DLF CYBER CITY DEVELOPERS LTD.,GURUGRAM vs. DCIT, CIRCLE-1(1), GURUGRAM

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

Bench: Shri C. N. Prasad & Shri M. Balaganeshacit, Vs. Dlf Cyber City Developers Ltd, 3Rd Floor, B-Wing, Shopping Mall Circle-1(1), Gurugram Complex, Arjun Marg, Dkf City, Phase-I, Gurgaon, Haryana (Appellant) (Respondent) Pan: Aaccd3572H Dlf Cyber City Developers Ltd, Vs. Addl. Cit, 3Rd Floor, B-Wing, Shopping Mall Range-I, Complex, Arjun Marg, Dkf City, Gurgaon Phase-I, Gurgaon, Haryana (Appellant) (Respondent) Pan: Aaccd3572H

section 80-IAB(1), qualify to be eligible for deduction there-under. That is, the lease rental is within the contemplation of the profits derived by a developer of a SEZ from the 'business' of developing it, eligible for deduction u/s. 80-IAB. It is in fact this that forms the basis of the decisions in Coimbatore Hitech Infrastructure

DLF CYBER CITY DEVELOPERS LTD.,GURUGRAM vs. DCIT, CIRCLE-1(1), GURUGRAM

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

Bench: Shri C. N. Prasad & Shri M. Balaganeshacit, Vs. Dlf Cyber City Developers Ltd, 3Rd Floor, B-Wing, Shopping Mall Circle-1(1), Gurugram Complex, Arjun Marg, Dkf City, Phase-I, Gurgaon, Haryana (Appellant) (Respondent) Pan: Aaccd3572H Dlf Cyber City Developers Ltd, Vs. Addl. Cit, 3Rd Floor, B-Wing, Shopping Mall Range-I, Complex, Arjun Marg, Dkf City, Gurgaon Phase-I, Gurgaon, Haryana (Appellant) (Respondent) Pan: Aaccd3572H

section 80-IAB(1), qualify to be eligible for deduction there-under. That is, the lease rental is within the contemplation of the profits derived by a developer of a SEZ from the 'business' of developing it, eligible for deduction u/s. 80-IAB. It is in fact this that forms the basis of the decisions in Coimbatore Hitech Infrastructure

DLF CYBER CITY DEVELOPERS LTD.,GURUGRAM vs. DCIT, CIRCLE-1, GURUGRAM

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

Bench: Shri C. N. Prasad & Shri M. Balaganeshacit, Vs. Dlf Cyber City Developers Ltd, 3Rd Floor, B-Wing, Shopping Mall Circle-1(1), Gurugram Complex, Arjun Marg, Dkf City, Phase-I, Gurgaon, Haryana (Appellant) (Respondent) Pan: Aaccd3572H Dlf Cyber City Developers Ltd, Vs. Addl. Cit, 3Rd Floor, B-Wing, Shopping Mall Range-I, Complex, Arjun Marg, Dkf City, Gurgaon Phase-I, Gurgaon, Haryana (Appellant) (Respondent) Pan: Aaccd3572H

section 80-IAB(1), qualify to be eligible for deduction there-under. That is, the lease rental is within the contemplation of the profits derived by a developer of a SEZ from the 'business' of developing it, eligible for deduction u/s. 80-IAB. It is in fact this that forms the basis of the decisions in Coimbatore Hitech Infrastructure

