SAS FASHIONS P. LTD.,NEW DELHI vs. DCIT, CIRCLE-22(2), NEW DELHI

In the result, appeal of assessee in ITA No

Bench: Shri Anubhav Sharma & Shri Naveen Chandra

House property” income or not. The hon’ble Delhi High Court in Prem Brothers Infrastructure LLP v. NFAC (supra) quashed the penalty u/s 270A on the ground that there was no misreporting and that in absence of details as to which limb of section

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

house property. 4. That on the facts and in law, the Ld. AO erred in not deciding the legal and factual issues arising out of the adjustments made vide intimation u/s 143(1) Page 2 of 12 ITA nos.- 1483 & 1640/Del/2022 Microsoft India (R&D) Pvt. Ltd. of the Act of Rs 12,53,64,240 and merely repeating

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

house property. 4. That on the facts and in law, the Ld. AO erred in not deciding the legal and factual issues arising out of the adjustments made vide intimation u/s 143(1) Page 2 of 12 ITA nos.- 1483 & 1640/Del/2022 Microsoft India (R&D) Pvt. Ltd. of the Act of Rs 12,53,64,240 and merely repeating

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 in which he had 1/3rd share. The Ld. AO noted that this property was inherited by the assessee from his parents who had purchased the property in 1967/69. Since the property was purchased prior to 1st April, 2001, the assessee got it valued from a registered valuer and used the value for determining tax payable on long term capital

SMT. SUCHITA GOYAL,DELHI vs. PCIT,-15, DELHI

In the result, appeal of the assessee is allowed

Bench: Shri Mahavir Singh, Hon’Ble & Shri Sanjay Awasthiआ.अ.सं/.I.T.A No.2860/Del/2025 िनधा"रणवष"/Assessment Year: 2020-21 बनाम Smt. Suchita Goyal, Pcit-15, Plot No.32, First Floor, Road No.43, Vs. Room No.1702, E-3 Block, Ashoka Park, Extension, S.P. Shivaji Park, Civic Centre, Minto Road, West Delhi. Delhi. Pan No.Aafpg5320G अपीलाथ" Appellant ""यथ"/Respondent

section 270A(9) of the Act.” 2. Before us, the Ld. AR pointed out that the facts in this case were that a loan had been taken by the assessee for buying a property bearing no.1001, situated at 10th floor in one “R.G. Trade Tower, Netaji Subhash Place, (Pitampura, Delhi)”. The loan from this property was transferred to a subsequent

DCIT, DELHI vs. PERSONIV CONTACT CENTERS INDIA PRIVATE LIMITED, DELHI

In the result, appeal of the assessee is allowed

Bench: Shri Mahavir Singh, Hon’Ble & Shri Sanjay Awasthiआ.अ.सं/.I.T.A No.2860/Del/2025 िनधा"रणवष"/Assessment Year: 2020-21 बनाम Smt. Suchita Goyal, Pcit-15, Plot No.32, First Floor, Road No.43, Vs. Room No.1702, E-3 Block, Ashoka Park, Extension, S.P. Shivaji Park, Civic Centre, Minto Road, West Delhi. Delhi. Pan No.Aafpg5320G अपीलाथ" Appellant ""यथ"/Respondent

section 270A(9) of the Act.” 2. Before us, the Ld. AR pointed out that the facts in this case were that a loan had been taken by the assessee for buying a property bearing no.1001, situated at 10th floor in one “R.G. Trade Tower, Netaji Subhash Place, (Pitampura, Delhi)”. The loan from this property was transferred to a subsequent

GURPREET SINGH DHILLON,INDIA vs. DCIT, CIRCLE INT TAX 1(2)(2), DELHI

In the result, appeal of the assessee is allowed

Bench: Shri Sudhir Pareek & Shri Brajesh Kumar Singh[Assessment Year: 2022-23] Gurpreet Singh Dhillon, Dcit, Kothi No. 2, Dear Baba Circle Int. Tax 1(2)(2), Jaimal Singh, Beas, Vs Civic Centre, Minto Road, Amritsar, New Delhi-110002. Punjab-143204 Pan- Afqpd5302R Assessee Revenue

Section 143(3) r.w.s. 144C(3) of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) by the ACIT, Circle 1(2)(2), International Taxation, New Delhi, (hereinafter referred to as the ‘Ld. AO’) pertaining to A.Y. 2022-23. 2. Brief facts of the case: During the year the assessee had earned rental Income from leased out property

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.

270A or section 271 or section 271BA, if any person in respect of an international transaction or specified domestic transaction,— (i) fails to keep and maintain any such information and document as required by sub-section (1) or sub-section (2) of section 92D; (ii) fails to report such transaction which he is required to do so; or (iii) maintains

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)

270A of the Act, dated 15.04.2021, would have to be set aside. It is ordered accordingly. 4.1. Liberty, however, is granted to the revenue to take next steps in the matter, in accordance with the law. 5. The writ petition and the pending applications are disposed of in the aforesaid terms.” (emphasis supplied)  Reliance is also placed on the decision

JUBILANT GENERICS LTD.,NOIDA vs. ACIT, CIRCLE- 5(1)(1), G.B. NAGAR

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

270A of the Act on arbitrary\npremise that there is under-reporting of Income done by the Appellant.”\n\nFacts of the case:\n\n3. The relevant facts giving rise to this appeal are that the assessee,\nengaged in the business of manufacturing pharmaceutical products,\nincluding Active Pharmaceutical Ingredients (APIs) and Dosage forms, filed\nits Income Tax Return (ITR') declaring

