ADDL. CIT, NEW DELHI vs. M/S IRCON INTERNATIONAL LTD.,, NEW DELHI

In the result, appeal of the Assessee is 7

Bench: Shri Anil Chaturvedi & Ms. Astha Chandra

Disallowance of deduction u/s 801 A: Income through PE & u/s 115JB: 41. These issues are akin to the grounds adjudicated above in ITA No. 2401/Del/2013 for the A.Y. 2006-07, hence the same ratio applies. The appeal of the assessee on this ground is allowed." 2.4. It can, thus, be seen that the Hon'ble ITAT was not benefitted

M/S. IRCON INTERNATIONAL LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result, appeal of the Assessee is 7

Bench: Shri Anil Chaturvedi & Ms. Astha Chandra

Disallowance of deduction u/s 801 A: Income through PE & u/s 115JB: 41. These issues are akin to the grounds adjudicated above in ITA No. 2401/Del/2013 for the A.Y. 2006-07, hence the same ratio applies. The appeal of the assessee on this ground is allowed." 2.4. It can, thus, be seen that the Hon'ble ITAT was not benefitted

DCIT CENTRAL CIRCLE-28, NEW DELHI vs. JINDAL ITF LIMITED, NEW DELHI

Accordingly, the appeal and application are dismissed

Bench: Shri G. S. Pannu & Ms. Madhumita Royi.T.A. No. 1776/Del/2023 (Assessment Year : 2012-13) Dcit Vs. M/S. Jindal Itf Limited Central Circle – 28 28, Shivaji Marg, New Delhi New Delhi-110 015 Pan: Aabcj 9263 C (Appellant) .. (Respondent)

Section 14A(2) of the Act, the Learned AO opined that the claim of expenditure of assessee was incorrect and quantum of disallowance was computed as per Rule 8D of the Income Tax Rules at Rs.20,98,39,135/- and restricted the disallowance to Rs.20,54,64,745/- i.e. to the extent of expenditure claimed by the assessee under

ADIDAS INDIA MARKETING PVT. LTD.,NEW DELHI vs. NATIONAL E- ASSESSMENT CENTRE, NEW DELHI

In the result, appeal of the assessee is allowed

Bench: Sh. Anil Chaturvedi & Sh. Yogesh Kumar Us & Stay Application No.73/Del/2021 (Assessment Year : 2016-17)

disallowance under section 40(a)(i) of the Act. The learned DRP in their order has listed the activities carried out by the Adidas International Trading BV in relation to procurement of goods as under: “a. Finding manufacturers for the goods concerned and making arrangements for their manufacture; b. Sourcing samples. c. placing orders for and / or purchase goods

DCM SHRIRAM LTD,NEW DELHI vs. ACIT, CIRCLE-7(1), NEW DELHI

section 80 IA of the Act, the\nassessee has also made application for submission of following additional\nevidence under Rule 29 of ITAT:\na) Detailed working of enhanced deduction u/s 80-IA of the Act.\nb) Chartered engineer's certificate computing the equivalent value of\nsteam.\nc) Supplementary Form 10CCBs along with power accounts of all the\neligible plants

DCM SHRIRAM LIMITED,DELHI vs. ASSESSMENT UNIT, DELHI

section 80 IA of the Act, the\nassessee has also made application for submission of following additional\nevidences under Rule 29 of ITAT:\na) Detailed working of enhanced deduction u/s 80-IA of the Act.\nb) Chartered engineer's certificate computing the equivalent value of\nsteam.\nc) Supplementary Form 10CCBs along with power accounts of all the\neligible plants

DCIT, NEW DELHI vs. DCM SHRIRAM LTD, NEW DELHI

section 80 IA of the Act, the\nassessee has also made application for submission of following additional\nevidences under Rule 29 of ITAT:\n\na) Detailed working of enhanced deduction u/s 80-IA of the Act.\nb) Chartered engineer's certificate computing the equivalent value of\nsteam.\nc) Supplementary Form 10CCBs along with power accounts of all the\neligible plants

DCM SHRIIRAM LIMITED,NEW DELHI vs. NEAC, NEW DELHI

section 80 IA of the Act, the\nassessee has also made application for submission of following additional\nevidences under Rule 29 of ITAT:\n\na) Detailed working of enhanced deduction u/s 80-IA of the Act.\nb) Chartered engineer's certificate computing the equivalent value of\nsteam.\nc) Supplementary Form 10CCBs along with power accounts of all the\neligible plants

