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

In the result, -Appeal in ITA No

Bench: Dr. B. R. R. Kumar & Shri Yogesh Kumar U.S.

section 14A of the Act, inter alia, by wrongly including (a) strategic/ business investments of the appellant; (b) investments yielding taxable income during the relevant year; and (c) investments not actually yielding exempt income during the relevant year, while applying formulae prescribed in Rule 8D of the Rules. 10 ITA Nos. 4796/Del/2017 & ors. M/s Religare Finvest Ltd. Vs. DCIT

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

In the result, -Appeal in ITA No

Bench: Dr. B. R. R. Kumar & Shri Yogesh Kumar U.S.

section 14A of the Act, inter alia, by wrongly including (a) strategic/ business investments of the appellant; (b) investments yielding taxable income during the relevant year; and (c) investments not actually yielding exempt income during the relevant year, while applying formulae prescribed in Rule 8D of the Rules. 10 ITA Nos. 4796/Del/2017 & ors. M/s Religare Finvest Ltd. Vs. DCIT

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

In the result, -Appeal in ITA No

Bench: Dr. B. R. R. Kumar & Shri Yogesh Kumar U.S.

section 14A of the Act, inter alia, by wrongly including (a) strategic/ business investments of the appellant; (b) investments yielding taxable income during the relevant year; and (c) investments not actually yielding exempt income during the relevant year, while applying formulae prescribed in Rule 8D of the Rules. 10 ITA Nos. 4796/Del/2017 & ors. M/s Religare Finvest Ltd. Vs. DCIT

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

In the result, -Appeal in ITA No

Bench: Dr. B. R. R. Kumar & Shri Yogesh Kumar U.S.

section 14A of the Act, inter alia, by wrongly including (a) strategic/ business investments of the appellant; (b) investments yielding taxable income during the relevant year; and (c) investments not actually yielding exempt income during the relevant year, while applying formulae prescribed in Rule 8D of the Rules. 10 ITA Nos. 4796/Del/2017 & ors. M/s Religare Finvest Ltd. Vs. DCIT

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

In the result, -Appeal in ITA No

Bench: Dr. B. R. R. Kumar & Shri Yogesh Kumar U.S.

section 14A of the Act, inter alia, by wrongly including (a) strategic/ business investments of the appellant; (b) investments yielding taxable income during the relevant year; and (c) investments not actually yielding exempt income during the relevant year, while applying formulae prescribed in Rule 8D of the Rules. 10 ITA Nos. 4796/Del/2017 & ors. M/s Religare Finvest Ltd. Vs. DCIT

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

In the result, -Appeal in ITA No

Bench: Dr. B. R. R. Kumar & Shri Yogesh Kumar U.S.

section 14A of the Act, inter alia, by wrongly including (a) strategic/ business investments of the appellant; (b) investments yielding taxable income during the relevant year; and (c) investments not actually yielding exempt income during the relevant year, while applying formulae prescribed in Rule 8D of the Rules. 10 ITA Nos. 4796/Del/2017 & ors. M/s Religare Finvest Ltd. Vs. DCIT

TECHNOLOGIES LTD) vs. ACIT

Appeals are allowed

disallowance of the commuted lease rentals. The appeal is allowed in this ground no. 7 of appeal. Since appeal is allowed in ground no. 7 of appeal, therefore, the plea of the appellant in ground no. 8 of appeal is infructuous and not necessary to be adjudicated.” 9.9 We find that the Ld. CIT(A) has distinguished the expenditure

TECHNOLOGIES LTD) vs. ACIT

Appeals are allowed

disallowance of the commuted lease rentals. The appeal is allowed in this ground no. 7 of appeal. Since appeal is allowed in ground no. 7 of appeal, therefore, the plea of the appellant in ground no. 8 of appeal is infructuous and not necessary to be adjudicated.” 9.9 We find that the Ld. CIT(A) has distinguished the expenditure

