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6,378 results for “disallowance”+ Section 9clear

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Key Topics

Addition to Income71Disallowance67Section 14A62Section 153A57Section 143(3)53Section 153C50Section 143(1)42Section 115J36Deduction30Section 68

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

Appeal of the Revenue is dismissed

ITA 1982/DEL/2019[2014-15]Status: DisposedITAT Delhi03 Feb 2023AY 2014-15

Bench: Shri Narendra Kumar Billaiya & Shri Kul Bharat

Section 14ASection 2(22)(e)Section 40Section 40a

9,86,947.50 D. Disallowance=A*B/C 31.84 (iii) ½% of average value of 132.94 investments [0.5%x3,32,90,205] Total disallowance 164.78 Less: Suo moto disallowance made in the return 67.03 Net disallowance made in the assessment order 97.75 The assessing officer has alternately proposed to disallow interest expenditure to the extent of Rs.31.84 lacs under section

AMAZON WEB SERVICES, INC.,USA vs. ACIT CIRCLE INTERNATIONAL TAX 1(1)(1), NEW DELHI

Accordingly, ground No. 3 along with its sub-grounds 3.1 to 3.4, ground No. 4 and ground No. 5 along with its sub-ground 5.1 r.w ground No. 2 are allowed

Showing 1–20 of 6,378 · Page 1 of 319

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Section 13226
Natural Justice11
ITA 523/DEL/2023[2016-17]Status: FixedITAT Delhi01 Aug 2023AY 2016-17

Bench: Shri G.S. Pannu, Hon’Ble & Ms. Astha Chandra

For Appellant: Shri Porus Kaka, Sr. AdvocateFor Respondent: Shri Vizay B. Vasanta, CIT-DR
Section 144CSection 147Section 151Section 201Section 9(1)(vi)

section 9(1)(vi) of the Act, cannot make the assessee liable to deduct tax at source. In other words, the assessee is not liable to deduct withholding tax and such non deduction of withholding tax does not render the assessee in default and consequently, no disallowance

AMAZON WEB SERVICES, INC.,USA vs. ACIT, CIRCLE-1(1)(1), NEW DELHI

Accordingly, ground No. 3 along with its sub-grounds 3.1 to 3.4, ground No. 4 and ground No. 5 along with its sub-ground 5.1 r.w ground No. 2 are allowed

ITA 522/DEL/2023[2014-15]Status: FixedITAT Delhi01 Aug 2023AY 2014-15

Bench: Shri G.S. Pannu, Hon’Ble & Ms. Astha Chandra

For Appellant: Shri Porus Kaka, Sr. AdvocateFor Respondent: Shri Vizay B. Vasanta, CIT-DR
Section 144CSection 147Section 151Section 201Section 9(1)(vi)

section 9(1)(vi) of the Act, cannot make the assessee liable to deduct tax at source. In other words, the assessee is not liable to deduct withholding tax and such non deduction of withholding tax does not render the assessee in default and consequently, no disallowance

JAINA MARKETING & ASSOCIATES,DELHI vs. DCIT, CENTRAL CIRCLE-18, DELHI

Accordingly, Appeals filed by the assessee are allowed

ITA 224/DEL/2023[2017-18]Status: DisposedITAT Delhi20 Mar 2024AY 2017-18

Bench: Shri M. Balaganesh & Shri Yogesh Kumar U.S.

Section 132Section 153ASection 270ASection 270A(9)Section 270A(9)(a)Section 271(1)(c)Section 271ASection 274

disallowances under section 14A of the Act. This by no stretch of imagination can be held to be 'misreporting'. 8. This Court also finds that there is not even a whisper as to which limb of section 270A of the Act is attracted and how the ingredient of sub- section (9

JAINA MARKETING & ASSOCIATES,DELHI vs. DCIT, CENTRAL CIRCLE-18, DELHI

Accordingly, Appeals filed by the assessee are allowed

ITA 226/DEL/2023[2019-20]Status: DisposedITAT Delhi20 Mar 2024AY 2019-20

Bench: Shri M. Balaganesh & Shri Yogesh Kumar U.S.

