JAR METAL INDUSTRIES(P) LTD.,DELHI vs. ITO WARD-13(2), NEW DELHI

The appeal is allowed

business activities and the assessee having no asset to\ndisposes. So in present circumstance of the assessee, we request\nyour good self kindly do not impose any penalty u/s 271(1)(c) of\nthe Income

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

penalty u/s 271(1)(c) of the Act on this disallowance. 5.3.3 In the case of DCIT v/s Shree Ram Electrocast (P) Ltd [2017] 84 taxmann.com 63 (Kolkata-Trib), Hon'ble ITAT has held that merely because losses were not allowed to be set off against normal business income

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

penalty u/s 271(1)(c) of the Act on this disallowance. 5.3.3 In the case of DCIT v/s Shree Ram Electrocast (P) Ltd [2017] 84 taxmann.com 63 (Kolkata-Trib), Hon'ble ITAT has held that merely because losses were not allowed to be set off against normal business income

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

penalty u/s 271(1)(c) of the Act on this disallowance. 5.3.3 In the case of DCIT v/s Shree Ram Electrocast (P) Ltd [2017] 84 taxmann.com 63 (Kolkata-Trib), Hon'ble ITAT has held that merely because losses were not allowed to be set off against normal business income

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

penalty u/s 271(1)(c) of the Act on this disallowance. 5.3.3 In the case of DCIT v/s Shree Ram Electrocast (P) Ltd [2017] 84 taxmann.com 63 (Kolkata-Trib), Hon'ble ITAT has held that merely because losses were not allowed to be set off against normal business income

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

penalty u/s 271(1)(c) of the Act on this disallowance. 5.3.3 In the case of DCIT v/s Shree Ram Electrocast (P) Ltd [2017] 84 taxmann.com 63 (Kolkata-Trib), Hon'ble ITAT has held that merely because losses were not allowed to be set off against normal business income

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

penalty u/s 271(1)(c) of the Act on this disallowance. 5.3.3 In the case of DCIT v/s Shree Ram Electrocast (P) Ltd [2017] 84 taxmann.com 63 (Kolkata-Trib), Hon'ble ITAT has held that merely because losses were not allowed to be set off against normal business income

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

penalty u/s 271(1)(c) of the Act on this disallowance. 5.3.3 In the case of DCIT v/s Shree Ram Electrocast (P) Ltd [2017] 84 taxmann.com 63 (Kolkata-Trib), Hon'ble ITAT has held that merely because losses were not allowed to be set off against normal business income

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

penalty u/s 271(1)(c) of the Act on this disallowance. 5.3.3 In the case of DCIT v/s Shree Ram Electrocast (P) Ltd [2017] 84 taxmann.com 63 (Kolkata-Trib), Hon'ble ITAT has held that merely because losses were not allowed to be set off against normal business income

ADDL. CIT, NEW DELHI vs. M/S. PHI SEEDS PVT. LTD., HYDERABAD

The appeals of the Revenue are dismissed and both the Rule 27 application of the assessee are allowed for A

Bench: Shri Mahavir Singh & Shri Brajesh Kumar Singh

business income (relevant paras are 4 and 31-35 of the assessment order). Further, an amount of Rs. 4,76,13,799/- was added on account of ‘Revaluation of closing stock’. (relevant paras are 37 and 38 of the assessment order). On account of these disallowances, the A.O. initiated penalty proceedings for furnishing inaccurate particulars of income under section 271

ADDL. CIT, NEW DELHI vs. M/S. PHI SEEDS PVT. LTD., HYDERABAD

The appeals of the Revenue are dismissed and both the Rule 27 application of the assessee are allowed for A

Bench: Shri Mahavir Singh & Shri Brajesh Kumar Singh

business income (relevant paras are 4 and 31-35 of the assessment order). Further, an amount of Rs. 4,76,13,799/- was added on account of ‘Revaluation of closing stock’. (relevant paras are 37 and 38 of the assessment order). On account of these disallowances, the A.O. initiated penalty proceedings for furnishing inaccurate particulars of income under section 271

JAINA MARKETING & ASSOCIATES,DELHI vs. DCIT, CENTRAL CIRCLE-18, DELHI

Accordingly, Appeals filed by the assessee are allowed

Bench: Shri M. Balaganesh & Shri Yogesh Kumar U.S.

