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

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

5)/2022-23/1042628144(1) was dispatched through speed post to the concerned officers; details of the same are as under:] SI. Concerned Officer Speed Post No. Date No. 01. The Pr. Commissioner of Income ED071553665IN 12.04.2022 - Tax,National e Assessment Centre, Delhi 02. The Commissioner of Income tax. ED071553753IN 12.04.2022 , Transfer Pricing -2, Delhi ED071553682IN 12.04.2022 03. The Addl./Joint/Deputy/Asst

M/S. BECHTEL INDIA PVT. LTD.,NEW DELHI vs. DCIT, NEW DELHI

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

Bench: Shri S.V. Mehrotra & Shri Chandra Mohan Garg

House, Circle-2(1), 21, K.G. Marg, New Delhi. New Delhi. (PAN: AAACB0298A) (Appellant) (Respondent) Appellant by: S/Shri S.D. Kalipa, R.R.Maurya, Praveen Sharma, Sanjay Kumar, Advocates Respondent by : S/Shri Ravi Jain, CIT DR, Subhakant Sahoo, Sr. DR Date of last hearing: 12.10.2015 Date of pronouncement: 14.10.2015 O R D E R PER CHANDRAMOHAN GARG, J.M. This appeal by the assessee

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

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

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

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

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. 4. Aggrieved by the assessment order passed u/s 143(3) r.w.s 144C

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

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

house property as adopted by the AO/DRP at Rs.1,03,43,551 for Appellant’s 1/3rd share s inadequate and the addition of Rs.2,23,23,116 as made towards long term capital gain is very excessive. 6. That the levy of interest under section 234D of Rs.9,00,769 is illegal and at any rate, very excessive. 7. That

M/S. DHARAMPAL SATYAPAL LTD.,DELHI vs. ACIT, NEW DELHI

Bench: Shri Amit Shukla & Sh. Prashant Maharishi(Through Video Conferencing) Assessment Year: 2012-13 M/S. Dharampal Satyapal Ltd. Acit, 1711, S. P. Mukherjee Marg, Vs Central Circle – 29, Delhi-110006 New Delhi Pan No. Aaacd0132H (Appellant) (Respondent) Appellant By Sh. R. S. Singhavi, Ca Sh. Satyajeet Goel, Ca Respondent By Sh. Sanjay I. Bara, Cit Dr Date Of Hearing: 28/08/2020 Date Of Pronouncement: 07/10/2020 Order

144C of the act before The Dispute Resolution Panel – I, New Delhi (the learned DRP). Such objections were disposed of by giving direction on 16 December 2016. Consequent to that the assessment order was passed u/s 143 (3) of the act on 30/1/2017 determining the total taxable income of the assessee of ₹ 1,200,423,319. The learned assessing officer

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

DCIT, NEW DELHI vs. M/S. UNITECH LTD., NEW DELHI

In the result this issue is allowed in favour of the assessee

Bench: Shri Amit Shukla & Shri L.P. Sahu

144C (5) vide order dated 27.10.2015, culminating into final assessment order dated 27.10.2015. 2. We will first take up revenue’s appeal wherein the only ground raised is, deletion of addition of Rs. 7,24,88,104/- proposed by the AO on account of interest paid to Tata Realty Infrastructure Limited. The facts in brief are that assessee company

M/S. UNITECH LIMITED,NEW DELHI vs. DCIT, NEW DELHI

In the result this issue is allowed in favour of the assessee

Bench: Shri Amit Shukla & Shri L.P. Sahu

144C (5) vide order dated 27.10.2015, culminating into final assessment order dated 27.10.2015. 2. We will first take up revenue’s appeal wherein the only ground raised is, deletion of addition of Rs. 7,24,88,104/- proposed by the AO on account of interest paid to Tata Realty Infrastructure Limited. The facts in brief are that assessee company

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

5 of the appeal of the assessee is against an addition of Rs. 3.02 lakhs by estimating the value of the scrap lying in stock as at the end of the relevant previous year on hypothetical and national basis. Ld. assessing officer on perusal of the significant accounting policies mentioned in scheduled 12 of the financial statements for the financial

MICROSOFT INDIA (R&D) P.LTD,NEW DELHI vs. DCIT, CIRCLE-16(1), NEW DELHI

In the result, appeal of the assessee is partly allowed

Bench: Shri N.K. Billaiya & Ms Astha Chandra

144C(13) of the Act. Since common issues are involved, both these appeals were Page 1 of 12 ITA nos.- 1483 & 1640/Del/2022 Microsoft India (R&D) Pvt. Ltd. heard together and are disposed of by this common order for the sake of convenience and brevity. ITA No.- 1483/Del/2022 for A.Y. 2017-18 2. The grievances of the assessee read

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

In the result, appeal of the assessee is partly allowed

Bench: Shri N.K. Billaiya & Ms Astha Chandra

144C(13) of the Act. Since common issues are involved, both these appeals were Page 1 of 12 ITA nos.- 1483 & 1640/Del/2022 Microsoft India (R&D) Pvt. Ltd. heard together and are disposed of by this common order for the sake of convenience and brevity. ITA No.- 1483/Del/2022 for A.Y. 2017-18 2. The grievances of the assessee read