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 deleted by Ld CIT(A). Thus, both, the grounds raised by the assessee as well as the Revenue are dismissed. 11. The ground No.1 of the appeal of the Revenue and additional ground No.4 of the appeal of the assessee are related to disallowance on account of provision for expenses. 11.1 Brief facts

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 deleted by Ld CIT(A). Thus, both, the grounds raised by the assessee as well as the Revenue are dismissed. 11. The ground No.1 of the appeal of the Revenue and additional ground No.4 of the appeal of the assessee are related to disallowance on account of provision for expenses. 11.1 Brief facts

DCIT, NEW DELHI vs. M/S. GUJARAT GUARDIAN LTD., NEW DELHI

In the result, appeal filed by the revenue against the direction of the Ld

Bench: Shri S.K.Yadav & Shri Prashant Maharishim/S. Guajarat Guardian Ltd, Vs. Dcit, 4-7/C, Dda Shopping Centre, Circle-12(1), (Now Circle- New Friends Colony, 10(2), New Delhi Cr Building, Ip Estate, Pan: Aaacg1622K New Delhi (Appellant) (Respondent) Dcit, Vs. M/S. Guajarat Guardian Ltd, Circle-12(1), (Now Circle-10(2), 4-7/C, Dda Shopping Cr Building, Ip Estate, Centre, New Delhi New Friends Colony, New Delhi Pan: Aaacg1622K (Appellant) (Respondent)

690 (Guj.) “Having heard learned counsel for the parties and critically examining the relevant provisions contained in section 80J in the light of the decisions cited before us, we are of the considered opinion that, as in the preceding assessment years, the appellant cannot be denied the benefit of deduction at the prescribed rate under section80J on the capital employed

MUFG BANK LTD,NEW DELHI vs. ACIT (INTERNATIONAL TAXATION) CIRCLE-2(2)(1), NEW DELHI

In the result appeal of the assessee is partly allowed

Bench: Shri Amit Shukla & Shri Prashant Maharishi(Through Video Conferencing) Mufg Bank Ltd, Vs. Acit (International Taxation), 5Th Floor, Worldmark 2, Asset 8, Circle-2(2)(1), Aerocity, Nh-8, New Delhi New Delhi Pan: Aabct3880D (Appellant) (Respondent)

690/– Under that interest income on pass through certificates which is claimed as exempt u/s 10 (35A) of the act. The assessee company has not disallowed the proportionate expenditure incurred on the above income as per the provisions of Section

PR. COMMISSIONER OF INCOME TAX-2 vs. M/S CARAF BUILDERS & CONSTRUCTIONS PVT. LTD.

Bench: HON'BLE MR. JUSTICE SANJIV KHANNA,HON'BLE MR. JUSTICE ANUP JAIRAM BHAMBHANI

disallowed under Section 14A leaving a balance sum of interest paid of Rs.8,55,97,765/-, which remained to be appropriated. Interest of Rs.8,55,97,765/- was set off against interest income of Rs.41,81,11,353/- and the taxable income, other than short term capital gains, was enhanced to Rs.33,31,99,690

SANDEEP KUMAR,NEW DELHI vs. ITO - WARD 1, PANIPAT, PANIPAT

In the result, appeal of the assessee is allowed

Bench: Shri Mahavir Singh & Shri Manish Agarwal[Assessment Year : 2018-19] Sandeep Kumar, Vs Ito C/O-B-50, Lgf, South Ward-1 Extension Part-Ii, Panipat New Delhi -110049 Pan-Aueps5626A Appellant Respondent Appellant By Shri Shantanu Jain, Adv. Ms. Jahnavi Khanna, Adv. Shri Gurjeet Singh, Ca Respondent By Shri Khitesh Gupta, Sr.Dr Date Of Hearing 26.11.2025 Date Of Pronouncement 28.11.2025 Order

690 and reflected in the return of income furnished under section 139 or (b) Determined by the Assessing Officer includes any income referred to in section 68 section 69, section 69A, section 69B, section 69C, Section 69D if such income is not covered under clause (a) the income tax payable shall be the aggregate of (i) the amount of income