TECHNOLOGIES LTD) vs. ACIT

Appeals are allowed

disallowance of the commuted lease rentals. The appeal is allowed in this ground no. 7 of appeal. Since appeal is allowed in ground no. 7 of appeal, therefore, the plea of the appellant in ground no. 8 of appeal is infructuous and not necessary to be adjudicated.” 9.9 We find that the Ld. CIT(A) has distinguished the expenditure

DCIT, NEW DELHI vs. M/S. MARUTI SUZUKI INDIA LTD., NEW DELHI

In the result, the appeal of the Revenue in ITA No

Bench: Shri Shamim Yahya & Shri Kul Bharat[Assessment Year : 2010-11] Maruti Suzuki India Ltd., Vs Dcit, Plot No.1, Nelson Mandela Road, Circle-16(1), Vasant Kunj, New Delhi-110070. New Delhi. Pan-Aaacm0829Q Appellant Respondent [Assessment Year : 2010-11] Dcit, Vs Maruti Suzuki India Ltd., Circle-16(1), Plot No.1, Nelson Mandela Road, New Delhi. Vasant Kunj, New Delhi-110070. Pan-Aaacm0829Q Appellant Respondent Appellant By Shri Ajay Vohra, Sr.Adv., Shri Neeraj Jain, Adv. & Ms. Tejasvi Jain & Ms. Somya Jain, Ca Respondent By Shri G.C.Srivastava, Adv., Shri Kalrav Mehrotra, Adv. & Shri Mayank Patawari, Ca Date Of Hearing 11.11.2022 Date Of Pronouncement 09.02.2023

72,67,904/- made in the computation of taxable income, being the amounts disallowed in earlier years under section 43 B of the Act. 4.1 That

MARUTI SUZUKI INDIA LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result, the appeal of the Revenue in ITA No

Bench: Shri Shamim Yahya & Shri Kul Bharat[Assessment Year : 2010-11] Maruti Suzuki India Ltd., Vs Dcit, Plot No.1, Nelson Mandela Road, Circle-16(1), Vasant Kunj, New Delhi-110070. New Delhi. Pan-Aaacm0829Q Appellant Respondent [Assessment Year : 2010-11] Dcit, Vs Maruti Suzuki India Ltd., Circle-16(1), Plot No.1, Nelson Mandela Road, New Delhi. Vasant Kunj, New Delhi-110070. Pan-Aaacm0829Q Appellant Respondent Appellant By Shri Ajay Vohra, Sr.Adv., Shri Neeraj Jain, Adv. & Ms. Tejasvi Jain & Ms. Somya Jain, Ca Respondent By Shri G.C.Srivastava, Adv., Shri Kalrav Mehrotra, Adv. & Shri Mayank Patawari, Ca Date Of Hearing 11.11.2022 Date Of Pronouncement 09.02.2023

72,67,904/- made in the computation of taxable income, being the amounts disallowed in earlier years under section 43 B of the Act. 4.1 That

DCIT, NEW DELHI vs. M/S. MARUTI SUZUKI INDIA LTD., NEW DELHI

In the result, all the three appeals of the assessee are allowed as indicated above and the appeal of Revenue is partly allowed

Bench: Shris.Rifaur Rahman & Shri Vimal Kumar

SECTION 45, READ WITH SECTION 28(i), OF THE INCOME-TAX ACT, 1961 - CAPITAL GAINS, CHARGEABLE AS - ISSUE OF TAXABILITY OF SURPLUS ON SALE OF SHARES AND SECURITIES - CAPITAL GAINS OR BUSINESS INCOME - INSTRUCTIONS IN ORDER TO REDUCE LITIGATION CIRCULAR NO.6/2016 [F.NO.225/12/2016-ITA-II], DATED 29-2-2016 1. Sub-section (14) of section 2 of the Income

MARUTI SUZUKI INDIA LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result, all the three appeals of the assessee are allowed as indicated above and the appeal of Revenue is partly allowed

Bench: Shris.Rifaur Rahman & Shri Vimal Kumar

SECTION 45, READ WITH SECTION 28(i), OF THE INCOME-TAX ACT, 1961 - CAPITAL GAINS, CHARGEABLE AS - ISSUE OF TAXABILITY OF SURPLUS ON SALE OF SHARES AND SECURITIES - CAPITAL GAINS OR BUSINESS INCOME - INSTRUCTIONS IN ORDER TO REDUCE LITIGATION CIRCULAR NO.6/2016 [F.NO.225/12/2016-ITA-II], DATED 29-2-2016 1. Sub-section (14) of section 2 of the Income