ANGELIC CONSTRUCTION PRIVATE LIMITED,NEW DELHI vs. ACIT, CENTRAL CIRCLE-8

In the result, the appeal of the assessee is dismissed

Bench: Sh. S. Rifaur Rahman & Sh. Sudhir Kumarassessment Year: 2011-12 Angelic Construction Private Vs Acit Central Circle -8 Limited New Delhi, H.No. 119 New Delhi G/F Gali No -1Kh No Khajuri Khas Near Shiv Mandir New Delhi-110094 Pan No. Aaacc1080F (Appellant) (Respondent) Appellants By None Present Respondent By Sh. Amit Katoch, Sr. Dr. Date Of Hearing: 11/09/2024 Date Of Pronouncement: 16/10/2024 Order Per Sudhir Kumar, Jm:

disallowance can be made on the basis of presumptions. 5. That the action of the Ld. CIT Appeal in confirming the addition of Rs. 8,25,801/- on account of ignorance of the term "expenditure incurred" in section

ASSOCIATED TECHNO PLASTIC P. LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result, the appeal of the assessee is dismissed

Bench: Shri Kul Bharat & Shri Brajesh Kumar Singh[Assessment Year : 2008-09] Associated Techno Plastic P.Ltd., Vs Dcit, Elegence Level-2, Mathura Road, Circle-2(1), Jasola, New Delhi-110025. New Delhi. Pan-Aaaca2525K Appellant Respondent Appellant By None Respondent By Shri Kanv Bali, Sr. Dr Date Of Hearing 08.05.2024 Date Of Pronouncement 22.05.2024

disallowance are contained in sub-sections (2) and (3) thereof. Sub-section (2) and (3) seek to achieve the underlying object of Section 14A(1) of the Act that any expenditure incurred in relation to exempt income should not be allowed deduction. It is also fairly well settled by a catena of decisions that procedural provisions apply to all pending

U K PAINTS INDIA PVT. LTD.,NEW DELHI vs. ACIT, CIRCLE- 27(1), NEW DELHI

In the result, appeal of the Assessee is allowed

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

801/-. Ld. Counsel for the assessee further submitted that both the Ld. AO and Ld. CIT(A) have picked up the figure of Rs. 49,97,853/- from audit report which was in the row 26(i)(B)(b). The said information given in the Tax Audit Report was not for the purpose of disallowance under section

HONDA MOTORCYCLE AND SCOOTER INDIA PVT. LTD. ,GURGAON vs. ACIT, CIRCLE-1(1), GURUGRAM

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

Bench: SHRI SHAMIM YAHYA (Accountant Member), SHRI CHALLA NAGENDRA PRASAD (Judicial Member)

section 43B of the Act without appreciating that the differential amount has already been disallowed by the Assessee in the ITR form, thus leading to double disallowance of same amount in the hands of the Assessee which is totally against the provisions of law. 16.4 That the AO erred in not following the direction issued by the DRP in Para

CANADIAN SPECIALITY VINYLS,NEW DELHI vs. ITO WARD - 63(4), NEW DELHI

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

Bench: Shri Chandra Mohan Garg & M.Balaganeshassessment Year: 2015-16 M/S. Canadian Specialty Vinyls Ito Ward-63(4), Delhi 110055 49, Rani Janshi Road, Jhandewalan, New Delhi 110055 Vs. Pan Aagfc 0200 J

disallowance of deduction claimed under section 801C of Income Tax Act of Rs. 2,00,10,879/- on account of late filling of income tax return. He further submitted that the CIT (A) has also erred on facts and in law for not considering the timely filling of Audit Report us 80IC in form 10CCB under rule 18BBB

MODI ENTERTAINMENT LTD vs. DCIT CIRCLE 5 (1),

In the result, the appeal of the assessee on this ground is dismissed

Bench: Sh. Saktijit Deydr. B. R. R. Kumar

disallowance could be made. Accordingly, we direct the Assessing Officer to delete the amount of Rs.88,290/- from the book profit." Thus, he submitted that the decision of Hon'ble Supreme Court in the case of Apollo Tyres Ltd. was duly considered by Tribunal before taking contrary view in the matter. But Hon'ble Delhi High Court did not accept

