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

CAIRN UK HOLDING LTD.,AHMEDABAD vs. DCIT (INTERNATIONAL TAXATION), NEW DELHI

In the result ground No. 5 of the appeal of the assessee is allowed

Bench: Shri H. S. Sidhu & Shri Prashant Maharishi

144C (13) of the Income Tax Act final assessment order on 25th January 2016 determining the total income of the assessee at Rs. 245035012588/– as short-term capital gain chargeable to tax in the hands of appellant taxable at the rate of 40%. Subject to chargeability of surcharge and cess as applicable. Further, Cairn U K Holdings Limited V DCIT

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

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.

144C(5) of the Act dated 16.05.2023 does not bear the DIN Number, was stated to be not pressed by the learned AR at the time of hearing. The same is reckoned as a statement made from the bar and accordingly, the additional ground raised by the assessee is hereby dismissed as not pressed. 3. Though, the assessee has raised

HERO MOTOCORP LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result appeal No. 2424/Del/ 2015 filed by the revenue in assessment year 2010-11 is partly allowed

Bench: Shri R. K. Panda & Ms Suchitra Kamble

144C passed by DCIT, Circle-11(1), New Delhi vide order dated 20/1/2017. 2. Ground No. 1 to 15 relate to addition of Transfer Pricing Adjustment u/s 92CA of the Income Tax Act, 1961. The addition/disallowance for Model Fee is Rs.172.08 Crore and for royalty is Rs.3.53 crore. During the relevant previous year, the assessee, for the purpose

HERO MOTOCORP LTD.,,NEW DELHI vs. ADDL.CIT, RANGE-11, NEW DELHI

In the result ground No

Bench: Shri R. K. Panda & Ms Suchitra Kamblei.T.A. No. 6990/Del/2017 (A.Y 2013-14)

144C passed by Addl.CIT, Range-11, New Delhi vide order dated 27/10/2017. 2. As regards Ground No. 3 to 3.1, relating to addition of freight inward/import clearing expenses to cost of closing inventory amounting to Rs. 3,17,000, it can be seen that the Assessee purchases raw material on CIF basis and included the freight cost for delivery

GE MONEY FINANCIAL SERVICES PVT. LTD.,DELHI vs. DCIT, NEW DELHI

In the result ground, no

Bench: Shri A.T.Varkey & Shri Prashant Maharishi

house and were essential for Appellant's business operations; c) That all intra-group services were in the nature of shareholder and stewardship activities, ignoring the fact that all the shareholder and stewardship activities were separately identified by the AEs and no amount for such activities had been paid by the Appellant. d) That the Appellant failed to satisfactorily explain

GE MONEY FINANCIAL SERVICES PVT. LTD.,NEW DELHI vs. ACIT, NEW DELHI

In the result ground, no

Bench: Shri A.T.Varkey & Shri Prashant Maharishi

house and were essential for Appellant's business operations; c) That all intra-group services were in the nature of shareholder and stewardship activities, ignoring the fact that all the shareholder and stewardship activities were separately identified by the AEs and no amount for such activities had been paid by the Appellant. d) That the Appellant failed to satisfactorily explain

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

144C of the Act. In such a draft order, the income is first computed by the Assessing Officer under respective heads, such as, 15 income chargeable under the head "Income from house property" is computed under section 24; income under the head `Profits and gains of business or profession’ is computed under section 29; income under the head `Capital gains

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

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

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

144C of the Income-tax Act, 1961 ('the Act'), vide order dated 30.04.2021, at an income of Rs. 31,66,82,06,82 1-/- under the normal provisions and at book profit of Rs. 43,79,43,08,839 under section 1l5JB of the Act. Re: Transfer Pricing Adjustment under section 92CA relating to inter unit transfer 2. That

VENETIAN LDF PROJECTS LLP,GURGAON vs. ACIT CIRCLE-4(1), GURGAON

In the result, grounds raised by the assessee are dismissed

Bench: Shri S. Rifaur Rahman & Shri Vimal Kumar

House: 139 ITR 182 (P&H) 158 In the facts of the present case, the Pr. CIT, in respect of all the issues, have merely held that further enquiry and examination is required, without even recording as to how the assessment order sought to be revised is erroneous on such issues; no error whatsoever has been pointed out regarding

CAIRN INDIA LTD.,GURGAON vs. DCIT, GURGAON

In the result, the appeal of the assessee in ITA Nos

Bench: Shri N.K. Billaiya & Ms. Suchitra Kamble[A.Y 2011-12] & [A.Y 2012-13] Cairn India Ltd., Vs. The A.C.I.T, Dlf Atria Building, Circle-1(1), Jacaranda Marg, N Block, Gurgaon. Dlf City Phase Ii, Gurgaon. [Pan: Aaccc 8799D] [Appellant] [Respondent] Date Of Hearing : 17.10.2018 Date Of Pronouncement : 24.10.2018 Assessee By : Shri Ajay Vohra, Sr. Adv Shri Ravi Sharma, Adv

144C(4) of the Income-tax Act, 1961 [hereinafter referred to as 'the Act]' pertaining to A.Y 2011-12. Since both these appeals were heard together, they are being disposed of by this common order for the sake of convenience and brevity, though the quantum may differ. 2. The common grievance in both these appeals relates to the addition being

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

BHUPINDER SINGH JULKA,NEW DELHI vs. ACIT, CIRCLE-INT. TAX. 2(1)(2), DELHI

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

Bench: Shri Kul Bharat & Shri M. Balaganesh

144C(13) of the Act. ITA No.-1807/Del/2022 Bhupinder Singh Julka 2. That ground no 2 to 2.2 relates to grievance of appellant in respect of addition of Rs. 3,37,202/- representing alleged short term capital gain as against claim of long term capital loss of Rs. 81,42,760/- on sale of capital asset by the appellant

HEWITT ASSOCIATES (INDIA) PVT. LTD.,GURGAON vs. ACIT, NEW DELHI

In the result, the appeal of the assesee is treated as allowed for statistical purposes

Bench: Shri R.K. Panda & Ms. Astha Chandraasstt. Year : 2007-08

144C of the Act, we request your goodself to allow us the benefit of working capital adjustment. Based on the above submission, we request your goodself to rectify the above- mentioned defects by passing a suitable order under section 154 of the Act and accordingly issue the revised assessment order. ------------------------------ Unquote 2. In addition to the above-mentioned prima facie

THE COMMISSIONER OF INCOME TAX - INTERNATIONAL TAXATION -3 vs. TELSTRA SINGAPORE PTE LTD.

Bench: CASES PERTAINING TO SPL.DIVISION BENCHES

144C of the Act, a Draft Assessment Order is stated to have been framed with the Assessing Officer9 proposing that the amount received by the respondent from Indian customers for the provision of bandwidth services outside India being liable to be construed as constituting equipment/process royalty taxable under Section 9(1)(vi) of the Act read along with Article