M/S. INTERARCH BUILDING PRODUCTS PVT. LTD.,NEW DELHI vs. DCIT, NEW DELHI

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

Bench: Shri O.P. Kant & Shri Kuldip Singh[Through Video Conferencing] Assessment Year: 2006-07 Interarch Building Vs. Dcit Products Pvt. Ltd., Circle -11 (1) Farm No.8 Khasra New Delhi No.56/23/2, Dera Mandi Village, Mehrauli New Delhi-110047 Pan No.Aaaci0106J (Appellant) (Respondent)

Section 80-IA/80-IB of IT Act, held that while working out the profits of the eligible units, the profits are to be computed as if such eligible business is the only source of income of the assessee and the devices adopted to reduce or inflate the profits of eligible business have to be rejected. He further submitted that

M/S AT & T GLOBAL BETWORK SERVICES (INDIA) PVT. LTD.,,GURGAON vs. DCIT, NEW DELHI

In the result, the appeal of assessee in ITA No

Bench: Shri N.K. Billaiya & Shri Kuldip Singh[A.Y 2008-09] At &T Global Network Services [India] Vs. The Dy. C.I.T Pvt Ltd, Vatika Triangle Circle - 2 (1) 3Rd Floor, Sushant Lok - I New Delhi Block A, Gurgaon Pan: Aafca 8810 L [A.Y 2008-09] The Dy. C.I.T Vs. At &T Global Network Services Circle 2(1) [India] Pvt Ltd, Vatika Triangle 3Rd Floor, Sushant Lok - I New Delhi Block A, Gurgaon Pan: Aafca 8810 L (Applicant) (Respondent) Assessee By : Shri Kanchan Kaushal, Adv Ms. Chinu Bhasin, Ca Department By : Shri H.K. Choudhary, Cit-Dr

disallowed by invoking rise provisions of section 40(a)(1) of the Act No short deduction of tax at source In this connection, we wish to submit that there was no short deduction on part of AT&T GNS and toe aforesaid difference between the expenses debited to the profit and loss account and the amount reported in the withholding

MANOJ KUMAR,PANIPAT vs. INCOME TAX OFFICER, WARD -1, PANIPAT, PANIPAT

In the result, appeal of the assessee is allowed

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal[Assessment Year : 2018-19] Manoj Kumar Vs Ito Prop. Avitex India, Barsat Ward-1 Road, Opp.Kirpal Ashram, Panipat Panipat, Haryana-132103. Pan-Aaepo2553J Appellant Respondent Assessee By Shri Suresh Kumar Gupta, Ca Revenue By Ms. Amisha S.Gutpa, Cit Dr Date Of Hearing 27.11.2025 Date Of Pronouncement 29.01.2026 Order Per Manish Agarwal, Am : The Captioned Appeal Is Filed By Assessee Against The Order Dated 27.03.2025 Passed By Ld. Pr. Commissioner Of Income Tax, Rohtak [“Ld. Pr. Cit”] U/S 263 Of The Income Tax Act, 1961 [“The Act”] Arising Out Of Assessment Order Dated 24.02.2023 Passed U/S 147 R.W.S. 144B Of The Act Pertaining To Assessment Year 2018-19. 2. Brief Facts Of The Case Are That The Assessee Filed His Return Of Income On 18.10.2018, Declaring Total Income Of Inr 5,12,820/-. Based On The Available That The Assessee Had Accepted Accommodation Entries In The Form Of Bogus Purchases From M/S. Soni Textiles Of Inr 11,47,500/-, Case Was Re-Opened By Issue Of Notice U/S 148 On 29.03.2022. In Response To The Notice, Assessee Filed Return Of Income On 25.11.2022, Declaring Total Income Of Inr 5,12,820/-. Thereafter, Various Notices Were Issued From Time To Time However, Were Remained Uncompiled With. Thereafter, Ao Vide Order Dated 24.02.2023 Passed U/S 147 R.W.S. 144B Of The Act Assessed The Income Of The Assessee At Inr 16,60,320/- By Making Addition Of Alleged Bogus Purchases.

