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 made by the assessing officer under section 40(a)(ia) of the Act.” 6. Considered the rival submissions and material

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 made by the assessing officer under section 40(a)(ia) of the Act.” 6. Considered the rival submissions and material

PRAYAG POLYTECH PVT. LTD.,NEW DELHI vs. ADDL. CIT, SPECIAL RANGE- 7, NEW DELHI

In the result, the appeal of the assessee is allowed

Bench: Shri H.S. Sidhu & Shri B.R.R. Kumarassessment Year: 2014-15

disallowance u/s. 68 actually comes to RS. 10,46,00,000/-. In appeal filed by the Assessee, Ld. CIT(A) deleted the addition of RS. 1,10,00,000/- in respect of I World Business Solutions 2 Pvt. Ltd. and Rs. 15,00,000/- in respect of KG Embroidery Mills Ltd. vide order dated 28.6.2017. Aggrieved with the aforesaid action

ADDL. CIT, SPECIAL RANGE- 7, NEW DELHI vs. PRAYAG POLYTECH PVT. LTD., NEW DELHI

In the result, the appeal of the assessee is allowed

Bench: Shri H.S. Sidhu & Shri B.R.R. Kumarassessment Year: 2014-15

disallowance u/s. 68 actually comes to RS. 10,46,00,000/-. In appeal filed by the Assessee, Ld. CIT(A) deleted the addition of RS. 1,10,00,000/- in respect of I World Business Solutions 2 Pvt. Ltd. and Rs. 15,00,000/- in respect of KG Embroidery Mills Ltd. vide order dated 28.6.2017. Aggrieved with the aforesaid action

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

Disallowance of reimbursement of expenses under section 40(a)(ia) Facts: During the year under consideration, the assessee claimed expenses of Rs. 6

TECHNOLOGIES LTD) vs. ACIT

Appeals are allowed

disallowance was made by the AO by invoking provisions of Section 14A of the Act and Rule 8D of the Rules. The break-up of the said figure is detailed out hereafter. S. No. Particulars Amount (Rs.) 1. Direct expenditure concerning exempt Nil 2021:DHC:1941-DB ITA 213-215/2020 Page 6

TECHNOLOGIES LTD) vs. ACIT

Appeals are allowed

disallowance was made by the AO by invoking provisions of Section 14A of the Act and Rule 8D of the Rules. The break-up of the said figure is detailed out hereafter. S. No. Particulars Amount (Rs.) 1. Direct expenditure concerning exempt Nil 2021:DHC:1941-DB ITA 213-215/2020 Page 6

TECHNOLOGIES LTD) vs. ACIT

Appeals are allowed

6 of 33 income [(refer Rule 8D(2)(i)] 2. Interest expenditure not directly attributable to any particular income [(refer Rule 8D (2)(ii)] 66,48,325 3. ½% of average investments [(refer Rule 8D(2)(iii)] 97,39,000 Total 1,63,87,325 Less: Suo motu disallowance by appellant/assessee 7,79,063 DISALLOWANCE

RELIGARE FINVEST LTD,NEW DELHI vs. ADDL.CIY, RANGE-21, NEW DELHI

In the result, for assessment year 2007-08 the appeal of the assessee as well as Revenue are dismissed

Bench: Shri O.P. Kant & Shri Kuldip Singh, Judicialmember

section 14A of the Act with rule 8D of the Income-tax Rules, 1962 (In short the ‘Rules’) computed disallowance of Rs.1,80,83,891 as under: 6

ACIT, CIRCLE- 21(1), NEW DELHI vs. RELIGARE FINVEST LTD., NEW DELHI

In the result, for assessment year 2007-08 the appeal of the assessee as well as Revenue are dismissed

Bench: Shri O.P. Kant & Shri Kuldip Singh, Judicialmember

section 14A of the Act with rule 8D of the Income-tax Rules, 1962 (In short the ‘Rules’) computed disallowance of Rs.1,80,83,891 as under: 6

ACIT,, NEW DELHI vs. M/S RELIGARE FINVEST LTD.,, NEW DELHI

In the result, for assessment year 2007-08 the appeal of the assessee as well as Revenue are dismissed

Bench: Shri O.P. Kant & Shri Kuldip Singh, Judicialmember

section 14A of the Act with rule 8D of the Income-tax Rules, 1962 (In short the ‘Rules’) computed disallowance of Rs.1,80,83,891 as under: 6

M/S RELIGARE FINVEST LTD.,,NEW DELHI vs. DCIT, NEW DELHI

In the result, for assessment year 2007-08 the appeal of the assessee as well as Revenue are dismissed

Bench: Shri O.P. Kant & Shri Kuldip Singh, Judicialmember

section 14A of the Act with rule 8D of the Income-tax Rules, 1962 (In short the ‘Rules’) computed disallowance of Rs.1,80,83,891 as under: 6

HERO MOTO CORP LTD.,NEW DELHI vs. NEAC, DELHI

Bench: Shri Kul Bharat & Shri Prashant Maharishi(Through Video Conferencing)

6. That the assessing officer erred on facts and in law in disallowing a sum of Rs.8,92,49,490 in respect of provision for advertisement expenses incurred at the head office at end of the relevant previous year, which were reversed in the succeeding year, alleging the same to be excessive. 6.1 That the assessing officer erred on facts

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

6. That the CIT(A), in view of the facts and circumstances of the case, has erred on facts and in law in restoring the matter to the Assessment Officer and not allowing the deduction claimed by the Assessee under Section 36(1)(viii) of the Income Tax Act 1961. 7. That the disallowance

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

6. That the CIT(A), in view of the facts and circumstances of the case, has erred on facts and in law in restoring the matter to the Assessment Officer and not allowing the deduction claimed by the Assessee under Section 36(1)(viii) of the Income Tax Act 1961. 7. That the disallowance

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

6. That the CIT(A), in view of the facts and circumstances of the case, has erred on facts and in law in restoring the matter to the Assessment Officer and not allowing the deduction claimed by the Assessee under Section 36(1)(viii) of the Income Tax Act 1961. 7. That the disallowance

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

6. That the CIT(A), in view of the facts and circumstances of the case, has erred on facts and in law in restoring the matter to the Assessment Officer and not allowing the deduction claimed by the Assessee under Section 36(1)(viii) of the Income Tax Act 1961. 7. That the disallowance

M/S. BAIN & COMPANY INDIA PVT. LTD.,GURGAON vs. ITO (TDS) (INTERNATIONAL TAXATION), NEW DELHI

6 research charges, etc., the AO held that the same are in the nature of consultancy payments and, hence, taxes are required to be withheld on the same. In connection with other expenses under the head ‘Client related expenses’, travel expenses, hotel cost, etc., the AO held that since these expenses are closely linked with the obligation of the assessee