WE ARE VOICES ENTERTAINMENT INC,GURGAON vs. DCIT INTERNATIONAL TAXATION 3(1)(1), DELHI

In the result, the appeal of the assessee is allowed

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

270A of the Act mechanically and without recording any adequate satisfaction for such initiation.” 3. Briefly stated, the assessee is a non-resident company incorporated under the laws of USA and is a tax resident of USA. The assessee is engaged in the business of branding and talent book agency services and inter alia acts as a mediator

SIMRAN BAGGA,DUBAI vs. ACIT,CIRCLE INT. TAXATION, 1(1)(2), NEW DELHI

In the result, the appeal of the assessee is allowed

Bench: Sh. Saktijit Deydr. B. R. R. Kumar

section 54 of the Income-tax Act, 1961 ('the Act'). 1.3 That on the facts and in the circumstances of the case and in law, the Ld. AO has erred in law in proposing to initiate penalty proceeding u/s 270A(9)(a) of the Act for under reporting of income in consequence to misreporting of income for 'misrepresentation or suppression

GE PRECISION HEALTHCARE LLC,USA vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE 1(3)(1), MINTO ROAD, NEW DELHI

In the result, the appeal of the assessee is allowed

Bench: Sh. Saktijit Deydr. B. R. R. Kumar

270A of the Act.” 3. Heard the arguments of both the parties and perused the material available on record. 3 GE Precision Healthcare LLC 4. GE Precision Healthcare LLC, is a company incorporated in the state of Delaware, USA. It carries on healthcare business for the General Electric group, and is a global medical device provider that designs, develops, manufactures

ARADHYA GHOSH,KOLKATA vs. DCIT, CIRCLE-69(1), DELHI

In the result, appeal of the assessee is allowed

Bench: Shri Chandra Mohan Garg

house property and income from other sources during the 2 ITA.No.1788/Del./2022 Shri Aradhya Ghosh, Kolkata. financial year relevant to the assessment year under consideration. The assessee filed return of income on 31.05.2017 declaring total income of Rs.42,63,710/- which was processed under section 143(1) of the Income Tax Act, 1961. Later, the assessee filed his revised

AGILENT TECHNOLOGIES (INTERNATIONAL) PRIVATE LTD,HARYANA vs. CIRCLE 1(1), DELHI

Bench: Shri Kul Bharat & Dr. B. R. R. Kumar

section 270A of the Act for misreporting of income. 3. The Agilent Technologies (International) Private Limited ("Agilent International" or "the aassessee" or "the Company") is a 100% subsidiary of Agilent Technologies International Europe, BV which in turn is a wholly owned subsidiary of Agilent Technologies Inc. The assessee is engaged in the provision of IT services & ITeS

SUDARSHAN DE,NEW DELHI vs. DCIT,CIRCLE-2(1)(1), GHAZIABAD

In the result, the Appeal of the Assessee is allowed

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwalsudarsan De Vs. Dcit C/O. C S Anand, Advocate Circle-2(1)(1), B-81, First Floor, (Part B), Ghaziabad Defence Colony, Bhishma Pitamah Marg, New Delhi Pan: Abdpd3749F Appellant Respondent Assessee By Advocate C.S. Anand & Advocate Vaishnavi Yadav Revenue By Sh. Manish Gupta, Sr. Dr Date Of Hearing 26/05/2025 Date Of Pronouncement 30/05/2025 Order Per Yogesh Kumar, U.S. Jm:

house property loss of Rs.2,00,000/- and Chapter VIA deduction at Rs.1,85,000/-. 2 Sudarshan De Vs. DCIT 3. The assessment in the case of the Assessee was completed at the return income. However, the Ld. A.O. recorded satisfaction for ‘under reporting the income’ and initiated of penalty u/s 270A of the Act. An order of penalty came

MASSIMO DUTTI INDIA PRIVATE LIMITED,GURGAON vs. ACIT, CIRCLE-1(1), GURGAON

In the result, the appeal of the Assessee is allowed

Bench: Shri M. Balaganesh & Shri Vimal Kumarmassimo Dutti India Pvt. Ltd, Vs. Acit, Unit No. 1 (Office 1) 8Th Floor, Circle-1(1), Ambience Island, Nh-8, Gurgaon Gurugram, Hayana-122 002 (Appellant) (Respondent) Pan: Aajcm0103G Assessee By : Shri Ravi Sharma, Adv Ms. Shruti Khimta, Adv Ms. Kashish Gupta, Ca Revenue By: Shri S. K. Jadav, Cit Dr Date Of Hearing 11/09/2025 Date Of Pronouncement 08/12/2025

house its inventory procured from its AEs and resells the same. Hence the entire risks are assumed by the Assessee herein as a routine distributor. Massimo Dutti India Pvt. Ltd We hold the Assessee to be a routine distributor assuming market risk, limited inventory risk, product liability risk and limited bad debts risk. Whereas the AE is classified

PRANAV VIKAS INDIA PVT LTD.,NEW DELHI vs. DCIT,CIRCLE-19(1), DELHI

In the result, the Assessee’s appeal is allowed

Bench: Shri Shamim Yahya

property. The assessee had claimed the business loss of Rs. 3,28,29,990/-. After set-off loss, the assessee had admitted total loss of Rs. 2,50,29,113/-. The assessee’s case was selected for scrutiny under CASS. The Assessing Officer (AO) issued notice u/s. 143(2) of the Act and completed the assessment by disallowing difference