690 and reflected in the return of income furnished under section 139 or (b) Determined by the Assessing Officer includes any income referred to in section 68 section 69, section 69A, section 69B, section 69C, Section 69D if such income is not covered under clause (a) the income tax payable shall be the aggregate of the amount of income

JOGINDER KUMAR & SONS HUF,PANIPAT vs. PCIT ROTAK, ROTAK

In the result, the appeal of the assessee is allowed

Bench: Shri Anubhav Sharma & Shri Manish Agarwaljoginder Kumar & Sons Huf Pcit, 352/6, Near S D Modern School, Rohtak. Panipat-132103. Vs. Pan- Aachj6257L (Appellant) (Respondent) Assessee By Shri Dhurv Goel, Ca Department By Shri Pradumna Kumar Singh, Sr. Dr Date Of Hearing 04.09.2025 Date Of Pronouncement 27.11.2025 O R D E R Per Manish Agarwal, Am: This Appeal Is Filed By The Assessee Against The Order Of The Ld. Principal Commissioner Of Income Tax, Rohtak (‘The Pcit’ In Short) Passed U/S 263 Of The Income Tax Act, 1961 Dated 21.03.2025 Wherein The Ld. Pcit Held The Assessment Order As Erroneous & Prejudicial To The Interest Of The Revenue In Terms Of Explanation 2 Of Section 263 & Direct The Ao To Conduct Fresh Enquiries & Passed The Speaking Order.

690 and reflected in the return of income furnished under section 139 or (b) Determined by the Assessing Officer includes any income referred to in section 68 section 69, section 69A, section 69B, section 69C, Section 69D if such income is not covered under clause (a) the income tax payable shall be the aggregate of (i) the amount of income

M/S. RELIGARE CAPITAL MARKETS LTD.,NEW DELHI vs. DCIT, NEW DELHI

Appeal is partly allowed in above terms

Bench: SHRI SATBEER SINGH GODARA (Judicial Member), SHRI S. RIFAUR RAHMAN (Accountant Member)

690,114,864 paid by the assessee to its employees during the subject AY on the ground that it is capital in nature. 4.2 That on facts and in circumstances of the case and in law, the AO while disallowing the salary and bonus expenditure has failed to appreciate that the assessee is engaged in routine business of institutional broking

ALCATEL-LUCENT INDIA LTD.,,GURGAON vs. ADDL.CIT, SPECIAL RANGE-1, NEW DELHI

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

Bench: Shri H.S. Sidhu & Shri O.P. Kantassessment Year: 2013-14 M/S. Alcatel-Lucent India Vs. Addl. Cit, Ltd., Special Range-1, New Delhi Dlf Cyber Greens, 14 & 15Th Floor, Tower C, Phase-Iii, Dlf City, Gurgaon Pan :Aacca8667N (Appellant) (Respondent) Appellant By Shri Deepak Chopra, Adv.; Ms. Manasvini Bajpai, Adv.; & Shri. Ankul Goyal, Adv. Respondent By Shri Sanjay I. Bara, Cit(Dr)

section 92CA(3) of the Act proposed adjustment of Rs.91,24,40,290/- to the value of the International Transaction. The Assessing Officer in the draft assessment order dated 30/12/2016 included that adjustment proposed by the learned TPO and other additions. Against the draft assessment order, the assessee filed objections before the learned DRP. The learned DRP after considering

DCIT, NEW DELHI vs. M/S. PODDAR PIGMENTS LTD., NEW DELHI

In the result, the appeal of the Revenue is dismissed

Bench: Sh. H.S. Sidhu & Sh. O.P. Kantassessment Year: 2007-08 Vs. M/S. Poddar Pigments Ltd., A- Dcit, Circle-14(1), New Delhi 283, Ground Floor, Okhla Indl. Area-1, New Delhi. Pan : Aaacp1125E (Appellant) (Respondent) Appellant By Sh. F.R. Meena, Sr.Dr Respondent By Sh. P.C. Parwal, Fca Date Of Hearing 08.08.2016 Date Of Pronouncement 05.10.2016 Order Per O.P. Kant, A.M.: This Appeal By The Revenue Is Directed Against The Order Dated 15/01/2014 Passed By The Learned Commissioner Of Income-Tax (Appeals) For Assessment Year 2007-08, Wherein He Allowed The Appeal Of The Assessee Against Order Of The Assessing Officer Dated 29/03/2012 Levying Penalty Under Section 271(1)(C) Of The Income-Tax Act, 1961. The Grounds Of Appeal Raised By The Revenue Are As Under: I. On The Facts & Circumstances Of The Case, The Learned Commissioner Of Income Tax (Appeals) Erred In Deleting The Penalty Made By The Assessing Officer U/S 271(1)(C) Of The Act On Account Of Additions Under The Head Of U/S 40(A)(I) Amounting To Rs.9,14,191/- & Ltcg Amounting To Rs.41,62,154/- Holding That The Assessee Has Not Furnished Any Inaccurate Particulars Or Has Made Any Deliberate Attempt To Conceal Income. Ii. On The Facts & Circumstances Of The Case, The Learned Commissioner Of Income Tax (Appeals) Erred In Deleting The Above

disallowance of Rs.9,14,191/- under section 40(a)(i) of the Act was levied by the Assessing Officer on the following three amounts: (i) payment of Rs.4,43,363/- made to M/s. Coperion Werner & Pfleiderer (ii) payment of Rs. 4,44,690