business and residential premises of Jain Group of case based at Delhi and other places. As a consequence of the above search, assessment orders have been passed u/s 153A/143(3) of the Act by making various additions in Assessment Year 2017-18 to 2019-20. Pursuant to the assessment orders three penalty orders u/s 271(1)(c)/271A and 271AAB

JAINA MARKETING & ASSOCIATES,DELHI vs. DCIT, CENTRAL CIRCLE-18, DELHI

Accordingly, Appeals filed by the assessee are allowed

Bench: Shri M. Balaganesh & Shri Yogesh Kumar U.S.

business and residential premises of Jain Group of case based at Delhi and other places. As a consequence of the above search, assessment orders have been passed u/s 153A/143(3) of the Act by making various additions in Assessment Year 2017-18 to 2019-20. Pursuant to the assessment orders three penalty orders u/s 271(1)(c)/271A and 271AAB

JAINA MARKETING & ASSOCIATES,DELHI vs. DCIT, CENTRAL CIRCLE-18, DELHI

Accordingly, Appeals filed by the assessee are allowed

Bench: Shri M. Balaganesh & Shri Yogesh Kumar U.S.

business and residential premises of Jain Group of case based at Delhi and other places. As a consequence of the above search, assessment orders have been passed u/s 153A/143(3) of the Act by making various additions in Assessment Year 2017-18 to 2019-20. Pursuant to the assessment orders three penalty orders u/s 271(1)(c)/271A and 271AAB

DCIT, CIRCLE-3(1)(1), INT. TAXATION, NEW DELHI vs. RAYTHEON COMPANY, UNITED STATES

In the result, all the appeals of the Revenue for the

Bench: Shri Challa Nagendra Prasad & Shri M Balaganeshआ.अ.सं/.I.T.A Nos.1383 To 1392/Del/2023 िनधा"रणवष"/Assessment Yeasrs:2004-05 To 2006-07, 2008-09 To 2011-12 & 2014-15 To 2016-17 बनाम Dcit, Raytheon Company Circle 3(1)(1), Vs. 870, Winter Steet, Int. Taxation, Waltham-Ma 02451, Room No. 416, Foreign Usa, 4Th Floor, E-2 Block, Usa. Dr. S.P. Mukherjee Civic Centre, J.L. Nehru Marg, New Delhi. Pan No. Aadcr3511P अपीलाथ" Appellant ""यथ"/Respondent & आ.अ.सं/.I.T.A No.441/Del/2023 िनधा"रणवष"/Assessment Year:2007-08 बनाम Acit, Raytheon Company Circle 3(1)(1), Vs. C/O Srbc & Associates Int. Taxation, Llp, Golf View Corporate Room No. 416, Tower-B, Sector-42, 4Th Floor, E-2 Block, Sector Road, Gurgaon, Dr. S.P. Mukherjee Civic Centre, Haryana. J.L. Nehru Marg, New Delhi. Pan No. Aadcr3511P अपीलाथ" Appellant ""यथ"/Respondent

penalty u/s 271(1)(c) of the Act. 4. Heard rival submissions, perused the orders of the authorities below. 5. We observe that the assessee in all these assessment years filed returns declaring NIL income. The assessments were completed by the AO treating the amounts received by the assessee for report maintenance support services, supply of spares, supply of hardware

DCIT, CIRCLE-3(1)(1), INT. TAXATION, NEW DELHI vs. RAYTHEON COMPANY, UNITED STATES

In the result, all the appeals of the Revenue for the

Bench: Shri Challa Nagendra Prasad & Shri M Balaganeshआ.अ.सं/.I.T.A Nos.1383 To 1392/Del/2023 िनधा"रणवष"/Assessment Yeasrs:2004-05 To 2006-07, 2008-09 To 2011-12 & 2014-15 To 2016-17 बनाम Dcit, Raytheon Company Circle 3(1)(1), Vs. 870, Winter Steet, Int. Taxation, Waltham-Ma 02451, Room No. 416, Foreign Usa, 4Th Floor, E-2 Block, Usa. Dr. S.P. Mukherjee Civic Centre, J.L. Nehru Marg, New Delhi. Pan No. Aadcr3511P अपीलाथ" Appellant ""यथ"/Respondent & आ.अ.सं/.I.T.A No.441/Del/2023 िनधा"रणवष"/Assessment Year:2007-08 बनाम Acit, Raytheon Company Circle 3(1)(1), Vs. C/O Srbc & Associates Int. Taxation, Llp, Golf View Corporate Room No. 416, Tower-B, Sector-42, 4Th Floor, E-2 Block, Sector Road, Gurgaon, Dr. S.P. Mukherjee Civic Centre, Haryana. J.L. Nehru Marg, New Delhi. Pan No. Aadcr3511P अपीलाथ" Appellant ""यथ"/Respondent

