/S. ONGC VIDESH LTD., NEW DELHI

In the result, the appeals of the Revenue stand dismissed

section 42 agreement are binding on the assessee as the same are special provisions sanctioned by Parliament and have overriding effect. 11. On the facts and circumstances of the case and in law, the Ld.CIT(A) is erred in deleting the disallowance of claim of pre- acquisition expenses amounting to Rs.79,18,87,613/- by ignoring the fact there cannot

ADDL. CIT, SPECIAL RANGE- 7, NEW DELHI vs. ONGC VIDESH LTD., NEW DELHI

In the result, the appeals of the Revenue stand dismissed

section 42 agreement are binding on the assessee as the same are special provisions sanctioned by Parliament and have overriding effect. 11. On the facts and circumstances of the case and in law, the Ld.CIT(A) is erred in deleting the disallowance of claim of pre- acquisition expenses amounting to Rs.79,18,87,613/- by ignoring the fact there cannot

ADDL. CIT, SPECIAL RANGE-7, NEW DELHI vs. ONGC VIDESH LTD., NEW DELHI

In the result, the appeals of the Revenue stand dismissed

section 42 agreement are binding on the assessee as the same are special provisions sanctioned by Parliament and have overriding effect. 11. On the facts and circumstances of the case and in law, the Ld.CIT(A) is erred in deleting the disallowance of claim of pre- acquisition expenses amounting to Rs.79,18,87,613/- by ignoring the fact there cannot

DCIT, NEW DELHI vs. M/S. ONGC VIDESH LTD., NEW DELHI

In the result, the appeals of the Revenue stand dismissed

section 42 agreement are binding on the assessee as the same are special provisions sanctioned by Parliament and have overriding effect. 11. On the facts and circumstances of the case and in law, the Ld.CIT(A) is erred in deleting the disallowance of claim of pre- acquisition expenses amounting to Rs.79,18,87,613/- by ignoring the fact there cannot

ADDL. CIT, SPECIAL RANGE-7, NEW DELHI vs. ONGC VIDESH LTD., NEW DELHI

In the result, the appeals of the Revenue stand dismissed

section 42 agreement are binding on the assessee as the same are special provisions sanctioned by Parliament and have overriding effect. 11. On the facts and circumstances of the case and in law, the Ld.CIT(A) is erred in deleting the disallowance of claim of pre- acquisition expenses amounting to Rs.79,18,87,613/- by ignoring the fact there cannot