INTERGLOBE TECHNOLOGY QUOTIENT PRIVATE LIMITED,NEW DELHI vs. ASSISTANT COMMISSIONER CIRCLE 10(1), NEW DELHI

Bench: Shri M. Balaganesh & Shri Anubhav Sharma[Assessment Year: 2020-21

section 80G of the Act, in the income tax return for assessment year 2020-21 was extended till 30th July, 2020. 5. The remaining amount of the disallowance

MCKINSEY GLOBAL CAPABILITIES AND SERVICES PRIVATE LIMITED (MGCS) [MGSIPL NOW MERGED WITH MGCS],HARYANA vs. ADDITIONAL / JOINT / DEPUTY / ASSISTANT COMMISSIONER OF INCOME TAX / INCOME-TAX OFFICER, DELHI

Appeal is allowed

Bench: Sh. Satbeer Singh Godara & Sh. Amitabh Shuklaita No. 5314/Del/2025 : Asstt. Year : 2018-19 Mckinsey Global Capabilities & Vs Cit(A)/Nfac, Services Pvt. Ltd. (Mckinsey Global Delhi Services India Pvt. Ltd.), 3Rd Floor, Block-Iii, Vatika Business Park, Sector-49, Sohna Road, Gurgaon-12201 (Appellant) (Respondent) Pan No. Aaccm2356G Assessee By : Sh. Nikhil Tiwari, Ca Revenue By : Ms. Ankush Kalra, Sr. Dr Date Of Hearing: 15.01.2026 Date Of Pronouncement: 15.01.2026 Order Per Satbeer Singh Godara: This Assessee’S Appeal For Assessment Year 2018-19, Arises Against The Cit(A)/Nfac, Delhi’S Din & Order No. Itba/Nfac/S/250/2025–26/1077218408(1) Dated 19.06.2025, In Proceedings U/S 143(3) Of The Income Tax Act, 1961 (In Short “The Act”).

disallowance of these expenditures u/s 80G, if other conditions of section 80G are fulfilled. There is no allegation of Revenue that other conditions of Section 80G are not fulfilled. We, thus sustain the ground.” 5

ACIT, CIRCLE-7(1), DELHI, DELHI vs. FIS GLOBAL BUSINESS SOLUTIONS INDIA PRIVATE LIMITED, DELHI

In the result, the appeal of the revenue as well as cross objection of the assessee are dismissed

Bench: Shri C.N. Prasad & Shri Naveen Chandra[Assessment Year: 2020-21] Dcit Vs. Fis Global Business Solutions New Delhi India Private Limited S-405, Lower Ground Floor, Greater Kailash, Part Ii New Delhi Pan No.Aaach2851H Appellant Respondent Co. No. 213/Del/2025 (In Ita No.5002/Del/2025) [Assessment Year: 2020-21] Fis Global Business Vs. Dcit Solutions India Private New Delhi Limited S-405, Lower Ground Floor, Greater Kailash, Part Ii New Delhi Pan No.Aaach2851H Appellant Respondent Revenue By Ms. Ankush Kalra, Sr. Dr Assessee By Sh. Vishal Kalra, Advocate Ms. Reema Grewal, Ca Sh. Kashish Gupta, Advocate Date Of Hearing 18.11.2025 Date Of Pronouncement 14.01.2026

5 to 9). There is no dispute on eligibility under section 80G of the Act. The AO has alleged that Assessee is not eligible for deduction under section 80G of the Act, since CSR is not voluntary exercise and made the disallowance

AMERICAN EXPRESS (INDIA) PRIVATE LIMITED,NEW DELHI vs. PRINCIPAL COMMISSIONER OF INCOME TAX-1, DELHI, NEW DELHI

In the result, appeal of the assessee is allowed

disallowed and added back in terms of Explanation 2 to Section 37(1) of the Act. In terms of Section 135(5) of the Act read with Section 80G