Section 132Section 153ASection 270ASection 270A(9)Section 270A(9)(a)Section 271(1)(c)Section 271ASection 274

disallowances under section 14A of the Act. This by no stretch of imagination can be held to be 'misreporting'. 8. This Court also finds that there is not even a whisper as to which limb of section 270A of the Act is attracted and how the ingredient of sub- section (9

JAINA MARKETING & ASSOCIATES,DELHI vs. DCIT, CENTRAL CIRCLE-18, DELHI

Accordingly, Appeals filed by the assessee are allowed

ITA 225/DEL/2023[2018-19]Status: DisposedITAT Delhi20 Mar 2024AY 2018-19

Bench: Shri M. Balaganesh & Shri Yogesh Kumar U.S.

Section 132Section 153ASection 270ASection 270A(9)Section 270A(9)(a)Section 271(1)(c)Section 271ASection 274

disallowances under section 14A of the Act. This by no stretch of imagination can be held to be 'misreporting'. 8. This Court also finds that there is not even a whisper as to which limb of section 270A of the Act is attracted and how the ingredient of sub- section (9

M/S. PTC INDIA FINANCIAL SERVICES LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result, the appeals of the assessee for AY 2013-14 and 2014-15

ITA 2162/DEL/2017[2013-14]Status: DisposedITAT Delhi29 Nov 2023AY 2013-14

Bench: Shri N.K. Billaiya & Ms. Astha Chandraasstt. Year 2013-14 & Asstt. Year 2014-15

For Appellant: Shri Salil Kapoor, AdvocateFor Respondent: Shri Vivek Vardhan, Sr. DR
Section 234BSection 36(1)(viii)Section 37

section 36(1)(viii) and disallowance of Rs. 9,69,602/- under section 37 aggregating in all to Rs. 24,71,35,045/-. 5. The Ld. AO completed

ADDL. CIT, SPECIAL RANGE- 7, NEW DELHI vs. PTC INDIA FINANCIAL SERVICES LTD, NEW DELHI

In the result, the appeals of the assessee for AY 2013-14 and 2014-15

ITA 7433/DEL/2017[2014-15]Status: DisposedITAT Delhi29 Nov 2023AY 2014-15

Bench: Shri N.K. Billaiya & Ms. Astha Chandraasstt. Year 2013-14 & Asstt. Year 2014-15

For Appellant: Shri Salil Kapoor, AdvocateFor Respondent: Shri Vivek Vardhan, Sr. DR
Section 234BSection 36(1)(viii)Section 37

section 36(1)(viii) and disallowance of Rs. 9,69,602/- under section 37 aggregating in all to Rs. 24,71,35,045/-. 5. The Ld. AO completed

PTC INDIA FINANCIAL SERVICES LTD.,NEW DELHI vs. DCIT, CIRCLE- 19(2), NEW DELHI

In the result, the appeals of the assessee for AY 2013-14 and 2014-15

ITA 7273/DEL/2017[2014-15]Status: DisposedITAT Delhi29 Nov 2023AY 2014-15

Bench: Shri N.K. Billaiya & Ms. Astha Chandraasstt. Year 2013-14 & Asstt. Year 2014-15

For Appellant: Shri Salil Kapoor, AdvocateFor Respondent: Shri Vivek Vardhan, Sr. DR
Section 234BSection 36(1)(viii)Section 37

section 36(1)(viii) and disallowance of Rs. 9,69,602/- under section 37 aggregating in all to Rs. 24,71,35,045/-. 5. The Ld. AO completed

ACIT, NEW DELHI vs. M/S. PTC INDIA FINANCIAL SERVICES LTD., NEW DELHI

In the result, the appeals of the assessee for AY 2013-14 and 2014-15

ITA 2175/DEL/2017[2013-14]Status: DisposedITAT Delhi29 Nov 2023AY 2013-14

Bench: Shri N.K. Billaiya & Ms. Astha Chandraasstt. Year 2013-14 & Asstt. Year 2014-15