DEPUTY COMMISSIONER OF INCOME TAX, NEW DELHI vs. GLOBAL AGRO CORP, NEW DELHI

In the result, appeal of the Revenue is dismissed

Bench: Shri Anubhav Sharma & Shri Manish Agarwal[Assessment Year : 2017-18] Dcit Vs Global Agro Corp, Room No.1704, Plot No.07,1St Floor, E-2 Block, Central Market West Civic Centre, Avenue Road, New Delhi-110002. West Punjabi Bagh, New Delhi-110026. Pan-Aakfg2650A Appellant Respondent Revenue By Shri Dheeraj Kumar Jaiswal, Sr.Dr Assessee By Shri Nitin Gulati, Ca Date Of Hearing 17.09.2025 Date Of 21.11.2025 Pronouncement Order Per Manish Agarwal, Am : The Present Appeal Is Filed By The Revenue Against The Order Dated 19.07.2024 Passed By Ld. Commissioner Of Income Tax (A), [“Ld.Cit(A)”], National Faceless Appeal Centre (“Nfac”), Delhi In Appeal No. Cit(A), Delhi-15/10990/2019-20 U/S 250 Of The Income Tax Act,1961 [“The Act”] Arising Out Of The Assessment Order Dated 31.12.2019 Passed U/S 143(3) Of The Act Pertaining To Assessment Year 2017-18. 2. Brief Facts Of The Case Are That Assessee Is A Partnership Firm, Engaged In Export Of Rice & E-Filed Its Return Of Income On 28.09.2017 Declaring Income At Inr 66,28,650/-. The Case Was Selected Through Cass & After Considering The Submissions Made By The Assessee From Time To Time, Assessment Was Completed U/S 143(3) Vide Assessment Order Dated 31.12.2019 Wherein Following Additions Were Made:

disallowance of INR 32,30,550/- of court settlement expenses. 3. Against the said order, assessee filed an appeal before Ld. CIT(A) who vide order dated 19.07.2024, allowed the appeal of the assessee. 4. Aggrieved by the order of Ld. CIT(A), Revenue is in appeal before the Tribunal by taking following grounds of appeal:- 1. That

M/S SHRING CONSTRUCTION CO. PVT. LTD.,,DEHRADUN vs. ACIT, MUZAFFARNAGAR

Bench: Sh. Satbeer Singh Godara & Sh. Naveen Chandraita No. 5226/Del/2016 : Asstt. Year: 2012-13 Ita No. 7057/Del/2018 : Asstt. Year: 2012-13 M/S Shring Construction Company Pvt. Vs Acit/Dcit, Ltd., D-245, Nehru Colony, Haridwar Circle-2, Road, Dehradun Muzaffarnagar (Appellant) (Respondent) Pan No. Aabcr4560L Assessee By : Sh. Ankit Gupta, Adv. Revenue By : Ms. Harpreet Kaur Hansra, Sr. Dr Date Of Hearing: 11.02.2026 Date Of Pronouncement: 11.02.2026 Order Per Satbeer Singh Godara: These Assessee’S Twin Appeals Ita Nos. 5226/Del/2016 &

disallowance of Rs.1,26,89,824/- and Rs.7,62,000/- on payments made to contractors/sub-contractors and legal and interest charges etc. as well as treating it’s secured loans of Rs.24,00,000/- as unexplained cash credits u/s 68 of the Act; respectively. 4. Both the parties vehemently reiterate their respective stands against and in support of the impugned disallowance/additions

SHRING CONSTRUCTION COMPANY PVT. LTD.,DEHRADUN vs. DCIT, CIRCLE-2, MUZAFFARNAGAR

Bench: Sh. Satbeer Singh Godara & Sh. Naveen Chandraita No. 5226/Del/2016 : Asstt. Year: 2012-13 Ita No. 7057/Del/2018 : Asstt. Year: 2012-13 M/S Shring Construction Company Pvt. Vs Acit/Dcit, Ltd., D-245, Nehru Colony, Haridwar Circle-2, Road, Dehradun Muzaffarnagar (Appellant) (Respondent) Pan No. Aabcr4560L Assessee By : Sh. Ankit Gupta, Adv. Revenue By : Ms. Harpreet Kaur Hansra, Sr. Dr Date Of Hearing: 11.02.2026 Date Of Pronouncement: 11.02.2026 Order Per Satbeer Singh Godara: These Assessee’S Twin Appeals Ita Nos. 5226/Del/2016 &

disallowance of Rs.1,26,89,824/- and Rs.7,62,000/- on payments made to contractors/sub-contractors and legal and interest charges etc. as well as treating it’s secured loans of Rs.24,00,000/- as unexplained cash credits u/s 68 of the Act; respectively. 4. Both the parties vehemently reiterate their respective stands against and in support of the impugned disallowance/additions

ACIT, CIRCLE-61(1), NEW DELHI vs. SUBRAMANIAM HARIHARAN, NEW DELHI

disallowed payments amounting to these law firms or\nindividuals invoking provisions of section 40(a)(i) of the Act, allegedly holding\nthat the said payments were in the nature of Fees for Technical Services (FTS)\n3\n\nand therefore, were chargeable to tax in India, thus tax at source should have\nbeen deducted. The same was sustained