ACIT, CIRCLE-1(1), GURUGRAM vs. DLF CYBER CITY DEVELOPERS LTD., GURUGRAM

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

Bench: Shri C. N. Prasad & Shri M. Balaganeshacit, Vs. Dlf Cyber City Developers Ltd, 3Rd Floor, B-Wing, Shopping Mall Circle-1(1), Gurugram Complex, Arjun Marg, Dkf City, Phase-I, Gurgaon, Haryana (Appellant) (Respondent) Pan: Aaccd3572H Dlf Cyber City Developers Ltd, Vs. Addl. Cit, 3Rd Floor, B-Wing, Shopping Mall Range-I, Complex, Arjun Marg, Dkf City, Gurgaon Phase-I, Gurgaon, Haryana (Appellant) (Respondent) Pan: Aaccd3572H

section 80-IAB(1), qualify to be eligible for deduction there-under. That is, the lease rental is within the contemplation of the profits derived by a developer of a SEZ from the 'business' of developing it, eligible for deduction u/s. 80-IAB. It is in fact this that forms the basis of the decisions in Coimbatore Hitech Infrastructure

DLF CYBER CITY DEVELOPERS LTD.,GURGAON vs. ADDL. CIT, GURGAON

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

Bench: Shri C. N. Prasad & Shri M. Balaganeshacit, Vs. Dlf Cyber City Developers Ltd, 3Rd Floor, B-Wing, Shopping Mall Circle-1(1), Gurugram Complex, Arjun Marg, Dkf City, Phase-I, Gurgaon, Haryana (Appellant) (Respondent) Pan: Aaccd3572H Dlf Cyber City Developers Ltd, Vs. Addl. Cit, 3Rd Floor, B-Wing, Shopping Mall Range-I, Complex, Arjun Marg, Dkf City, Gurgaon Phase-I, Gurgaon, Haryana (Appellant) (Respondent) Pan: Aaccd3572H

section 80-IAB(1), qualify to be eligible for deduction there-under. That is, the lease rental is within the contemplation of the profits derived by a developer of a SEZ from the 'business' of developing it, eligible for deduction u/s. 80-IAB. It is in fact this that forms the basis of the decisions in Coimbatore Hitech Infrastructure

ACIT, CIRCLE- 47(1), NEW DELHI vs. J. KISHORE EXPORTS, NEW DELHI

In the result, the appeal of the Revenue is dismissed

Bench: Shri G.S.Pannu & Shri Kul Bharat[Assessment Year : 2014-15] Acit, Vs J.Kishore Exports, Circle-47(1), 558, Katra Ishwar Bhawan, New Delhi. Khari Baoli, New Delhi-110006. Pan-Aagfj9713M Appellant Respondent Appellant By Sh. Ashwani Kalia, Ca Respondent By Sh. Umesh Takyar, Sr.Dr Date Of Hearing 01.11.2021 Date Of Pronouncement 23.11.2021

property in India. viii) The commission was remitted directly to Midland General Trading (LLC), outside India as per RBI's guidelines and not received by anyone on behalf of it in India. ix) The Explanation to Section 9(2) inserted by Finance Act, 2010 with retrospective effect from 01.06.1976, by virtue of which the income of the non-resident from

YOSHIO KUBO vs. COMMISSIONER OF INCOME TAX

The appeals are disposed of accordingly

195 of the Income Tax Act cannot also be ignored in this context. It would be unrealistic to say that the said payment had no integral connection with the salary received by the assessee. We are, therefore, of the opinion that the High Court and the authorities under the Act were right in holding that the said tax amount

YOSHIO KUBO vs. COMMISSIONER OF INCOME TAX

The appeals are disposed of accordingly

195 of the Income Tax Act cannot also be ignored in this context. It would be unrealistic to say that the said payment had no integral connection with the salary received by the assessee. We are, therefore, of the opinion that the High Court and the authorities under the Act were right in holding that the said tax amount

YOSHIO KUBO vs. COMMISSIONER OF INCOME TAX

The appeals are disposed of accordingly

195 of the Income Tax Act cannot also be ignored in this context. It would be unrealistic to say that the said payment had no integral connection with the salary received by the assessee. We are, therefore, of the opinion that the High Court and the authorities under the Act were right in holding that the said tax amount

