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)

Housing Ltd. Vs. National E Assessment Center Delhi ; 441 ITR 285(del)  Devanshu Infin Ltd. Vs. National E Assessment Center Delhi ;284 Taxman 36  Ramprastha Buildwell (P.) Ltd. Vs. National E Assessment Center, Delhi; 283 Taxman 235 13  KRS Home Developers (P.) Ltd. Vs. National Faceless Assessment Centre ;283 Taxman 413  Umkal Healthcare (P.) Ltd. Vs. National Faceless Assessment Centre

MICROSOFT CORPORATION (INDIA) PRIVATE LIMITED,NEW DELHI vs. DCIT, CIRCLE-16(1), NEW DELHI

In the result, the appeal of the assessee is allowed

Bench: Shri M. Balaganesh & Shri Yogesh Kumar Usmicrosoft Corporation (India) Vs. Dcit, Pvt. Ltd, Circle-16(1), 807, New Delhi House, New Delhi Barakhamba Road, New Delhi (Appellant) (Respondent) Pan: Aaacm5586C Assessee By : Shri Nageswar Rao & Parth, Adv Revenue By: Shri Rajesh Kumar, Cit(Dr) Date Of Hearing 22/02/2024 Date Of Pronouncement 28/02/2024

House of Parliament.” 9. In our considered opinion pursuant to the faceless regime introduced by the Govt. of India, National e Assessment Centre becomes Income Tax Authority vested with the powers of issuing notice, transferring the case, framing the assessment etc. Once, any document which is (ld DRP directions dated 25.03.2022 in the instant case) is uploaded in the ITBA

CIT vs. GS PHARMBUTOR PVT LTD

The appeal is allowed to the aforesaid extent

Bench: HON'BLE MR. JUSTICE BADAR DURREZ AHMED,HON'BLE MR. JUSTICE R.V.EASWAR

House Dr. Annie Besant Road, Worli, Mumbai, Sir, LPA 134/2013 Page 12 of 60 Please refer to your passport application dated 22.07.2008, on the basis of which you were issued passport bearing No. Z-1784222 dated 30.07.2008 by this office. It is informed by the Directorate of Enforcement, Mumbai that a complaint dated 16.9.2010 under section 13 of FEMA

RAJEEV VASUDEVA,DELHI vs. DCIT CIRCLE INTERNATIONAL TAXATION 3(1) , DELHI

In the result, appeal of the assessee is partly allowed

Bench: us, the only effective issue to be decided in this appeal is as to whether the learned CIT(A) was justified in confirming the action of the learned AO in denying the claim of exemption under section 54F of the Act in the facts and circumstances of the instant case.

13) of the Income-tax Act, 1961 (in short ‘the Act’) pertaining to assessment year 2020-21 in pursuance to directions of learned Dispute Resolution Panel (DRP). 2. The additional ground raised by the assessee vide letter dated 13.11.2023, stating that the directions issued by learned DRP under section 144C(5) of the Act dated 16.05.2023 does not bear

ACIT (LTU), NEW DELHI vs. MAX NEW YORK LIFE INSURANCE COMPANY LTD., NEW DELHI

In the result, the appeal is allowed for statistical purposes

Bench: Shri R.S. Syal & Shri Sudhanshu Srivastavaassessment Year : 2002-03

house property" shall be computed after making the following deductions………….’. Similarly, for the income under the head `Capital gains’, charging section is 45, which provides that : `Any 13 profits or gains arising from the transfer of a capital asset effected in the previous year shall, ….be chargeable ….’ and the computation provision is contained in section 48, which provides that

ANIL BHARDWAJ,ZAMBIA vs. DCIT-ACIT-INT-TAX GURGAON, GURGAON

In the result, the Appeal filed by the Assessee is allowed

Bench: Dr. B. R. R. Kumar & Shri Yogesh Kumar U.S.I.T.A. No. 1250/Del/2024 (A.Y 2020-21) Anil Bhardwaj Dcit/Acit 5994, Benakale Road, P. O Vs. International Tax, Box No. 31776, Northmead, Office Of Acit-Dcit Int- Near Rhodes Park School, Tax, Gurgaon Lusaka-10101, Zambia, Ny (Respondent) Pan No. Anlpb2321F (Appellant)

