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

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

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

8. Based on this it was argued by the ld AR that when the ld DRP‟s directions got uploaded in ITBA portal way back on 07.04.2022 itself, the ld AO ought to have been pass a final assessment order on or before 31.05.2022, whereas, the final assessment order was passed on 30.06.2022 which is barred by limitation. We find

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

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

8 4. The appellant craves leave to add to, alter, amend or vary from the above grounds of appeal at or before the time of hearing.” 9. At the outset, Shri M.S. Syali, the ld. Sr. Counsel, moved an application under Rule 27 of Income-tax (Appellate Tribunal) Rules 1963, raising the following legal ground:- “That on facts

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

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

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

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

8,35,79,90,352 as against INR 7,47.99.55.792 by inadvertently adding" income from house property and other sources amounting to 6 JCB INDIA LTD. Vs. DCIT INR 87.80.34.560 in the computation sheet without appreciating that same were already included in the returned income 10. That on the facts and circumstances of the case

ASSISTANT COMMISSIONER OF INCOME TAX, NEW DELHI vs. RAJAN SEHGAL, DELHI

In the result, the appeal filed by the Revenue is dismissed

Bench: Shri Saktijit Dey, Hon’Ble & Shri S. Rifaur Rahman

144C of the Act as with the following observations. 4. He observed that the transactions for FY 2014-15 were flagged in Non-filers Monitoring System. He observed that entries in Form 26AS and ITS data for the FY 2014-15 indicated that assessee had received following amounts:- (i) Rs.22,73,333/- from Ravissance Developers Private Ltd.; and (ii) Rs.19

ASSISTANT COMMISSIONER OF INCOME TAX, DELHI vs. RAJAN SEHGAL, DELHI

In the result, the appeal filed by the Revenue is dismissed

Bench: Shri Saktijit Dey, Hon’Ble & Shri S. Rifaur Rahman

144C of the Act as with the following observations. 4. He observed that the transactions for FY 2014-15 were flagged in Non-filers Monitoring System. He observed that entries in Form 26AS and ITS data for the FY 2014-15 indicated that assessee had received following amounts:- (i) Rs.22,73,333/- from Ravissance Developers Private Ltd.; and (ii) Rs.19

HERO MOTOCROP LTD.,NEW DELHI vs. ACIT, CIRCLE- 11(1), NEW DELHI

The appeal of the assessee is partly allowed

Bench: Shri Sudhanshu Srivastava & Shri O.P. Kantassessment Year: 2015-16

144C of the Income-tax Act, 1961 ('the Act'), vide order dated 30.10.2019, at an income of Rs. 3146,87,81,016/- under the normal provisions and at book profit of Rs. 3557,57,46,134 under section 115JB of the Act. 2. That the assessing officer/ Transfer Pricing Officer (‘TPO’) erred on facts and in law in partly disallowing

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

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

DCIT, NEW DELHI vs. M/S. MARUTI SUZUKI INDIA LTD., NEW DELHI

In the result, all the three appeals of the assessee are allowed as indicated above and the appeal of Revenue is partly allowed

Bench: Shris.Rifaur Rahman & Shri Vimal Kumar

144C(S) of the Act without judiciously and independently considering e factual and legal objections to the draft assessment order, is illegal and bad in law. 1.2 That the DRP erred on facts and in law in not directing the assessing officer to delete certain additions/ disallowance which were squarely covered in favour of the appellant by the appellate orders

MARUTI SUZUKI INDIA LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result, all the three appeals of the assessee are allowed as indicated above and the appeal of Revenue is partly allowed

Bench: Shris.Rifaur Rahman & Shri Vimal Kumar

144C(S) of the Act without judiciously and independently considering e factual and legal objections to the draft assessment order, is illegal and bad in law. 1.2 That the DRP erred on facts and in law in not directing the assessing officer to delete certain additions/ disallowance which were squarely covered in favour of the appellant by the appellate orders