penalty u/s 271(1)(c) of the Act. 4. Heard rival submissions, perused the orders of the authorities below. 5. We observe that the assessee in all these assessment years filed returns declaring NIL income. The assessments were completed by the AO treating the amounts received by the assessee for report maintenance support services, supply of spares, supply of hardware

DCIT, CIRCLE 3(1)(1), INTERNATIONAL TAXATION, NEW DELHI vs. RAYTHEON COMPANY, UNITED STATE

In the result, all the appeals of the Revenue for the

Bench: Shri Challa Nagendra Prasad & Shri M Balaganeshआ.अ.सं/.I.T.A Nos.1383 To 1392/Del/2023 िनधा"रणवष"/Assessment Yeasrs:2004-05 To 2006-07, 2008-09 To 2011-12 & 2014-15 To 2016-17 बनाम Dcit, Raytheon Company Circle 3(1)(1), Vs. 870, Winter Steet, Int. Taxation, Waltham-Ma 02451, Room No. 416, Foreign Usa, 4Th Floor, E-2 Block, Usa. Dr. S.P. Mukherjee Civic Centre, J.L. Nehru Marg, New Delhi. Pan No. Aadcr3511P अपीलाथ" Appellant ""यथ"/Respondent & आ.अ.सं/.I.T.A No.441/Del/2023 िनधा"रणवष"/Assessment Year:2007-08 बनाम Acit, Raytheon Company Circle 3(1)(1), Vs. C/O Srbc & Associates Int. Taxation, Llp, Golf View Corporate Room No. 416, Tower-B, Sector-42, 4Th Floor, E-2 Block, Sector Road, Gurgaon, Dr. S.P. Mukherjee Civic Centre, Haryana. J.L. Nehru Marg, New Delhi. Pan No. Aadcr3511P अपीलाथ" Appellant ""यथ"/Respondent

penalty u/s 271(1)(c) of the Act. 4. Heard rival submissions, perused the orders of the authorities below. 5. We observe that the assessee in all these assessment years filed returns declaring NIL income. The assessments were completed by the AO treating the amounts received by the assessee for report maintenance support services, supply of spares, supply of hardware

DCIT, CIRCLE-3(1)(1) INT. TAXATION, NEW DELHI vs. RAYTHEON COMPANY, UNITED STATES

In the result, all the appeals of the Revenue for the

Bench: Shri Challa Nagendra Prasad & Shri M Balaganeshआ.अ.सं/.I.T.A Nos.1383 To 1392/Del/2023 िनधा"रणवष"/Assessment Yeasrs:2004-05 To 2006-07, 2008-09 To 2011-12 & 2014-15 To 2016-17 बनाम Dcit, Raytheon Company Circle 3(1)(1), Vs. 870, Winter Steet, Int. Taxation, Waltham-Ma 02451, Room No. 416, Foreign Usa, 4Th Floor, E-2 Block, Usa. Dr. S.P. Mukherjee Civic Centre, J.L. Nehru Marg, New Delhi. Pan No. Aadcr3511P अपीलाथ" Appellant ""यथ"/Respondent & आ.अ.सं/.I.T.A No.441/Del/2023 िनधा"रणवष"/Assessment Year:2007-08 बनाम Acit, Raytheon Company Circle 3(1)(1), Vs. C/O Srbc & Associates Int. Taxation, Llp, Golf View Corporate Room No. 416, Tower-B, Sector-42, 4Th Floor, E-2 Block, Sector Road, Gurgaon, Dr. S.P. Mukherjee Civic Centre, Haryana. J.L. Nehru Marg, New Delhi. Pan No. Aadcr3511P अपीलाथ" Appellant ""यथ"/Respondent

penalty u/s 271(1)(c) of the Act. 4. Heard rival submissions, perused the orders of the authorities below. 5. We observe that the assessee in all these assessment years filed returns declaring NIL income. The assessments were completed by the AO treating the amounts received by the assessee for report maintenance support services, supply of spares, supply of hardware