MANKIND PHARMA LIMITED,DELHI vs. DCIT, CIRCLE-1(1)(1), MEERUT

In the result, the additional Ground No

Bench: Shri Challa Nagendra Prasad & Shri Pradip Kumar Kedia

5,72,619 Other additions/disallowances Addition w.r.t. to expenditure incurred on in-house 12,01,42,780 scientific research under section 35(2AB) of the Act Disallowance w.r.t. deduction claimed under section 638,13,601 80G

M/S. HAVELLS INDIA LTD.,NEW DELHI vs. ACIT, NEW DELHI

The appeal of the assessee is partly allowed for statistical purpose

Bench: Shri Anil Chaturvedi & Ms Suchitra Kamble(Through Video Conferencing) Vs Havells India Ltd. Acit 1, Raj Narian Marg, Ltu Civil Lines New Delhi New Delhi Aaach0351E (Respondent) (Appellant)

disallowance of Rs. 3,96,91,355/- made by the Assessing Officer but also enhanced the income of the assessee by Rs.29,56,344/- without issuing the notice of enhancement u/s 251 of the Act. The Ld. AR submitted that the aforesaid issue now stands covered in favour of the assessee by the order of the Tribunal in asseesse

ERICSSON INDIA GLOBAL SERVICES PRIVATE LIMITED,DELHI vs. DCIT, CIRCLE-7(1), NEW DELHI

In the result, appeal is partly allowed for statistical purposes

Bench: Sh. Saktijit Dey, Vice- & Sh. Pradip Kumar Kediaericsson India Global Vs. Dcit Services Private Ltd. Circle – 7(1) 18/17, 4Th Floor, Wea, New Delhi Pusa Lane, Dhaka House, Karol Bagh, Delhi-110 005 Pan No. Aacce 4175 D (Appellant) (Respondent) Assessee By Shri Vishal Kalra, Adv., Shri Ankit Sahni, Adv. & Shri Yishu Goel, Adv. Revenue By Shri Vizay B. Vasanta, Cit-D.R. Date Of Hearing: 28.02.2024 Date Of Pronouncement: 05.03.2024

disallowed under section 80G of the Act. 18. We have heard both the parties and perused the records. We find that ITAT, Bangalore Bench in the case of Goldman Sachs Services (P.) Ltd. (supra) has held that the other contributions made under section 135 (5

INTERGLOBE ENTERPRISES PRIVATE LIMITED,NEW DELHI vs. ACIT CIRCLE-10(1), NEW DELHI

In the result, the appeal of the assessee is allowed

Bench: Shri Pradip Kumar Kedia & Shri Sudhir Pareek

disallowance of such expenses/ outgo in view of stipulations made in section 37 of the Act does not put any fetters on the eligibility under other provisions of the Act viz. Section 80G of the Act. The claim is eligible for deduction under S. 80G unless statutorily prohibited. The ld. counsel contends that there being

KEYSIGHT TECHNOLOGIES INDIA PRIVATE LIMITED (ACQUIRER OF IXIA TECHNOLOGIES PRIVATE LIMITED),GURGAON vs. ACIT CIRCLE 13(1), NEW DELHI

In the result, the appeal of the assessee is allowed

Bench: Shri Pradip Kumar Kedia & Shri Sudhir Pareekassessment Year 2016-17

disallowance of such expenses/ outgo in view of stipulations made in section 37 of the Act does not put any fetters on the eligibility under other provisions of the Act viz. Section 80G of the Act. The claim is eligible for deduction under S. 80G unless statutorily prohibited. The ld. counsel contends that there being

HERO MOTOCORP LIMITED,NEW DELHI vs. JCIT, NEW DELHI

In the result appeal of the assessee in ITA No

Bench: Sh. I. C. Sudhir & Shri Prashant Maharishihero Motocorp Limited, Jcit, 34, Basant Lok, Vasant Range-1, New Delhi Vs. Vihar, New Delhi Pan: Aaach0812J (Appellant) (Respondent) Dcit, M/S. Hero Moto Corp. Circle-11(1), Ltd., 34, Community Vs. New Delhi Centre, Basant Lok, Vasant Vihar, New Delhi-110057 (Appellant) (Respondent) Dcit, M/S. Hero Moto Corp. Circle-11(1), Ltd., 34, Community

disallowed on the ground of the same being contingent in nature. He further submitted that similar provision for increase in prices as at the end of the year was accepted and allowed in Hero MotoCorp Limited Vs. JCIT & DCIT Vs. Hero MotoCorp Ltd. ITA Nos. 1545/Del/2015 and 2424/Del/2015 (AY 2010-11) ITA No. 1609/Del/2016 and 914/Del/2016 (AY 2011-12) Page