C & S ELECTRIC LTD.,NEW DELHI vs. DCIT, CIRCLE- 1, LTU, NEW DELHI

In the result, the revenue's appeal stands dismissed as above

Disallowance of Club expenses of Rs.1,59,005/- (Gr. No. 4).\n6. The assessee has claimed deductions under section 80IC and 10AA of\nthe Act for its units situated in Uttarakhand and NOIDA respectively. The AO,\nquestioning the pricing of goods/material transferred to & from exempted to\nnon-exempted units & vice-versa and allocating the Head Office expenses of\nRs.4

DCIT, CIRCLE-20(1), NEW DELHI vs. PRIAPUS DEVELOPERS PRIVATE LIMITED, NEW DELHI

Bench: Shri Challa Nagendra Prasad & Shri Pradip Kumar Kedia

Section 14A of the Act and quantified the disallowance in terms of Rule 8D of the Income Tax Rules at Rs.1,26,86,514/-. The Assessing Officer also made another disallowance of Rs.25,72

C & S ELECTRIC LTD.,NEW DELHI vs. DCIT, CIRCLE- 1, LTU, NEW DELHI

In the result, the revenue’s appeal stands dismissed as above

Bench: Shri Yogesh Kumar U.S. & Shri Avdhesh Kumar Mishraita No. 2622/Del/2018, A.Y. 2013-14 Ita No. 2623/Del/2018, A.Y. 2014-15 Ita No. 7981/Del/2018, A.Y. 2015-16 C & S Electric Limited Deputy Commissioner Of 222, Okhla Industrial Estate Income Tax, Phase-Iii, New Delhi Vs. Circle-1, Ltu, New Delhi Pan: Aaacc0909K (Appellant) (Respondent) Ita No. 2532/Del/2018, A.Y.2013-14 Ita No. 2533/Del/2018, A.Y.2014-15 Ita No. 8274/Del/2018, A.Y.2015-16 Deputy Commissioner Of C & S Electric Limited Income Tax, (Formerly Controls & Circle-1, Ltu, Vs. Switchgear Co. Ltd.) New Delhi 222, Okhla Industrial Estate, Phase-Iii, New Delhi Pan: Aaacc0909K (Appellant) (Respondent) Appellant By Sh. Anil Bhalla, Ca Respondent By Sh. Rajesh Kumar Dhanesta, Sr. Dr Date Of Hearing 05/06/2025 Date Of Pronouncement 30/06/2025 Order Per Bench Cross Appeal By The Assessee & Revenue Containing Common Facts Were Heard Together Being Inter-Connected With Each Other & Are Being Disposed Off By This Common Order. Ita No.2532, 2533 & 8274/Del/2018 C & S Electric Ltd. 2. These Appeals Filed By The Assessee & Revenue Are Directed Against Orders Dated 10.01.18 & 25.09.2018 Respectively Of The Commissioner Of Income Tax (Appeals)-22, New Delhi [‘Cit(A)’].

Disallowance of Club expenses of Rs.1,59,005/- (Gr. No. 4). 6. The assessee has claimed deductions under section 80IC and 10AA of the Act for its units situated in Uttarakhand and NOIDA respectively. The AO, questioning the pricing of goods/material transferred to & from exempted to non-exempted units & vice-versa and allocating the Head Office expenses of Rs.4

