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

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

A2Z INFRA ENGINEERING LIMITED,GURGAON vs. DCIT- 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

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

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. DCIT- 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

MARUTI SUZUKI INDIA LTD.,NEW DELHI vs. ADDL. CIT, NEW DELHI

Appeal of the assessee is partly allowed for statistical purpose

Bench: Shri R. K. Panda & Ms Suchitra Kamblei.T.A .No. 467/Del/2014 (A.Y 2009-10)

section 43B of the Income-tax Act, 1961 (‘the Act). According to the Assessment order, the following are such statutory duties claimed by the assessee for deduction, but disallowed by the Assessing Officer: Item Item Particulars Amount (Rs.) No. 1(a) PLA Balance of Excise Duty on Vehicles 28,21,616 1(b) PLA Balance R&D Cess on Vehicles

PR. COMMISSIONER OF INCOME TAX -7 vs. SUMITOMO CORPORATION INDIA (P) LTD.

Bench: HON'BLE MR. JUSTICE YASHWANT VARMA,HON'BLE MR. JUSTICE RAVINDER DUDEJA

disallowances. On 07 April and 28 July 2021, the petitioner was served with notices under Section 92CA intimating it of a reference having been made to the TPO. The TPO issued a show cause notice on 03 September 2021 apprising the writ petitioner of various adjustments which were proposed to be made. Since the additions proposed would have been binding

THE PR. COMMISSIONER OF INCOME TAX -6 vs. MICROSOFT INDIA ( R & D) PVT. LTD.

Bench: HON'BLE MR. JUSTICE VIPIN SANGHI,HON'BLE MR. JUSTICE SANJEEV NARULA

disallowances. On 07 April and 28 July 2021, the petitioner was served with notices under Section 92CA intimating it of a reference having been made to the TPO. The TPO issued a show cause notice on 03 September 2021 apprising the writ petitioner of various adjustments which were proposed to be made. Since the additions proposed would have been binding

THE PR. COMMISSIONER OF INCOME TAX -6 vs. MARUTI SUZUKI INDIA LTD.

Bench: HON'BLE MR. JUSTICE VIPIN SANGHI,HON'BLE MR. JUSTICE SANJEEV NARULA

disallowances. On 07 April and 28 July 2021, the petitioner was served with notices under Section 92CA intimating it of a reference having been made to the TPO. The TPO issued a show cause notice on 03 September 2021 apprising the writ petitioner of various adjustments which were proposed to be made. Since the additions proposed would have been binding

DCIT, NEW DELHI vs. M/S. PUNJ LLOYD INDUSTRIAL LTD., NEW DELHI

In the result the appeal filed by the revenue stands statistically allowed

Bench: Shri N. K. Saini & Smt. Beena A. Pillai

disallowance of deferred revenue expenditure amounting to RS.1,05,077/- and long term capital loss of Rs.1,45,77,465/-. As regard levy of penalty under section 271(1)(c) on account of difference in income declared in original return of income filed under section 139 and return of income filed under section 153A of the Income

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

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

NESTLE R & D CENTRE INDIA PVT. LTD.,NEW DELHI vs. DCIT, CIRCLE- 18(1), NEW DELHI

In the result, the appeal of the assessee is dismissed

Bench: Shri Amit Shukla & Shri O.P. Kant[Through Video Conferencing]

5A, Connaught Circus, New Delhi New Delhi. PAN :AAACE2226P (Appellant) (Respondent) Appellant by None Respondent by Ms. Rinku Singh, Sr. DR Date of hearing 01.03.2021 Date of pronouncement 11.03.2021 ORDER PER O.P. KANT, AM: This appeal by the assessee is directed against the order dated 24th July, 2017 passed by the learned Commissioner of Income Tax (Appeals)-37, New Delhi

M/S VEE GEE INDUSTRIAL ENTERPRISES,FARIDABAD vs. ACIT, FARIDABAD

In the result, appeal of the revenue is dismissed

Bench: Shri R. K. Panda & Smt. Beena A. Pillaiassessment Year : 2007-08

5A to section 271(1)(c) is incorrect. He further held that for getting immunity from Explanation 5 to section 271(1)(c) of the I.T. Act, the assessee has to fulfill all the three conditions, which are as under :- 4 “(i) the assessee must make a statement under Section 132(4) in the course of search stating that