TERADATA INDIA P.LTD,GURUGRAM vs. DCIT,CIRCLE-3(1), GURUGRAM

Appeal of the revenue is allowed for AY 2018-19

Bench: Shri M. Balaganesh & Shri Yogesh Kumar Us

5. That once working capital adjustment is granted no separate adjustment on account of outstanding receivables is maintainable. Part III-Corporate Tax Grounds 6. Denial of deduction under Section 80G 6.1. That on the facts and circumstances of the case and in law, the Learned AO has erred in disallowing

TERADATA INDIA PVT LTD,GRUGRAM vs. DCIT CIRCLE-3(1), GURUGRAM

Appeal of the revenue is allowed for AY 2018-19

Bench: Shri M. Balaganesh & Shri Yogesh Kumar Us

5. That once working capital adjustment is granted no separate adjustment on account of outstanding receivables is maintainable. Part III-Corporate Tax Grounds 6. Denial of deduction under Section 80G 6.1. That on the facts and circumstances of the case and in law, the Learned AO has erred in disallowing

ACIT-CIRCLE-3(1), GURGAON vs. TERADATA INDIA PRIVATE LIMITED, GURGAON

Appeal of the revenue is allowed for AY 2018-19

Bench: Shri M. Balaganesh & Shri Yogesh Kumar Us

5. That once working capital adjustment is granted no separate adjustment on account of outstanding receivables is maintainable. Part III-Corporate Tax Grounds 6. Denial of deduction under Section 80G 6.1. That on the facts and circumstances of the case and in law, the Learned AO has erred in disallowing

AMWAY INDIA ENTERPRISES PRIVATE LIMITED,NEW DELHI vs. DCIT, CIRCLE 1(1), DELHI / NFAC, DELHI

Appeal of the assessee is allowed

Bench: Shri Sudhir Pareek & Shri Manish Agarwalamway India Enterprises Private Dcit, Limited, Circle-1(1), Ground Floor, Elegance Tower, Vs. Delhi/Nfac. Plot No.8, Non Hierarchical Commercial, Jasola, Delhi-110025. Pan-Aaaca5603Q (Appellant) (Respondent)

disallowance of deduction claimed also 80G of the Act by wrongly interpreting section 800 of the Act. 14. The Ld. AO has erred on facts and law in initiating penalty proceedings u/s 70A(1) and 270A(8) of the Income Tax Act, 1961. 15. The Ld. AO has erred on facts and law in charging interest w/s 234A

GENPACT SERVICES LLC,GURGAON vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE - INT TAX 1(3)(1), DELHI