ACIT, CIRCLE- 1, LTU, NEW DELHI vs. C&S ELECTRIC LTD., NEW DELHI

In the result, the revenue’s appeal stands dismissed as above

Bench: Shri Yogesh Kumar U.S. & Shri Avdhesh Kumar Mishraita No. 2622/Del/2018, A.Y. 2013-14 Ita No. 2623/Del/2018, A.Y. 2014-15 Ita No. 7981/Del/2018, A.Y. 2015-16 C & S Electric Limited Deputy Commissioner Of 222, Okhla Industrial Estate Income Tax, Phase-Iii, New Delhi Vs. Circle-1, Ltu, New Delhi Pan: Aaacc0909K (Appellant) (Respondent) Ita No. 2532/Del/2018, A.Y.2013-14 Ita No. 2533/Del/2018, A.Y.2014-15 Ita No. 8274/Del/2018, A.Y.2015-16 Deputy Commissioner Of C & S Electric Limited Income Tax, (Formerly Controls & Circle-1, Ltu, Vs. Switchgear Co. Ltd.) New Delhi 222, Okhla Industrial Estate, Phase-Iii, New Delhi Pan: Aaacc0909K (Appellant) (Respondent) Appellant By Sh. Anil Bhalla, Ca Respondent By Sh. Rajesh Kumar Dhanesta, Sr. Dr Date Of Hearing 05/06/2025 Date Of Pronouncement 30/06/2025 Order Per Bench Cross Appeal By The Assessee & Revenue Containing Common Facts Were Heard Together Being Inter-Connected With Each Other & Are Being Disposed Off By This Common Order. Ita No.2532, 2533 & 8274/Del/2018 C & S Electric Ltd. 2. These Appeals Filed By The Assessee & Revenue Are Directed Against Orders Dated 10.01.18 & 25.09.2018 Respectively Of The Commissioner Of Income Tax (Appeals)-22, New Delhi [‘Cit(A)’].

Disallowance of Club expenses of Rs.1,59,005/- (Gr. No. 4). 6. The assessee has claimed deductions under section 80IC and 10AA of the Act for its units situated in Uttarakhand and NOIDA respectively. The AO, questioning the pricing of goods/material transferred to & from exempted to non-exempted units & vice-versa and allocating the Head Office expenses of Rs.4

DCIT, CIRCLE- 1, LTU, NEW DELHI vs. C & S ELECTRIC LTD., NEW DELHI

In the result, the revenue’s appeal stands dismissed as above

Bench: Shri Yogesh Kumar U.S. & Shri Avdhesh Kumar Mishraita No. 2622/Del/2018, A.Y. 2013-14 Ita No. 2623/Del/2018, A.Y. 2014-15 Ita No. 7981/Del/2018, A.Y. 2015-16 C & S Electric Limited Deputy Commissioner Of 222, Okhla Industrial Estate Income Tax, Phase-Iii, New Delhi Vs. Circle-1, Ltu, New Delhi Pan: Aaacc0909K (Appellant) (Respondent) Ita No. 2532/Del/2018, A.Y.2013-14 Ita No. 2533/Del/2018, A.Y.2014-15 Ita No. 8274/Del/2018, A.Y.2015-16 Deputy Commissioner Of C & S Electric Limited Income Tax, (Formerly Controls & Circle-1, Ltu, Vs. Switchgear Co. Ltd.) New Delhi 222, Okhla Industrial Estate, Phase-Iii, New Delhi Pan: Aaacc0909K (Appellant) (Respondent) Appellant By Sh. Anil Bhalla, Ca Respondent By Sh. Rajesh Kumar Dhanesta, Sr. Dr Date Of Hearing 05/06/2025 Date Of Pronouncement 30/06/2025 Order Per Bench Cross Appeal By The Assessee & Revenue Containing Common Facts Were Heard Together Being Inter-Connected With Each Other & Are Being Disposed Off By This Common Order. Ita No.2532, 2533 & 8274/Del/2018 C & S Electric Ltd. 2. These Appeals Filed By The Assessee & Revenue Are Directed Against Orders Dated 10.01.18 & 25.09.2018 Respectively Of The Commissioner Of Income Tax (Appeals)-22, New Delhi [‘Cit(A)’].

Disallowance of Club expenses of Rs.1,59,005/- (Gr. No. 4). 6. The assessee has claimed deductions under section 80IC and 10AA of the Act for its units situated in Uttarakhand and NOIDA respectively. The AO, questioning the pricing of goods/material transferred to & from exempted to non-exempted units & vice-versa and allocating the Head Office expenses of Rs.4