For Appellant: Shri Salil Kapoor, AdvocateFor Respondent: Shri Vivek Vardhan, Sr. DR
Section 234BSection 36(1)(viii)Section 37

section 36(1)(viii) and disallowance of Rs. 9,69,602/- under section 37 aggregating in all to Rs. 24,71,35,045/-. 5. The Ld. AO completed

SHARDA EDUCATIONAL TRUST ,GREATER NOIDA vs. ITO (TDS), INTERNATIONAL TAXATION, NOIDA

In the result, ITA.No.3377/Del

ITA 3383/DEL/2018[2017-18]Status: DisposedITAT Delhi05 May 2022AY 2017-18

Bench: Shri R.K. Panda & Shri Anubhav Sharma

For Appellant: Shri Gaurav Gupta, ARFor Respondent: Smt. Anupma Anand, CIT-DR
Section 12ASection 133ASection 195Section 201(1)

Section 9(i)(vii) defines FTS as under: "For the purpose of this clause, FTS means any consideration including any consideration for rendering any managerial, technical or consultancy services (including the provisions of services of technical or other personnel) but does not include consideration for any construction assembly, mining or like project undertaken by the recipient or consideration which would

SHARDA EDUCATIONAL TRUST ,GREATER NOIDA vs. ITO (TDS), INTERNATIONAL TAXATION, NOIDA

In the result, ITA.No.3377/Del

ITA 3377/DEL/2018[2011-12]Status: DisposedITAT Delhi05 May 2022AY 2011-12

Bench: Shri R.K. Panda & Shri Anubhav Sharma

For Appellant: Shri Gaurav Gupta, ARFor Respondent: Smt. Anupma Anand, CIT-DR
Section 12ASection 133ASection 195Section 201(1)

Section 9(i)(vii) defines FTS as under: "For the purpose of this clause, FTS means any consideration including any consideration for rendering any managerial, technical or consultancy services (including the provisions of services of technical or other personnel) but does not include consideration for any construction assembly, mining or like project undertaken by the recipient or consideration which would

SHARDA EDUCATIONAL TRUST ,GREATER NOIDA vs. ITO (TDS), INTERNATIONAL TAXATION, NOIDA

In the result, ITA.No.3377/Del

ITA 3378/DEL/2018[2012-13]Status: DisposedITAT Delhi05 May 2022AY 2012-13

Bench: Shri R.K. Panda & Shri Anubhav Sharma

For Appellant: Shri Gaurav Gupta, ARFor Respondent: Smt. Anupma Anand, CIT-DR
Section 12ASection 133ASection 195Section 201(1)

Section 9(i)(vii) defines FTS as under: "For the purpose of this clause, FTS means any consideration including any consideration for rendering any managerial, technical or consultancy services (including the provisions of services of technical or other personnel) but does not include consideration for any construction assembly, mining or like project undertaken by the recipient or consideration which would

SHARDA EDUCATIONAL TRUST ,GREATER NOIDA vs. ITO (TDS), INTERNATIONAL TAXATION, NOIDA

In the result, ITA.No.3377/Del

ITA 3379/DEL/2018[2013-14]Status: DisposedITAT Delhi05 May 2022AY 2013-14

Bench: Shri R.K. Panda & Shri Anubhav Sharma

For Appellant: Shri Gaurav Gupta, ARFor Respondent: Smt. Anupma Anand, CIT-DR
Section 12ASection 133ASection 195Section 201(1)

Section 9(i)(vii) defines FTS as under: "For the purpose of this clause, FTS means any consideration including any consideration for rendering any managerial, technical or consultancy services (including the provisions of services of technical or other personnel) but does not include consideration for any construction assembly, mining or like project undertaken by the recipient or consideration which would

SHARDA EDUCATIONAL TRUST ,GREATER NOIDA vs. ITO (TDS), INTERNATIONAL TAXATION, NOIDA

In the result, ITA.No.3377/Del

ITA 3380/DEL/2018[2014-15]Status: DisposedITAT Delhi05 May 2022AY 2014-15

Bench: Shri R.K. Panda & Shri Anubhav Sharma

For Appellant: Shri Gaurav Gupta, ARFor Respondent: Smt. Anupma Anand, CIT-DR
Section 12ASection 133ASection 195Section 201(1)