NIIT FOUNDATION,NEW DELHI vs. CIT(E), NEW DELHI

In the result, the appeal of the assessee is allowed

Bench: Shri Prashant Maharishi & Shri K.N.Charyniit Foundation, Vs. Cit(E), Plot No. 8, Balaji Estate, New Delhi Sudarshan Munjal Marg, Kalkaji, New Delhi Pan: Aacan3951E (Appellant) (Respondent)

houses has been subjected to tax deduction at source under section 194J and therefore the nature of these receipts are commercial in nature. Further it was also point of concern for CIT exemption that the turnover from services reported to the service tax authorities amounted to " 38665028 and assessee has also paid service tax on the fees etc received from

MRS. RASHMI DHARIWAL,NEW DELHI vs. ACIT, NEW DELHI

In the result ground No. 11 and 12 of the appeal of the assessee are allowed accordingly

Bench: Shri H.S.Sidhu & Shri Prashant Maharishirashmi Dhariwal, Vs. Acit, Aashray Farms, Sub Po, Circle-23(1), Sawan Public School, Bhatti New Delhi Mines, Asola Village, New Delhi Pan:Aappd9702P (Appellant) (Respondent)

section 143 (3) of the act wide order dated 29th of December 2010. Aggrieved by the order of the Ld. assessing officer assessee preferred an appeal before the Ld. CIT (A) who confirmed the action of the Ld. assessing officer in making an addition of an amount of Rs. 3 60 3966/– under that income from house property. He also

ACIT, NEW DELHI vs. M/S. KCT PAPERS LTD., NEW DELHI

In the result, grounds raised by the revenue are dismissed

Bench: Shri S.Rifaur Rahman & Shri Anubhav Sharmaacit, Circle 5 (1) Vs. M/S. Kct Papers Limited, New Delhi. Thapar House, 124, Janpath, New Delhi – 110 001. (Pan : Aacck4937D) (Appellant) (Respondent) Assessee By : Shri Rohit Jain, Advocate Shri Deepesh Jain, Advocate Shri Tavish Verma, Advocate Revenue By : Shri Kailash Dan Ratnoo, Cit Dr Date Of Hearing : 10.09.2025 Date Of Order : 05.12.2025 O R D E R Per S.Rifaur Rahman: 1. This Appeal Is Filed By The Assessee Against The Order Of Ld. Commissioner Of Income-Tax (Appeals)-Viii, New Delhi [Hereinafter Referred To As ‘Ld. Cit (A)] Dated 21.03.2014For Assessment Year 2008-09. 2. Brief Facts Of The Case Are, The Assessee Company Belongs To The Thapar Group Established By Late Lala Karam Chand Thapar. There Was A Family Settlement Between The Various Constituents Of The Karam Chand Thapar Family As A Result Of Which Revenue-Organization/Restructuring Of The Group Dated 27Th April, 2001. The Re April, 2001. The Re-Organization Of The Group Companies & Trusts Organization Of The Group Companies & Trusts Was Made Into Four Groups, As Under, Each Headed By The Sons Of Late Lala Was Made Into Four Groups, As Under, Each Headed By The Sons Of Late Lala Was Made Into Four Groups, As Under, Each Headed By The Sons Of Late Lala K.C. Thapar. The Family Tree Of Karam Chand T K.C. Thapar. The Family Tree Of Karam Chand Thapar Family Is Explained As Hapar Family Is Explained As Under In The Form Of A Diagrammatic Chart: Under In The Form Of A Diagrammatic Chart:

House, 124, Janpath, New Delhi – 110 001. (PAN : AACCK4937D) (APPELLANT) (RESPONDENT) ASSESSEE BY : Shri Rohit Jain, Advocate Shri Deepesh Jain, Advocate Shri Tavish Verma, Advocate REVENUE BY : Shri Kailash Dan Ratnoo, CIT DR Date of Hearing : 10.09.2025 Date of Order : 05.12.2025 O R D E R PER S.RIFAUR RAHMAN, ACCOUNTANT MEMBER : 1. This appeal is filed by the assessee against

