(Now known as Sony India Limited)

36 of 142 valuation of the contract price and computation of the arm‘s length price, consequent assessments etc. are without jurisdiction and authority of law. 43. This argument on behalf of the assessees would have been weighty and perhaps justified, if the Legislature by the Finance Act, 2012 had not inserted sub-section (2B). The said Sub-Section

OM PRAKASH JAKHOTIA,TELANGNA vs. ACIT, CC-26, NEW DELHI

The appeals of the assessee are allowed

Bench: Shri Amit Shukla & Dr. B.R.R. Kumar

36 We have heard the arguments of both the parties and also considered their written submissions and material placed on record before us which was referred to at the time of hearing. 37 In so far as admission of additional grounds as raised by the assessee for the A.Y 2009-10 and AY 2011-12, are concerned, we find that

OM PRAKASH JAKHOTIA,TELANGNA vs. ACIT, CC-26, NEW DELHI

The appeals of the assessee are allowed

Bench: Shri Amit Shukla & Dr. B.R.R. Kumar

36 We have heard the arguments of both the parties and also considered their written submissions and material placed on record before us which was referred to at the time of hearing. 37 In so far as admission of additional grounds as raised by the assessee for the A.Y 2009-10 and AY 2011-12, are concerned, we find that

OM PRAKASH JAKHOTIA,TELANGNA vs. ACIT, CC-26, NEW DELHI

The appeals of the assessee are allowed

Bench: Shri Amit Shukla & Dr. B.R.R. Kumar

36 We have heard the arguments of both the parties and also considered their written submissions and material placed on record before us which was referred to at the time of hearing. 37 In so far as admission of additional grounds as raised by the assessee for the A.Y 2009-10 and AY 2011-12, are concerned, we find that

OM PRAKASH JAKHOTIA,TELANGNA vs. ACIT, CC-26, NEW DELHI

The appeals of the assessee are allowed

Bench: Shri Amit Shukla & Dr. B.R.R. Kumar

36 We have heard the arguments of both the parties and also considered their written submissions and material placed on record before us which was referred to at the time of hearing. 37 In so far as admission of additional grounds as raised by the assessee for the A.Y 2009-10 and AY 2011-12, are concerned, we find that

INDIAN NATIONAL CONG. (I) AICC vs. C.I.T.- XI

36 of 71 by way of ‘voluntary contribution’. In any event since it did not fall within the definition of income under Section 2(24) of the Act it could not be held liable to be assessed as that would be beyond the scope of Section 5 of the Act. 64. Mr Aggarwal submitted that had income

DCIT, CENTRAL CIRCLE-25, NEW DELHI vs. MAHAVEER TRANSMISSION LTD, NEW DELHI

In the result, the all appeals of the assessee are allowed and all the appeals of the Revenue are dismissed

Bench: Dr. B. R. R. Kumar, Sh. Sudhir Kumar

36. The AO has quoted bank statement of the supplier with respect to the above observation. ITA Nos. 2844 to 2846/Del/2022 Mahavir Transmission Ltd. i. It is evident from the bank statement reproduced by the AO himself that the assessee has made purchases through banking channels only which have also been duly received by these suppliers. ii. There

DCIT, CENTRAL CIRCLE-25, NEW DELHI vs. MAHAVEER TRANSMISSION LTD., NEW DELHI

In the result, the all appeals of the assessee are allowed and all the appeals of the Revenue are dismissed

Bench: Dr. B. R. R. Kumar, Sh. Sudhir Kumar

36. The AO has quoted bank statement of the supplier with respect to the above observation. ITA Nos. 2844 to 2846/Del/2022 Mahavir Transmission Ltd. i. It is evident from the bank statement reproduced by the AO himself that the assessee has made purchases through banking channels only which have also been duly received by these suppliers. ii. There

MAHAVIR TRANSMISSION LTD,NEW DELHI vs. DCIT, CENTRAL CIRCLE-25, NEW DELHI

In the result, the all appeals of the assessee are allowed and all the appeals of the Revenue are dismissed

Bench: Dr. B. R. R. Kumar, Sh. Sudhir Kumar

36. The AO has quoted bank statement of the supplier with respect to the above observation. ITA Nos. 2844 to 2846/Del/2022 Mahavir Transmission Ltd. i. It is evident from the bank statement reproduced by the AO himself that the assessee has made purchases through banking channels only which have also been duly received by these suppliers. ii. There

MAHAVIR TRANSMISSION LTD,NEW DELHI vs. DCIT, CENTRAL CORCLE-25, NEW DELHI

In the result, the all appeals of the assessee are allowed and all the appeals of the Revenue are dismissed

Bench: Dr. B. R. R. Kumar, Sh. Sudhir Kumar

36. The AO has quoted bank statement of the supplier with respect to the above observation. ITA Nos. 2844 to 2846/Del/2022 Mahavir Transmission Ltd. i. It is evident from the bank statement reproduced by the AO himself that the assessee has made purchases through banking channels only which have also been duly received by these suppliers. ii. There

