SH. VALMIK THAPAR,NEW DELHI vs. ACIT, NEW DELHI

Appeals are disposed of by this common order as indicated above

Bench: Hon’Ble Justice P.P. Bhatt & Shri Prashant Maharishi(Through Video Conferencing) Shri Valmik Thapar, Vs. Acit, 19, Kautilya Marg, Circle-53(1), New Delhi New Delhi (Appellant) (Respondent) Shri Valmik Thapar, Vs. Dcit, M/S. R. N. Khanna & Company, Ca, Circle-32(1), 14-15F, Shivam House, Connaught New Delhi Place, New Delhi Pan: Aacpt7098K (Appellant) (Respondent) Acit, Vs. Shri Valmik Thapar, Circle-53(1), 19, Kautilya Marg, New Delhi New Delhi Pan: Aacpt7098K (Appellant) (Respondent) Assessee By : Shri Salil Agarwal, Senior Advocate Along With Shri Shailesh Gupta, Shri Mahur Agarwal, Advocates Revenue By: Shri H. K. Choudhary, Cit Dr Date Of Hearing 11/06/2021 (Last Hearing) Date Of Pronouncement 11/06/2021. O R D E R Per Prashant Maharishi, A. M. 1. These Are Three Appeals For Two Assessment Years Pertaining To One Assessee, Mr. Valmik Thapar, A Resident, Individual [Assessee]. Assessee Filed Ita Number

41. With respect to the ground number [2] of the appeal, he submitted that under the provisions of Section 54 (1) of the act the assessee is only entitled to the deduction of one residential house property

ACIT, NEW DELHI vs. SH. VALMIK THAPAR, NEW DELHI

Appeals are disposed of by this common order as indicated above

Bench: Hon’Ble Justice P.P. Bhatt & Shri Prashant Maharishi(Through Video Conferencing) Shri Valmik Thapar, Vs. Acit, 19, Kautilya Marg, Circle-53(1), New Delhi New Delhi (Appellant) (Respondent) Shri Valmik Thapar, Vs. Dcit, M/S. R. N. Khanna & Company, Ca, Circle-32(1), 14-15F, Shivam House, Connaught New Delhi Place, New Delhi Pan: Aacpt7098K (Appellant) (Respondent) Acit, Vs. Shri Valmik Thapar, Circle-53(1), 19, Kautilya Marg, New Delhi New Delhi Pan: Aacpt7098K (Appellant) (Respondent) Assessee By : Shri Salil Agarwal, Senior Advocate Along With Shri Shailesh Gupta, Shri Mahur Agarwal, Advocates Revenue By: Shri H. K. Choudhary, Cit Dr Date Of Hearing 11/06/2021 (Last Hearing) Date Of Pronouncement 11/06/2021. O R D E R Per Prashant Maharishi, A. M. 1. These Are Three Appeals For Two Assessment Years Pertaining To One Assessee, Mr. Valmik Thapar, A Resident, Individual [Assessee]. Assessee Filed Ita Number

41. With respect to the ground number [2] of the appeal, he submitted that under the provisions of Section 54 (1) of the act the assessee is only entitled to the deduction of one residential house property

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

1,28,73,670/- derived from 'Non Eligible Business' of the assessee as 'Income from Other Sources' against 'Income from House Property claimed by the assessee and thereby denying deduction u/s 24(a) of the Act. 5.1 That the Ld CIT (A), erred in upholding the issue regarding 'Signage Income, to be assessed as 'Income from Other Sources', without distinguishing

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

1,28,73,670/- derived from 'Non Eligible Business' of the assessee as 'Income from Other Sources' against 'Income from House Property claimed by the assessee and thereby denying deduction u/s 24(a) of the Act. 5.1 That the Ld CIT (A), erred in upholding the issue regarding 'Signage Income, to be assessed as 'Income from Other Sources', without distinguishing

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

1,28,73,670/- derived from 'Non Eligible Business' of the assessee as 'Income from Other Sources' against 'Income from House Property claimed by the assessee and thereby denying deduction u/s 24(a) of the Act. 5.1 That the Ld CIT (A), erred in upholding the issue regarding 'Signage Income, to be assessed as 'Income from Other Sources', without distinguishing

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

1,28,73,670/- derived from 'Non Eligible Business' of the assessee as 'Income from Other Sources' against 'Income from House Property claimed by the assessee and thereby denying deduction u/s 24(a) of the Act. 5.1 That the Ld CIT (A), erred in upholding the issue regarding 'Signage Income, to be assessed as 'Income from Other Sources', without distinguishing

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

1,28,73,670/- derived from 'Non Eligible Business' of the assessee as 'Income from Other Sources' against 'Income from House Property claimed by the assessee and thereby denying deduction u/s 24(a) of the Act. 5.1 That the Ld CIT (A), erred in upholding the issue regarding 'Signage Income, to be assessed as 'Income from Other Sources', without distinguishing

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

1,28,73,670/- derived from 'Non Eligible Business' of the assessee as 'Income from Other Sources' against 'Income from House Property claimed by the assessee and thereby denying deduction u/s 24(a) of the Act. 5.1 That the Ld CIT (A), erred in upholding the issue regarding 'Signage Income, to be assessed as 'Income from Other Sources', without distinguishing