Section 9(i)(vii) defines FTS as under: "For the purpose of this clause, FTS means any consideration including any consideration for rendering any managerial, technical or consultancy services (including the provisions of services of technical or other personnel) but does not include consideration for any construction assembly, mining or like project undertaken by the recipient or consideration which would

SHARDA EDUCATIONAL TRUST ,GREATER NOIDA vs. ITO (TDS), INTERNATIONAL TAXATION, NOIDA

In the result, ITA.No.3377/Del

ITA 3381/DEL/2018[2015-16]Status: DisposedITAT Delhi05 May 2022AY 2015-16

Bench: Shri R.K. Panda & Shri Anubhav Sharma

For Appellant: Shri Gaurav Gupta, ARFor Respondent: Smt. Anupma Anand, CIT-DR
Section 12ASection 133ASection 195Section 201(1)

Section 9(i)(vii) defines FTS as under: "For the purpose of this clause, FTS means any consideration including any consideration for rendering any managerial, technical or consultancy services (including the provisions of services of technical or other personnel) but does not include consideration for any construction assembly, mining or like project undertaken by the recipient or consideration which would

SHARDA EDUCATIONAL TRUST ,GREATER NOIDA vs. ITO (TDS), INTERNATIONAL TAXATION, NOIDA

In the result, ITA.No.3377/Del

ITA 3382/DEL/2018[2016-17]Status: DisposedITAT Delhi05 May 2022AY 2016-17

Bench: Shri R.K. Panda & Shri Anubhav Sharma

For Appellant: Shri Gaurav Gupta, ARFor Respondent: Smt. Anupma Anand, CIT-DR
Section 12ASection 133ASection 195Section 201(1)

Section 9(i)(vii) defines FTS as under: "For the purpose of this clause, FTS means any consideration including any consideration for rendering any managerial, technical or consultancy services (including the provisions of services of technical or other personnel) but does not include consideration for any construction assembly, mining or like project undertaken by the recipient or consideration which would

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

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

ITA 7552/DEL/2018[2014-15]Status: HeardITAT Delhi29 Aug 2022AY 2014-15

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)

Section 14A

disallowance of interest cost could have been made. 9. Learned Departmental Representative, in addition to his oral submission has filed written submissions. In sum and substance, the learned Departmental Representative submitted that, in view of the amendment made to Section

QAI INDIA LTD.,NEW DELHI vs. DCIT, CIRCLE-14(1), NEW DELHI

In the result, the appeals of the assessee are allowed

ITA 3998/DEL/2017[2011-12]Status: DisposedITAT Delhi05 Aug 2024AY 2011-12

Bench: Dr. B. R. R. Kumar, Ms. Madhumita Roy

For Appellant: Sh. Ved Jain Adv. &For Respondent: Sh. Saurabh Anand, Sr. DR
Section 192Section 195Section 251(1)(a)Section 40Section 9(1)(vii)

section 9(1)(vi). 9. Accordingly, we answer the question of law referred to us in the affirmative, in favour of the assessee and against the revenue. No costs. ” 28. Considering the facts of the case, above mentioned provisions of the Act and case laws relied upon by the assessee, the disallowance

QAI INDIA LTD.,NEW DELHI vs. DCIT, CIRCLE-14(1), NEW DELHI

In the result, the appeals of the assessee are allowed

ITA 3999/DEL/2017[2012-13]Status: DisposedITAT Delhi05 Aug 2024AY 2012-13

Bench: Dr. B. R. R. Kumar, Ms. Madhumita Roy

For Appellant: Sh. Ved Jain Adv. &For Respondent: Sh. Saurabh Anand, Sr. DR
Section 192Section 195Section 251(1)(a)Section 40Section 9(1)(vii)

section 9(1)(vi). 9. Accordingly, we answer the question of law referred to us in the affirmative, in favour of the assessee and against the revenue. No costs. ” 28. Considering the facts of the case, above mentioned provisions of the Act and case laws relied upon by the assessee, the disallowance