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

disallowed by the Assessing Officer by treating the same as the loss of speculative nature by invoking the Explanation I.T.As No.2631/Del/2018 & 811, 812, 939, 940, 941, 942, 943/Del/2019 17 to section 73. The Assessing Officer also imposed penalty under section 271(1

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

disallowed by the Assessing Officer by treating the same as the loss of speculative nature by invoking the Explanation I.T.As No.2631/Del/2018 & 811, 812, 939, 940, 941, 942, 943/Del/2019 17 to section 73. The Assessing Officer also imposed penalty under section 271(1

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

disallowed by the Assessing Officer by treating the same as the loss of speculative nature by invoking the Explanation I.T.As No.2631/Del/2018 & 811, 812, 939, 940, 941, 942, 943/Del/2019 17 to section 73. The Assessing Officer also imposed penalty under section 271(1

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

disallowed by the Assessing Officer by treating the same as the loss of speculative nature by invoking the Explanation I.T.As No.2631/Del/2018 & 811, 812, 939, 940, 941, 942, 943/Del/2019 17 to section 73. The Assessing Officer also imposed penalty under section 271(1

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

disallowed by the Assessing Officer by treating the same as the loss of speculative nature by invoking the Explanation I.T.As No.2631/Del/2018 & 811, 812, 939, 940, 941, 942, 943/Del/2019 17 to section 73. The Assessing Officer also imposed penalty under section 271(1

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

disallowed by the Assessing Officer by treating the same as the loss of speculative nature by invoking the Explanation I.T.As No.2631/Del/2018 & 811, 812, 939, 940, 941, 942, 943/Del/2019 17 to section 73. The Assessing Officer also imposed penalty under section 271(1

EBRO INDIA PVT.LTD. ,DELHI vs. ACIT CIRCLE-7(1), DELHI

In the result, the ground no 4 raised by the assessee is allowed

Bench: SHRI S.RIFAUR RAHMAN (Accountant Member), SHRI YOGESH KUMAR U.S. (Accountant Member)

1) of the Act proceeded to treat the aforesaid sum of Rs.134.99 crores as unexplained credit under section 68 of the Act. While making the said addition, the NFAC vaguely alleged that the assessee has not filed the requisite details/ documentary evidence to establish the nature and source of credit in the form of share capital, nor it is proved

RICHMOND EDUCATIONAL SOCIETY,NOIDA vs. DCIT/ACIT CENTRAL CIRCLE, GHAZIABAD, GHAZIABAD

In the result, the appeal of the Assessee is allowed

1), and the order,\ndirection or decree, by whatever name called, holding that such non-\ncompliance has occurred, has either not been disputed or has attained finality,\nthen, the Principal Commissioner or the Commissioner may, by an order in writing,\ncancel the registration of such trust or institution:\nProvided that the registration shall not be cancelled under this sub-section

(Now known as Sony India Limited)

Sections (1) and (2) to Section 92C are applicable to the assessed, as well as the Assessing Officer invoking power under Sub-Section (3) to Section 92C of the Act. As noted above, sub-section (2) to Section 92C stipulates that most appropriate method, out of the methods specified in sub-section (1) shall be applied to determine

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

73,658 pertaining to prior period. Details enclosed at page no. 96 of PB on Merits. AO: In the assessment order, the assessing officer has disallowed the aforesaid expenses, on the ground that same pertained to prior period and are not allowable revenue expenditure against income of the relevant year. CIT(A): The CIT(A) deleted the disallowance made

ORIENTAL BANK OF COMMERCE,GURGAON vs. DCIT, NEW DELHI

In the result, the appeals of the assessee are allowed and the appeals of the Revenue are dismissed

Bench: Sh. A. D. Jain, Vice-Dr. B. R. R. Kumarita No. 1581/Del/2017 : Asstt. Year : 2012-13 Ita No. 1582/Del/2017 : Asstt. Year : 2013-14 Ita No. 1583/Del/2017 : Asstt. Year : 2014-15 Ita No. 1199/Del/2018 : Asstt. Year : 2015-16 Oriental Bank Of Commerce, Vs Addl. Cit, Central Accounts Office, Plot No. 5, Range-13 (Present Range-19) Sector-32, Institutional Area, New Delhi Gurgaon-122001 Dcit/Acit, Circle-19(1), New Delhi (Appellant) (Respondent) Pan No. Aaaco0191M

disallowed.” 42. However, the assessee has claimed deduction u/s 36(1)(vii) for a sum of Rs.315.00 crores in respect of bad debts written off identified separately in the profit & loss account other than those provisions which were claimed u/s 36(1)(viia). The AO has mentioned in his order that the assessee has provided complete details