Section 144C(13) of the Act dated 27/04/2023 by making 4 Anil Bhardwaj Zambia addition of Rs. 20,10,008/- as short term capital gain and further disallowed Rs. 80,14,041/- u/s 54 of the Act being 50% wife’s shares in the new house property

VINAY CHAUDHARY,PITAMPURA vs. ACIT INT TAX 1(2)(1), DELHI

In the result, the appeal of the assesse is allowed

Bench: “Shri Ramit Kochar & Shri Raj Kumar Chauhan

house property. The DRP vide its directions dated 18.09.2023 passed u/s 144C(13) of the Act, upheld the aforesaid action of the AO, pursuant to which final assessment order dated 18.10.2023 was passed at an assessed income of Rs. 4,16,38,920/- u/s 143(3) r.w.s. 144C of the Act. The assessee has earned an LTCG

MICROSOFT INDIA (R&D) PVT. LTD.,NEW DELHI vs. DCIT, CIRCLE-16(2), NEW DELHI

In the result, appeal of the assessee for Assessment Year 2014-15 and 2015-16 is partly allowed

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

section 144C of the Income Tax Act, 1961 (the Act) dated 31.10.2018 for Assessment Year 2014-15 wherein, the original return of income was filed by the assessee on 29.11.2014 at Rs. 2,59,00,06,780/- assessed at Rs. 4,86,64,97,120/-. Majorly the addition of Rs. 2,24,82,44,566/- was made on account

MADHURITTU PURI,UNITED KINGDOM vs. DCIT, CIRCLE INTERNATIONAL TAXATION 2(2)(2) , NEW DELHI

In the result, the appeal of the assessee is allowed

Bench: Shri G.S. Pannu, Hon’Ble & Ms. Astha Chandraasstt. Year: 2019-20

144C(13) of the income Tax Act 1961 (‘Act’) in pursuance to directions of Dispute Resolution Panel (‘DRP’) is arbitrary, unjust and illegal on various factual and legal grounds including but not limited :o the following: a) Reference as made by the AO under section 142A of the Act to Department’s Valuation Officer ( DVO ) for determining fair market value

JCB INDIA LTD.,NEW DELHI vs. DCIT NEAC, NEW DELHI

In the result, the appeal filed by the assessee is allowed for statistical purpose

Bench: Shri B. R. R. Kumar & Sh. Yogesh Kumar Us

144C(13) of the Act and not computing the assessed income in conformity with the order/ directions of the TPO/ DRP. 3.1 That on the facts and circumstances of the case and in law, the AO has erred in enhancing the transfer pricing adjustment with respect to payment of royalty on 2DX model and retaining disallowance under section

LM WIND POWER AS ,DENMARK vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE INTERNATIONAL TAX 2(2)(1), DELHI

In the result, ground raised by the assessee is allowed

Bench: Shris.Rifaur Rahman & Shri Yogesh Kumar U.S.Lm Wind Power As, Vs, Acit, Circle Juptervej 6, 6000 Kolding, International Tax 2(2)(1), Denmark – 999999. Delhi (Pan :Aabcl8590Q) (Appellant) (Respondent) Assessee By : Shri Ajay Vohra, Sr. Advocate Shri Aditya Vohra, Advocate Shri Arpitgoyal, Ca Revenue By : Shri Saroj Kumar Dubey, Cit Dr Date Of Hearing : 27.08.2025 Date Of Order : 21.11.2025 Order Per S. Rifaur Rahman: 1. This Appealpreferred By The Assessee Is Directed Against The Assessment Order Dated 27.01.2025 Passed By The Acit, Circle Int. Tax 2(2)(1), Delhi Under Section 143(3) R.W.S. 144C(13) Of The Income-Tax Act, 1961 (For Short ‘The Act”) For Assessment Year 2020-21 Pursuant To The Directions Of The Dispute Resolution Panel U/S 144C(5) Of The Act Raising Following Grounds Of Appeal :- “1. That On The Facts & Circumstances Of The Case & In Law, The Assessment Order Dated 29.07.2024 Passed Under Section 143(3) Read With Section 144C(13) Of The Income-Tax Act, 1961 (He Act") For Assessment Year 2020-21 Assessing The Total Income Of The Assessee At Rs.81,14, 14,893 Is Bad In Law, Void- Ab-Initio & Therefore, Liable To Be Quashed And/ Or Set Aside.