In the result, appeal of the assessee is partly allowed

Bench: Shri Prakash Chand Yadav\Nand\Nshri Brajesh Kumar Singh\N\Nita No. 4477/Del/2024\N[Assessment Year: 2020-21]\N\N| Genpact Services Llc,\Nplot 22A & B, Sector 18,\Nudyog Vihar,\Ngurgaon, Haryana-122002\Npan-Aaccg3353P\Nappellant\N|\Nassistant Commissioner Of Income\Ntax, Circle-International Tax-1(3)(1),\Nvs Delhi-110002\Nrespondent\N\N| Appellant By\Nshri Vishal Kalra, Adv.,\Nms. Reema Malik, Adv.& Ms.\Nsnigdha Gautam, Adv.\Nrespondent By\Nshri S.K. Jadhav, Cit Dr\N\Ndate Of Hearing\N30.07.2025\Ndate Of Pronouncement\N31.07.2025\N\Norder\N\Nper Brajesh Kumar Singh, Am,\Nthis Appeal By The Assessee Is Directed Against The Order Of The\Nassessing Officer Dated 29.07.2024 Passed U/S 143(3) R.W.S.144C(13) Of\Nthe Income Tax Act, 1961 (Hereinafter ‘The Act') In Pursuance To The\Ndirections Of Dispute Resolution Panel Dated 25.06.2024 Pertaining To\N Assessment Year 2020-21.\N2. The Relevant Facts Are That The Assessee Is An Indian Branch Office Of\Ngenpact Llc, A Usa Company. The Assessee Is A Service Provider\Nrendering Off-Shore Support Services Akin To Bpo Services, Including\Ncollections/Analytics Call Centre Services & Other Back-Office Support\Nservices To Its Aes. The Assessee Is Responsible For Rendering The\Ndesignated Bpo / Collections Services From Its Facility / Infrastructure In\Nindia. As For Assessment Year 2020-21, The Assessee Filed Its Return Of\Nincome (Roi') Declaring An Income Of Inr 20,57,10,540/- On 07.01.2021.\Nduring The Course Of Scrutiny, The Assessing Officer Made A Reference U/S\N92Ca Of The Act To The Transfer Pricing Officer (Tpo') To Determine The\Narm'S Length Price (‘Alp') In Respect Of International Transaction Entered\Ninto By The Assessee.\N2.

Section 80G are not fulfilled.\nWe, thus sustain the ground.\n7. 3. Therefore, respectfully following the above order of the Tribunal, we\ndelete the disallowance of deduction amounting to Rs.16,90,975/- made\nby the Assessing Officer which was claimed by the assessee u/s 80G(5

NTT COMMUNICATIONS INDIA NETWORK SERVICES PVT LTD,DELHI vs. DCIT, CIRCLE 16(1), DELHI

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

5: That, in the facts and circumstances of the case and in law,\nthe FAO/Commissioner (Appeals) grossly erred in disallowing a sum of\nRs. 24,00,100/- claimed as deduction from total income under Section\n80G of the Act by invoking Explanation 2 to Section 37(1) of the Act and\nnot appreciating that the said provisions are not mutually

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

Section\n36(1)(viii) of the Act was to be seen at the time of sanction of loans and\nin case of no change in the character of account i.e. tenure being more\nthan 5 years even after assignment, the same was held eligible for\ndeduction w/s 36(1)(viii) of the Act. Since, Ld CIT(A) had followed

CHEIL INDIA PRIVATE LIMITED,GURGAON vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 4(2), DELHI

In the result, appeal of the assessee is allowed

Bench: Shri Shamim Yahya & Shri Sudhir Pareeka.Yr. : 2020-21 Cheil India Private Limited Vs. Dcit, Circle 4(2), 7Th Floor, Two Horizon C.R. Building, Centre, New Delhi – 2 Golf Course Road, Gurgaon, Haryana-122001 (Pan: Aaccc2299Q) (Appellant) (Respondent)

80G of the Act pertaining to eligible payments without appreciating that section 37 of the Act does not provide any restriction towards deduction under Chapter VI-A of the Act, which is otherwise eligible. 5. That the Assessment Centre/ Appeal Centre has erred on facts and in law in not appreciating the intent of the legislature that the disallowance

AGILENT TECHNOLOGIES (INTERNATIONAL) PRIVATE LIMITED,MANESAR, GURGAON vs. THE DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 1(1), GURGAON

In the result, the appeal of the assessee is allowed

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarassessment Year: 2020-21 Agilent Technologies Vs. Dcit, (International) Private Limited, Circle 1(1), Plot No.Cp-11, Sector 8, Imt, Gurgaon Manesar, (Haryana) Gurgaon - 122051 Aadca4115C (Appellant) (Respondent)

disallowance of these expenditures u/s 80G, if other conditions of section 80G are fulfilled. There is no allegation of Revenue that other conditions of Section 80G are not fulfilled. We, thus sustain the ground.” 11. Thus we are of considered view that ld. Tax authorities below have fallen in error to deny benefit of Section 80G to the assessee