DCIT, NEW DELHI vs. M/S SAHARA INDIA MASS COMMUNICATION LTD., MUMBAI

In the result, appeals filed by the Revenue are partly allowed

Bench: Shri S. Rifaur Rahman & Shri Vimal Kumar

section 40(a)(ia) of the Act. But the revenue's contention is that the payments are in the nature of machinery hire charges falling under the head 'rent' and the previous provisions of section 194-I of the Act are applicable. According to revenue, the assessee has deducted tax @ 1% u/s. 194C(2) of the Act as against

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

87,60,935/- (after allowing depreciation at the rate of 25%) made by the AO on account of disallowance of royalty and Technical Fee Guidance. 17. Whether, on the facts and circumstances of the case the Ld. CIT(A) has erred in deleting the disallowance of expenditure Rs. 67,40,312/- incurred under the head of ‘Corporate Social Responsibility

HERO MOTO CORP LTD.,NEW DELHI vs. NEAC, DELHI

Bench: Shri Kul Bharat & Shri Prashant Maharishi(Through Video Conferencing)

section 14Af of the Act. 12.2 That the assessing officer erred on facts and in law in attributing entire interest expenditure incurred during the year towards earning of exempt income by mechanically applying provisions of Rule 8D of the Rules. Re: Disallowance of depreciation on model fee on the ground that the same was attributable to closing stock of finished

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

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

In the result, revenue’s appeal is dismissed and cross-objection

Bench: Shri Saktijit Dey & Shri Pradip Kumar Kedia:Assessment Year: 2014-15 Deputy Commissioner Of Vs. M/S. Religare Enterprises Income-Tax, Circle-21(1), Ltd., 2Nd Floor, Rajlok New Delhi Building, 24-Nehru Place, New Delhi-110019 Pan :Aaacv5888N (Appellant) (Respondent)

disallowance under section 14A of the Act cannot exceed the actual exempt dividend income. 2. Each of the aforesaid contentions are elaborated hereunder: Re (a): Amendment in section 14A - prospective and not retrospective 3. Kind attention is, at the outset, invited to the provisions of section 14A of the Act, as amended by the Finance Act, 2022, w.e.f

TECHNOLOGIES LTD) vs. ACIT

Appeals are allowed

87,325 Less: Suo motu disallowance by appellant/assessee 7,79,063 DISALLOWANCE 1,56,08,262 4.2. The appellant/assessee carried the order, passed by the AO, in appeal to the CIT(A). The CIT(A), vide order dated 30.07.2013, partly allowed the appeal preferred by the appellant/assessee. The net result was that, while CIT(A) sustained the disallowance ordered

TECHNOLOGIES LTD) vs. ACIT

Appeals are allowed

87,325 Less: Suo motu disallowance by appellant/assessee 7,79,063 DISALLOWANCE 1,56,08,262 4.2. The appellant/assessee carried the order, passed by the AO, in appeal to the CIT(A). The CIT(A), vide order dated 30.07.2013, partly allowed the appeal preferred by the appellant/assessee. The net result was that, while CIT(A) sustained the disallowance ordered

TECHNOLOGIES LTD) vs. ACIT

Appeals are allowed

87,325 Less: Suo motu disallowance by appellant/assessee 7,79,063 DISALLOWANCE 1,56,08,262 4.2. The appellant/assessee carried the order, passed by the AO, in appeal to the CIT(A). The CIT(A), vide order dated 30.07.2013, partly allowed the appeal preferred by the appellant/assessee. The net result was that, while CIT(A) sustained the disallowance ordered

HERO MOTOCORP LTD.,NEW DELHI vs. DCIT, CIRCLE- 11(1), NEW DELHI

Appeal of the assessee is partly allowed for statistical purpose

Bench: Shri N. K. Billaiya & Ms Suchitra Kamble

disallowance could not have exceeded 30% of the total expenditure in view of the amended provisions of section 40(a)(ia) of the Act. 23. That the assessing officer erred on facts and in law in holding that expenditure aggregating to Rs. 340,87