ACIT, CIRCLE- 19(1), NEW DELHI vs. ORIENTAL BANK OF COMMERCE, GURGAON

In the result, the appeals of the assessee are allowed and the appeals of the Revenue are dismissed

Bench: Sh. A. D. Jain, Vice-Dr. B. R. R. Kumarita No. 1581/Del/2017 : Asstt. Year : 2012-13 Ita No. 1582/Del/2017 : Asstt. Year : 2013-14 Ita No. 1583/Del/2017 : Asstt. Year : 2014-15 Ita No. 1199/Del/2018 : Asstt. Year : 2015-16 Oriental Bank Of Commerce, Vs Addl. Cit, Central Accounts Office, Plot No. 5, Range-13 (Present Range-19) Sector-32, Institutional Area, New Delhi Gurgaon-122001 Dcit/Acit, Circle-19(1), New Delhi (Appellant) (Respondent) Pan No. Aaaco0191M

disallowed.” 42. However, the assessee has claimed deduction u/s 36(1)(vii) for a sum of Rs.315.00 crores in respect of bad debts written off identified separately in the profit & loss account other than those provisions which were claimed u/s 36(1)(viia). The AO has mentioned in his order that the assessee has provided complete details

ORIENTAL BANK OF COMMERCE,GURGAON vs. DCIT, NEW DELHI

In the result, the appeals of the assessee are allowed and the appeals of the Revenue are dismissed

Bench: Sh. A. D. Jain, Vice-Dr. B. R. R. Kumarita No. 1581/Del/2017 : Asstt. Year : 2012-13 Ita No. 1582/Del/2017 : Asstt. Year : 2013-14 Ita No. 1583/Del/2017 : Asstt. Year : 2014-15 Ita No. 1199/Del/2018 : Asstt. Year : 2015-16 Oriental Bank Of Commerce, Vs Addl. Cit, Central Accounts Office, Plot No. 5, Range-13 (Present Range-19) Sector-32, Institutional Area, New Delhi Gurgaon-122001 Dcit/Acit, Circle-19(1), New Delhi (Appellant) (Respondent) Pan No. Aaaco0191M

disallowed.” 42. However, the assessee has claimed deduction u/s 36(1)(vii) for a sum of Rs.315.00 crores in respect of bad debts written off identified separately in the profit & loss account other than those provisions which were claimed u/s 36(1)(viia). The AO has mentioned in his order that the assessee has provided complete details

ACIT, NEW DELHI vs. M/S. ORIENTAL BANK OF COMMERCE, GURGAON

In the result, the appeals of the assessee are allowed and the appeals of the Revenue are dismissed

Bench: Sh. A. D. Jain, Vice-Dr. B. R. R. Kumarita No. 1581/Del/2017 : Asstt. Year : 2012-13 Ita No. 1582/Del/2017 : Asstt. Year : 2013-14 Ita No. 1583/Del/2017 : Asstt. Year : 2014-15 Ita No. 1199/Del/2018 : Asstt. Year : 2015-16 Oriental Bank Of Commerce, Vs Addl. Cit, Central Accounts Office, Plot No. 5, Range-13 (Present Range-19) Sector-32, Institutional Area, New Delhi Gurgaon-122001 Dcit/Acit, Circle-19(1), New Delhi (Appellant) (Respondent) Pan No. Aaaco0191M

disallowed.” 42. However, the assessee has claimed deduction u/s 36(1)(vii) for a sum of Rs.315.00 crores in respect of bad debts written off identified separately in the profit & loss account other than those provisions which were claimed u/s 36(1)(viia). The AO has mentioned in his order that the assessee has provided complete details

ACIT, NEW DELHI vs. M/S. ORIENTAL BANK OF COMMERCE, GURGAON

In the result, the appeals of the assessee are allowed and the appeals of the Revenue are dismissed

Bench: Sh. A. D. Jain, Vice-Dr. B. R. R. Kumarita No. 1581/Del/2017 : Asstt. Year : 2012-13 Ita No. 1582/Del/2017 : Asstt. Year : 2013-14 Ita No. 1583/Del/2017 : Asstt. Year : 2014-15 Ita No. 1199/Del/2018 : Asstt. Year : 2015-16 Oriental Bank Of Commerce, Vs Addl. Cit, Central Accounts Office, Plot No. 5, Range-13 (Present Range-19) Sector-32, Institutional Area, New Delhi Gurgaon-122001 Dcit/Acit, Circle-19(1), New Delhi (Appellant) (Respondent) Pan No. Aaaco0191M

disallowed.” 42. However, the assessee has claimed deduction u/s 36(1)(vii) for a sum of Rs.315.00 crores in respect of bad debts written off identified separately in the profit & loss account other than those provisions which were claimed u/s 36(1)(viia). The AO has mentioned in his order that the assessee has provided complete details