SHIV KUMAR JATIA,NEW DELHI vs. ITO, WARD- 10(2), NEW DELHI

The appeals of the assessee are allowed

Bench: Sh. Bhavnesh Sainidr. B. R. R. Kumar(Through Video Conferencing) Ita No. 7256/Del/2019 : Asstt. Year : 2011-12 Ita No. 241/Del/2019 : Asstt. Year : 2013-14 Sh. Shiv Kumar Jatia, Vs Income Tax Officer, B-50, Gulmohar Park, Ward-10(2), New Delhi-110049 New Delhi-110002 (Appellant) (Respondent) Pan No. Aabpj7582K Assessee By : Sh. C. S. Aggarwal, Sr. Adv. Revenue By : Sh. Prakash Dubey, Sr. Dr Date Of Hearing: 10.03.2021 Date Of Pronouncement: 26.04.2021

house property" is a loss, in respect of the assessment years commencing on the 1st day of April, 1995 and the 1st day of April, 1996, such loss shall be first set off under sub-sections (1) and (2) and thereafter the loss referred to in section 71A shall be set off in the relevant assessment year in accordance with

SHIV KUMAR JATIA,NEW DELHI vs. ITO, WARD- 10(2), NEW DELHI

The appeals of the assessee are allowed

Bench: Sh. Bhavnesh Sainidr. B. R. R. Kumar(Through Video Conferencing) Ita No. 7256/Del/2019 : Asstt. Year : 2011-12 Ita No. 241/Del/2019 : Asstt. Year : 2013-14 Sh. Shiv Kumar Jatia, Vs Income Tax Officer, B-50, Gulmohar Park, Ward-10(2), New Delhi-110049 New Delhi-110002 (Appellant) (Respondent) Pan No. Aabpj7582K Assessee By : Sh. C. S. Aggarwal, Sr. Adv. Revenue By : Sh. Prakash Dubey, Sr. Dr Date Of Hearing: 10.03.2021 Date Of Pronouncement: 26.04.2021

house property" is a loss, in respect of the assessment years commencing on the 1st day of April, 1995 and the 1st day of April, 1996, such loss shall be first set off under sub-sections (1) and (2) and thereafter the loss referred to in section 71A shall be set off in the relevant assessment year in accordance with

COMMISSIONER OF INCOME TAX

195 (SC) in support of his contention that in order for a new industrial undertaking to be established, there must be an emergence of a physically separate industrial Unit which may exist on its own as a viable Unit. It was submitted that this condition was fulfilled as Unit Nos.2 & 3 were capable to carry on their activity independent

COMMISSIONER OF INCOME TAX-IV vs. DELHI PRESS PATRA PRAKASHAN LTD

195 (SC) in support of his contention that in order for a new industrial undertaking to be established, there must be an emergence of a physically separate industrial Unit which may exist on its own as a viable Unit. It was submitted that this condition was fulfilled as Unit Nos.2 & 3 were capable to carry on their activity independent

COMMISSIONER OF INCOME TAX

195 (SC) in support of his contention that in order for a new industrial undertaking to be established, there must be an emergence of a physically separate industrial Unit which may exist on its own as a viable Unit. It was submitted that this condition was fulfilled as Unit Nos.2 & 3 were capable to carry on their activity independent

THE COMMISSIONER OF INCOME TAX vs. DELHI PRESS PATRA PRAKASHAN LT

195 (SC) in support of his contention that in order for a new industrial undertaking to be established, there must be an emergence of a physically separate industrial Unit which may exist on its own as a viable Unit. It was submitted that this condition was fulfilled as Unit Nos.2 & 3 were capable to carry on their activity independent

COMMISSIONER OF INCOME TAX

195 (SC) in support of his contention that in order for a new industrial undertaking to be established, there must be an emergence of a physically separate industrial Unit which may exist on its own as a viable Unit. It was submitted that this condition was fulfilled as Unit Nos.2 & 3 were capable to carry on their activity independent