144C(13) of the Act. 2.4 He submitted that computation of assessed income of the assessee in the draft assessment order is as under: 5 Particulars Amount (inRs.) Returned income under the head ‘profit and gains 64,16,57,700 from business or profession’ Add: Sales commission received from LM India 16,97,57,193 Total assessed income

MICROSOFT INDIA (R&D) PRIVATE LIMITED,NEW DELHI vs. NEAC, NEW DELHI

In the result, the appeal filed by the assessee is partly allowed for statistical purposes

Bench: Shri Shamim Yahya & Shri Saktijit Deyassessment Year: 2016-17

144C(13)/143(3A)/143(3B) of the Income-tax Act, 1961 (for short ‘the Act’) pursuant to the directions of the Dispute Resolution Panel (DRP). 2 2. The assessee has taken the following grounds of the appeal before the Tribunal:- “1. Orders passed by Transfer Pricing Officer-2(2)(2) (‘Ld. TPO'), draft assessment order passed by Assistant Commissioner

UK GRID SOLUTIONS LIMITED ,UNITED KINGDOM vs. DCIT CIRCLE INTL. TAXATION 3(1)(1), NEW DELHI

In the result, the appeal of the assessee in ITA No

Bench: Shri C. N. Prasad & Shri M. Balaganesh

House reveals that it is an undisclosed agent of GE Energy UK Ltd. upon terms which provide that GE Energy UK Ltd. receives all income and pays all expenditure of the assessee company. It is evident that the assessee company is not a beneficial owner of any income earned by it from its business activities as it is practically fiscally

UK GRID SOLUTIONS LIMITED,UNITED KINGDOM vs. DCIT CIRCLE INTERNATIONAL TAX 3(1)(1), NEW DELHI

In the result, the appeal of the assessee in ITA No

Bench: Shri C. N. Prasad & Shri M. Balaganesh

House reveals that it is an undisclosed agent of GE Energy UK Ltd. upon terms which provide that GE Energy UK Ltd. receives all income and pays all expenditure of the assessee company. It is evident that the assessee company is not a beneficial owner of any income earned by it from its business activities as it is practically fiscally

UK GRID SOLUTIONS LIMITED ,UNITED KINGDOM vs. DCIT CIRCLE INTL. TAXATION 3(1)(1), NEW DELHI

In the result, the appeal of the assessee in ITA No

Bench: Shri C. N. Prasad & Shri M. Balaganesh

House reveals that it is an undisclosed agent of GE Energy UK Ltd. upon terms which provide that GE Energy UK Ltd. receives all income and pays all expenditure of the assessee company. It is evident that the assessee company is not a beneficial owner of any income earned by it from its business activities as it is practically fiscally

UK GRID SOLUTIONS LIMITED,UNITED KINGDOM vs. DCIT CIRCLE INTERNATIONAL TAX 3(1)(1), NEW DELHI

In the result, the appeal of the assessee in ITA No

Bench: Shri C. N. Prasad & Shri M. Balaganesh

House reveals that it is an undisclosed agent of GE Energy UK Ltd. upon terms which provide that GE Energy UK Ltd. receives all income and pays all expenditure of the assessee company. It is evident that the assessee company is not a beneficial owner of any income earned by it from its business activities as it is practically fiscally

PR. COMMISSIONER OF INCOME TAX, INTERNATIONAL TAXATION-1, NEW DELHI vs. COURSERA INC.

Section 144C(1) of the Act. 7. It was the Assessee’s case before the AO that it had received the gross amount of ₹106,18,97,258/- during the previous year relevant to AY 2021- 22 in respect of services rendered. The Assessee had explained that it operates a platform which hosts multimedia courses for consumption of end- users

PR. COMMISSIONER OF INCOME TAX, INTERNATIONAL TAXATION-1, NEW DELHI vs. COURSERA INC.

Bench: HON'BLE MR. JUSTICE VIBHU BAKHRU,HON'BLE MR. JUSTICE TEJAS KARIA

Section 144C(1) of the Act. 7. It was the Assessee’s case before the AO that it had received the gross amount of ₹106,18,97,258/- during the previous year relevant to AY 2021- 22 in respect of services rendered. The Assessee had explained that it operates a platform which hosts multimedia courses for consumption of end- users