ACIT, NEW DELHI vs. M/S. AIR SHAGOON NETWORK PVT. LTD., NEW DELHI

In the result appeal of the revenue is dismissed

Bench: Shri Amit Shukla & Shri O.P. Kantasstt. Year: 2012-13 Acit M/S. Air Shagoon Network Pvt. Ltd. Circle-2(1) C-37, Hauz Khas New Delhi. New Delhi – 110 016 Pan Aaeca0868R Vs. (Appellant) (Respondent)

Section 201(1), hence, the disallowance of RS.1,75,76,690/- is deleted. 4 3. Before us, Ld. DR submitted

CROSSLINK FINLEASE PVT. LTD.,NEW DELHI vs. ITO WARD - 6(4), NEW DELHI

In the result, the appeal is partly allowed for statistical

Bench: Shri Saktijit Deyassessment Year: 2009-10 M/S. Cross Links Finlease Vs. Income Tax Officer, Pvt. Ltd. , Ward-6(4), B-1, Kalindi Colony, New Delhi New Delhi Pan :Aabcc3727A (Appellant) (Respondent)

690/-. The return of income filed by the assessee was processed under section 143(1) of the Act. Subsequently, the Assessing Officer received information from Investigation Wing indicating that the assessee is one of the companies which has created fictitious profit and loss by misusing the client code modification facility in Future and Option (F & O) segment of National Stock

REC LIMITED,NEW DELHI vs. ACIT-10 (OSD), DELHI, NEW DELHI

disallowed by stating that\nprocessing fee is not derived from LT\nfinancing. Issue pending in the present\nappeal.\ni\ne\n202021\n554198049\n0\nNo addition on said issue by Ld. AO in the\nAssessment Order passed dated 28.09.2022\nt\n202122\n641301896.5\n0\nNo addition on said issue by Ld. AO in the\nAssessment Order passed dated 26.12.2022\n13\nITA Nos.319

M/S. NEW DELHI TELEVISION LTD.,NEW DELHI vs. ACIT, NEW DELHI

Bench: Shri H. S. Sidhu & Shri Prashant Maharishinew Delhi Television Ltd, Vs. Acit, 207, Okhla Industrial Estate, Phase- Circle-13(1), Iii, New Delhi New Delhi Pan: Aaacn0865D (Appellant) (Respondent) Acit, Vs. New Delhi Television Ltd, Circle-13(1), 207, Okhla Industrial Estate, New Delhi Phase-Iii, New Delhi Pan: Aaacn0865D (Appellant) (Respondent)

690/-by relying on the ITAT decision in the assessee's own case for the AY 2006-07, ignoring the fact that the revenue is in appeal. Thus, the issue has not attained its finality. 2. On the facts and circumstances of the case and in law, the Ld.CIT (A) has erred in reducing the disallowance of software expenses from

DCIT, NEW DELHI vs. M/S. NEW DELHI TELEVISION LTD., NEW DELHI

Bench: Shri H. S. Sidhu & Shri Prashant Maharishinew Delhi Television Ltd, Vs. Acit, 207, Okhla Industrial Estate, Phase- Circle-13(1), Iii, New Delhi New Delhi Pan: Aaacn0865D (Appellant) (Respondent) Acit, Vs. New Delhi Television Ltd, Circle-13(1), 207, Okhla Industrial Estate, New Delhi Phase-Iii, New Delhi Pan: Aaacn0865D (Appellant) (Respondent)

690/-by relying on the ITAT decision in the assessee's own case for the AY 2006-07, ignoring the fact that the revenue is in appeal. Thus, the issue has not attained its finality. 2. On the facts and circumstances of the case and in law, the Ld.CIT (A) has erred in reducing the disallowance of software expenses from