ORIENTAL BANK OF COMMERCE,GURGAON vs. ACIT, CIRCLE- 19(1), NEW DELHI

In the result, the appeals of the assessee are allowed and the appeals of the Revenue are dismissed

Bench: Sh. A. D. Jain, Vice-Dr. B. R. R. Kumarita No. 1581/Del/2017 : Asstt. Year : 2012-13 Ita No. 1582/Del/2017 : Asstt. Year : 2013-14 Ita No. 1583/Del/2017 : Asstt. Year : 2014-15 Ita No. 1199/Del/2018 : Asstt. Year : 2015-16 Oriental Bank Of Commerce, Vs Addl. Cit, Central Accounts Office, Plot No. 5, Range-13 (Present Range-19) Sector-32, Institutional Area, New Delhi Gurgaon-122001 Dcit/Acit, Circle-19(1), New Delhi (Appellant) (Respondent) Pan No. Aaaco0191M

disallowed.” 42. However, the assessee has claimed deduction u/s 36(1)(vii) for a sum of Rs.315.00 crores in respect of bad debts written off identified separately in the profit & loss account other than those provisions which were claimed u/s 36(1)(viia). The AO has mentioned in his order that the assessee has provided complete details

ORIENTAL BANK OF COMMERCE,GURGAON vs. ADDL. CIT, NEW DELHI

In the result, the appeals of the assessee are allowed and the appeals of the Revenue are dismissed

Bench: Sh. A. D. Jain, Vice-Dr. B. R. R. Kumarita No. 1581/Del/2017 : Asstt. Year : 2012-13 Ita No. 1582/Del/2017 : Asstt. Year : 2013-14 Ita No. 1583/Del/2017 : Asstt. Year : 2014-15 Ita No. 1199/Del/2018 : Asstt. Year : 2015-16 Oriental Bank Of Commerce, Vs Addl. Cit, Central Accounts Office, Plot No. 5, Range-13 (Present Range-19) Sector-32, Institutional Area, New Delhi Gurgaon-122001 Dcit/Acit, Circle-19(1), New Delhi (Appellant) (Respondent) Pan No. Aaaco0191M

disallowed.” 42. However, the assessee has claimed deduction u/s 36(1)(vii) for a sum of Rs.315.00 crores in respect of bad debts written off identified separately in the profit & loss account other than those provisions which were claimed u/s 36(1)(viia). The AO has mentioned in his order that the assessee has provided complete details

RAVI AVIATION LEASING LIMITED,IRELAND vs. DCIT INT TAX CIRCLE 3(1)(1) NEW DELHI, NEW DELHI

In the result, appeals of the assesses are allowed, pro tanto

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishraआअसं.994/िद"ी/2025(िन.व. 2022-23) Kosi Aviation Leasing Ltd., C/O Dmd Advocates, 30, Nizamuddin East, New Delhi 110013 ...... अपीलाथ"/Appellant Pan : Aaick-6199-B बनाम Vs. Assistant Commissioner Of Income Tax, International Taxation, Circle 2(1)(2), Civic Centre, ....."ितवादी/Respondent Minto Road, New Delhi 110002 आअसं.1027/िद"ी/2025(िन.व. 2022-23) Hoohly Aviation Leasing Ltd., C/O Dmd Advocates, 30, Nizamuddin East, New Delhi 110013 ...... अपीलाथ"/Appellant Pan : Aafch-6609-C बनाम Vs. Assistant Commissioner Of Income Tax, International Taxation, Circle 2(1)(1), Civic Centre, ....."ितवादी/Respondent Minto Road, New Delhi 110002 आअसं.1070/िद"ी/2025(िन.व. 2022-23) Luni Aviation Leasing Ltd., C/O Dmd Advocates, 30, Nizamuddin East, New Delhi 110013 ...... अपीलाथ"/Appellant Pan : Aaecl-5180-H बनाम Vs. Assistant Commissioner Of Income Tax, International Taxation, Circle 2(2)(1), Civic Centre, ....."ितवादी/Respondent Minto Road, New Delhi 110002

disallowance of Rs.268,91,48,934/- out of lease rental payments under section 37(1) of the I.T. Act, 1961? (4) Whether payment of Supplementary Lease Rent of Rs.328,09,64,412 l-is an allowable business expenditure and TDS is not deductible thereon?” 20. While answering the aforesaid questions the Special Bench took note of the agreement between Indigo