DY. COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-I NOIDA, NOIDA vs. M/S RUDRA BUILDWELL HOMES PVT. LTD., DELHI

Accordingly, all the grounds of appeal taken by Revenue are dismissed

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwaldy. Cit, M/S Rudra Buildwell Homes Central Circle-I, Private Limited, Noida-201301, Vs. D-53, Okhla, Phase-1, Uttar Pradesh. Delhi-110020. Pan-Aafcr6959P (Appellant) (Respondent) Dy. Cit, M/S Rudra Buildwell Projects Central Circle-I, Private Limited, Noida-201301, Vs. D-53, Okhla, Phase-1, Uttar Pradesh. Delhi-110020. Pan-Aaecr9589E (Appellant) (Respondent)

properties, including the project known as "Aqua Casa", along with corporate guarantees and pledges, thereby creating an enforceable security interest in favor of the lender. That as per the terms of the Facility Agreement, the repayment obligation in respect of the principal amount was to commence only after the expiry of 24 months from the respective dates of disbursement. That

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

A2Z INFRA ENGINEERING LIMITED,GURGAON vs. DCIT- CENTRAL CIRCLE-2, FARIDABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Pradip Kumar Kedia & Shri Anubhav Sharma

property for which rent of Rs. 6,60,000/- was in fact used as a guest house for the company during the year under consideration and the addition was confirmed by the CIT(A). As the appellant had furnished inaccurate particulars regarding the same, penalty w/s 271(1)(c) of the Act on this addition has been imposed

A2Z INFRA ENGINEERING LIMITED,GURGAON vs. DCIT- CENTRAL CIRCLE-2, FARIDABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Pradip Kumar Kedia & Shri Anubhav Sharma

property for which rent of Rs. 6,60,000/- was in fact used as a guest house for the company during the year under consideration and the addition was confirmed by the CIT(A). As the appellant had furnished inaccurate particulars regarding the same, penalty w/s 271(1)(c) of the Act on this addition has been imposed

A2Z INFRA ENGINEERING LIMITED,GURGAON vs. DCIT CC-2 , FARIDABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Pradip Kumar Kedia & Shri Anubhav Sharma

property for which rent of Rs. 6,60,000/- was in fact used as a guest house for the company during the year under consideration and the addition was confirmed by the CIT(A). As the appellant had furnished inaccurate particulars regarding the same, penalty w/s 271(1)(c) of the Act on this addition has been imposed

A2Z INFRA ENGINEERING LIMITED,GURGAON vs. CCIT- CENTRAL CIRCLE-2, FARIDABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Pradip Kumar Kedia & Shri Anubhav Sharma

property for which rent of Rs. 6,60,000/- was in fact used as a guest house for the company during the year under consideration and the addition was confirmed by the CIT(A). As the appellant had furnished inaccurate particulars regarding the same, penalty w/s 271(1)(c) of the Act on this addition has been imposed

A2Z MAINTENANCE & ENGINEERING SERVICES LTD.,GURGAON vs. DCIT, CENTRAL CIRCLE-II, FARIDABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Pradip Kumar Kedia & Shri Anubhav Sharma

property for which rent of Rs. 6,60,000/- was in fact used as a guest house for the company during the year under consideration and the addition was confirmed by the CIT(A). As the appellant had furnished inaccurate particulars regarding the same, penalty w/s 271(1)(c) of the Act on this addition has been imposed

DCIT CC-2 , FARIDABAD vs. A2Z MAINTENANCE AND ENGINEERING SERVICES LTD., GURGAON

In the result, the appeal of the assessee is allowed

Bench: Shri Pradip Kumar Kedia & Shri Anubhav Sharma

property for which rent of Rs. 6,60,000/- was in fact used as a guest house for the company during the year under consideration and the addition was confirmed by the CIT(A). As the appellant had furnished inaccurate particulars regarding the same, penalty w/s 271(1)(c) of the Act on this addition has been imposed

DCIT-CENTRAL CIRCLE-2, FARIDABAD vs. A2Z INFRA ENGINEERS LTD., GURGAON

In the result, the appeal of the assessee is allowed

Bench: Shri Pradip Kumar Kedia & Shri Anubhav Sharma

property for which rent of Rs. 6,60,000/- was in fact used as a guest house for the company during the year under consideration and the addition was confirmed by the CIT(A). As the appellant had furnished inaccurate particulars regarding the same, penalty w/s 271(1)(c) of the Act on this addition has been imposed

INFRA ENGINEERS LTD.,GURGAON vs. DCIT, CC-2, FARIDABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Pradip Kumar Kedia & Shri Anubhav Sharma

property for which rent of Rs. 6,60,000/- was in fact used as a guest house for the company during the year under consideration and the addition was confirmed by the CIT(A). As the appellant had furnished inaccurate particulars regarding the same, penalty w/s 271(1)(c) of the Act on this addition has been imposed

(Now known as Sony India Limited)

41 of 142 expenses in India. This is an undisputed position. The arm‘s length determination pertains to adequate compensation to the Indian AE for incurring and performing the functions by the domestic AE. The dispute pertains to adequacy of compensation for incurring and performing marketing and ‗non- routine‘ AMP expenses in India by the AE. The expenses incurred