DCIT, CENTRAL CIRCLE-25, NEW DELHI vs. MAHAVEER TRANSMISSION LTD, NEW DELHI

In the result, the all appeals of the assessee are allowed and all the appeals of the Revenue are dismissed

Bench: Dr. B. R. R. Kumar, Sh. Sudhir Kumar

36. The AO has quoted bank statement of the supplier with respect to the above observation. ITA Nos. 2844 to 2846/Del/2022 Mahavir Transmission Ltd. i. It is evident from the bank statement reproduced by the AO himself that the assessee has made purchases through banking channels only which have also been duly received by these suppliers. ii. There

MAHAVIR TRANSMISSIN LTD ,NEW DELHI vs. DCIT, CENTRAL CIRCLE-25 , NEW DELHI

In the result, the all appeals of the assessee are allowed and all the appeals of the Revenue are dismissed

Bench: Dr. B. R. R. Kumar, Sh. Sudhir Kumar

36. The AO has quoted bank statement of the supplier with respect to the above observation. ITA Nos. 2844 to 2846/Del/2022 Mahavir Transmission Ltd. i. It is evident from the bank statement reproduced by the AO himself that the assessee has made purchases through banking channels only which have also been duly received by these suppliers. ii. There

MAHAVIR TRANSMISSION LTD,NEW DELHI vs. DCIT, CENTRAL CIRCLE-25, NEW DELHI

In the result, the all appeals of the assessee are allowed and all the appeals of the Revenue are dismissed

Bench: Dr. B. R. R. Kumar, Sh. Sudhir Kumar

36. The AO has quoted bank statement of the supplier with respect to the above observation. ITA Nos. 2844 to 2846/Del/2022 Mahavir Transmission Ltd. i. It is evident from the bank statement reproduced by the AO himself that the assessee has made purchases through banking channels only which have also been duly received by these suppliers. ii. There

BSC C&C JOINT VENTURE,NEW DELHI vs. DCIT CIRCLE-61(1),, NEW DELHI

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

Bench: Shri M Balaganesh & Ms. Astha Chandraasstt. Year: 2017-18

36(1)(va) Rs. 1,42,72,897/- r.w.s. 2(24)(x) Total Assessed Income Rs. 45,93,89,452/- 3.2 The claim of deduction under section 80IA(4) was denied and taken as ‘NIL’. Accordingly, the final assessment was completed on 29.07.2022 by the Ld. AO under section 143(3)/ 92CA/ 144C(13) of the Act. 4. Aggrieved thereby

THE COMMISSIONER OF INCOME TAX vs. M.S.AGGARWAL

Xii) of the Gift Tax Act. The conditions laid down there are there should be transfer by one person to another of any existing movable or immovable property, the transfer should be voluntary and should be made without consideration of any money.‖ 39. At this stage, we may also refer to the observations of the Delhi High Court

BSC C&C JOINT VENTURE,NEW DELHI vs. DCIT, CIRCLE-61(1), NEW DELHI

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

Bench: SHRI G.S. PANNU (Vice President), SHRI ANUBHAV SHARMA (Judicial Member)

36(1)(va) r.w.s. 1,08,85,080/- 2(24)(x), as discussed in para 2.5.4 Less Disallowance of deduction claimed NIL u/s. 80IA as discussed in para 2.5.5 Total assessed income Rs. 49,81,91,872/- 4.3 The claim of deduction under section 80IA(4) was denied and taken as ‘NIL’. Accordingly, the final assessment was completed

JINDAL STEEL & POWER LIMITED vs. ADDL. CIT,

In the result, the appeal filed by the Revenue for the Assessment Year 2008-09 is dismissed

Bench: Shri Amit Shukla & Dr. B.R.R. Kumar(Through Video Conferencing)

xii) Creation of special facilities, 100% Export Oriented Units. xiii) Encourage investment by Non-Resident Indians. xiv) Encourage the establishment of industries in 14 ITA. No. 167/Del/2009 & 7 ors. the “thrust Sector” and formation of special schemes. xv) Encorage private sector participation in infrastructure development. xvi) Encourage Cooperative sector for industrial development. xvii) Facilitate commercial activity, so that commerce

ACIT, HISAR vs. M/S JINDAL STEEL & POWER LTD., HISAR

In the result, the appeal filed by the Revenue for the Assessment Year 2008-09 is dismissed

Bench: Shri Amit Shukla & Dr. B.R.R. Kumar(Through Video Conferencing)

xii) Creation of special facilities, 100% Export Oriented Units. xiii) Encourage investment by Non-Resident Indians. xiv) Encourage the establishment of industries in 14 ITA. No. 167/Del/2009 & 7 ors. the “thrust Sector” and formation of special schemes. xv) Encorage private sector participation in infrastructure development. xvi) Encourage Cooperative sector for industrial development. xvii) Facilitate commercial activity, so that commerce