CIT vs. SELECT HOLIDAY RESORTS PVT LTD

The appeals stand disposed of as above

Bench: HON'BLE MR. JUSTICE SANJIV KHANNA,HON'BLE MR. JUSTICE R.V.EASWAR

disallowance under section 14A, is set aside and the matter is restored to the file of the assessing officer who is to follow the steps outlined in paragraph 42 above. ITA No.217/2009 [CIT v. AKM Systems Pvt Ltd](AY 2001-02) ([) The assessee company received dividend of Rs 81,87

CIT vs. SELECT HOLIDAY RESORTS PVT LTD

The appeals stand disposed of as above

disallowance under section 14A, is set aside and the matter is restored to the file of the assessing officer who is to follow the steps outlined in paragraph 42 above. ITA No.217/2009 [CIT v. AKM Systems Pvt Ltd](AY 2001-02) ([) The assessee company received dividend of Rs 81,87

NIIT TECHNOLOGIES LTD.,NEW DELHI vs. ACIT, CIRCLE-18(2), NEW DELHI

Appeal is allowed for statistical

Bench: Shri S Rifaur Rahman & Ms. Madhumita Royita Nos.2889 & 2890/Del/2018 (Assessment Years: 2009-10 & 2010-11)

87,3357/- on account of disallowance u/s 14A of the Act made while calculating Book Profit u/s 115JB of the Act by ignoring the fact that clause (f) of Explanation 1 to section

NIIT TECHNOLOGIES LTD.,,NEW DELHI vs. ACIT, CIRCLE-18(2), NEW DELHI

Appeal is allowed for statistical

Bench: Shri S Rifaur Rahman & Ms. Madhumita Royita Nos.2889 & 2890/Del/2018 (Assessment Years: 2009-10 & 2010-11)

87,3357/- on account of disallowance u/s 14A of the Act made while calculating Book Profit u/s 115JB of the Act by ignoring the fact that clause (f) of Explanation 1 to section

ACIT, CIRCLE-18(2), NEW DELHI vs. NIIT TECHNOLOGIES LTD.,, NEW DELHI

Appeal is allowed for statistical

Bench: Shri S Rifaur Rahman & Ms. Madhumita Royita Nos.2889 & 2890/Del/2018 (Assessment Years: 2009-10 & 2010-11)

87,3357/- on account of disallowance u/s 14A of the Act made while calculating Book Profit u/s 115JB of the Act by ignoring the fact that clause (f) of Explanation 1 to section

ACIT, CIRCLE-18(2), NEW DELHI vs. NIIT TECHNOLOGIES LTD.,, NEW DELHI

Appeal is allowed for statistical

Bench: Shri S Rifaur Rahman & Ms. Madhumita Royita Nos.2889 & 2890/Del/2018 (Assessment Years: 2009-10 & 2010-11)

87,3357/- on account of disallowance u/s 14A of the Act made while calculating Book Profit u/s 115JB of the Act by ignoring the fact that clause (f) of Explanation 1 to section

M/S EICHER GOODEARTH LTD

The appeals stand disposed of as above

disallowance under section 14A, is set aside and the matter is restored to the file of the assessing officer who is to follow the steps outlined in paragraph 42 above. ITA No.217/2009 [CIT v. AKM Systems Pvt Ltd](AY 2001-02) The assessee company received dividend of Rs 81,87

M/S EICHER GOODEARTH LTD

The appeals stand disposed of as above

disallowance under section 14A, is set aside and the matter is restored to the file of the assessing officer who is to follow the steps outlined in paragraph 42 above. ITA No.217/2009 [CIT v. AKM Systems Pvt Ltd](AY 2001-02) The assessee company received dividend of Rs 81,87

M/S EICHER GOODEARTH LTD

The appeals stand disposed of as above

disallowance under section 14A, is set aside and the matter is restored to the file of the assessing officer who is to follow the steps outlined in paragraph 42 above. ITA No.217/2009 [CIT v. AKM Systems Pvt Ltd](AY 2001-02) The assessee company received dividend of Rs 81,87