ASSOCIATED MACHINERY CORP. PVT. LTD.,GHAZIABAD vs. ITO, GHAZIABAD

In the result, the appeal of the Assessee is dismissed

Bench: Shri Pradip Kumar Kedia & Shri Narender Kumar Choudhry

24)(x) read with section 36(1)(va) iii) Deemed dividend u/s 2(22)(e) 5,12,200/- iv) Bogus creditors 12,97,079/- v) Surrender on account of unverifiable creditors 100,00,000/- 4. On the aforesaid additions, penalty proceedings u/s 271

RAJESH KUMAR,GURGAON vs. ITO, WARD- 3(4), GURGAON

In the result, ITA No.1108/Del/2016 is partly allowed and ITA

Bench: Shri Shamim Yahya & Ms. Astha Chandra[Assessment Year: 2011-12]

24; return dated 16.02.2010 for AY 2009-10 at PB 25; return dated 23.03.2011 for AY 2010-11 at PB 26; return dated 28.03.2012 for AY 2011-12 which is the subject Assessment Year at PB 09). Each return has been filed with the same address as above. For AY 2009-10 there was a scrutiny assessment which

SHRI RAJESH KUMAR,GURGAON vs. ITO, GURGAON

In the result, ITA No.1108/Del/2016 is partly allowed and ITA

Bench: Shri Shamim Yahya & Ms. Astha Chandra[Assessment Year: 2011-12]

24; return dated 16.02.2010 for AY 2009-10 at PB 25; return dated 23.03.2011 for AY 2010-11 at PB 26; return dated 28.03.2012 for AY 2011-12 which is the subject Assessment Year at PB 09). Each return has been filed with the same address as above. For AY 2009-10 there was a scrutiny assessment which

RAKESH KUMAR GUPTA,DELHI vs. LD. ITO, WARD 35(1), DELHI, DELHI

In the result, the appeal of the assessee is allowed

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla, Accountnat Member [Assessment Year: 2021-22] Rakesh Kumar Gupta, Income Tax Officer, Ward-35(1), B-2/38, Ground Floor, E-2, Civic Centre, Delhi-110002 Ashok Vihar, Phase-Ii, Vs Delhi-110052 Pan-Aafhr8657H Appellant Respondent

271- AAB. (7) The penalty referred to in sub-section (1) shall be a sum equal to fifty per cent of the amount of tax payable on under-reported income. (8) Notwithstanding anything contained in sub-section (6) or subsection (7), where under-reported income is in consequence of any misreporting thereof by any person, the penalty referred

RIVET ELECTRICAL PVT LTD,FARIDABAD vs. PR. CIT, FARIDABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Kul Bharat & Shri Pradip Kumar Kedia[Assessment Year : 2014-15] Rivet Electrical Pvt.Ltd., Vs Pr.Cit, Ff-9, Vishnu Place, Faridabad, Near Neelam Flyover, Sec-20B, Haryana. Faridabad, Haryana-121002. Pan-Aafcr8803C Appellant Respondent Appellant By Shri Rajeev Saxena, Adv., Ms. Sumangl Saxena, Adv. & Shri Sahyamsunder, Adv. Respondent By Shri Anuj Garg, Sr.Dr Date Of Hearing 12.10.2022 Date Of Pronouncement 15.11.2022

penalty or fine has been incurred by the assessee. At point 37, no payment by way of commission or brokerage has been made during the year. At point 38, details regarding the expenses on which TDS is required to be deducted has been provided. At point 39, details regarding foreign transactions have been provided. At point 40, it is submitted

POTENT FOODS PRIVATE LIMTED,FARIDABAD vs. ITO WARD-2(1), FARIDABAD

In the result, appeal of the Assessee is allowed

Bench: Shri R.K. Panda

penalty proceedings u/s 271(l)(c) are being initiated for furnishing inaccurate particulars of the income on the above account. Accordingly, notice u/s 274 read with section 271(l)(c) of the Act, is being issued separately to the appellant. The AO is directed to give appeal effect on this account and issue demand notice u/s

SHERVANI HOSPITALITIES LTD. vs. COMMISSIONER OF INCOME TAX

The appeal is disposed of

2 are noticed below. The net loss of the assessee was determined at Rs.4,57,726/-, vide second appeal effect order dated 17th July, 2008 passed under Sections 254/250 of the Act. 5. Proceedings under Section 271(1)(c) of the Act were initiated and vide order dated 29th January, 2009, penalty of Rs.16,44,330/- was imposed inter-alia

ANMOL ARORA,DELHI vs. DCIT CENTRAL CIRCLE-15, NEW DELHI

In the result, this appeal filed by the assessee stands allowed

Bench: Shri Shamim Yahya & Shri N. K. Choudhry[Assessment Year: 2015-16]

24,915/- and which is against the facts and circumstances of the case. 2. That the Ld. CIT (A) has failed to appreciate the fact that no specific charge either for concealment of income or furnishing of inaccurate particulars of income have been framed before levying the penalty u/s 271(1)(c). 3. That no proper satisfaction has been recorded

ABHIRVEY PROJECTS PRIVATE LIMITED,NEW DELHI vs. ACIT CIRCLE-1(2), NEW DELHI

In the result, the appeal of the assessee is allowed

Bench: Shri Challa Nagendra Prasad & Shri Pradip Kumar Kedia

X Rs. 40.40 (diff. of Rs. 50 and Rs. 9.60). The disallowance u/s 56(2)(viib) of the Income Tax Act of Rs. 1,27,26,000/-. 4. Appeal preferred to the Ld. CIT(A) was dismissed by way of impugned order. Hence, the assessee is before in this appeal stating that the AO is not justified in rejecting

GENCHI INDIA PRIVATE LIMITED,CHENNAI vs. THE ACIT, CIRCLE 10(1), NEW DELHI, NEW DELHI

In the result, the appeal of the assessee is allowed

Bench: Shri Satbeer Singh Godara & Shri S.Rifaur Rahman

2(24)(x) of the Rs.17,14,158/- I.T. Act. 4. The penalty proceedings were initiated u/s 271(1)(c) by issuing notice u/s 274 of the Act on 15.12.2018 after being satisfied that the assessee had furnished in accurate particulars of its income. During penalty proceedings, Assessing Officer observed that during the year under consideration, the assessee company claimed

SRF LTD.,NEW DELHI vs. ACIT, NEW DELHI

In the result, the appeal being ITA No

Bench: Shris.Rifaur Rahman & Shri Sudhir Pareek

2. Interest subsidy under Technology Upgradation Fund (TUF) Scheme: 23. During the year, Assessee had obtained loan of Rs. 6,250 Lacs from SBI and Rs. 3,500 Lacs from State Bank of Mysore under TUF Scheme issued by the ministry of textile, Government of India. Whether the Loan was utilized as per the scheme is not under question. Under

SRF LIMITED,NEW DELHI vs. DCIT, CIRCLE- 1, LTU, NEW DELHI

In the result, the appeal being ITA No

Bench: Shris.Rifaur Rahman & Shri Sudhir Pareek

2. Interest subsidy under Technology Upgradation Fund (TUF) Scheme: 23. During the year, Assessee had obtained loan of Rs. 6,250 Lacs from SBI and Rs. 3,500 Lacs from State Bank of Mysore under TUF Scheme issued by the ministry of textile, Government of India. Whether the Loan was utilized as per the scheme is not under question. Under

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.

24 conscious of the fact that the said agreement was entered into only on 13.01.2021, which is evident from the noting in the assessment order at various places. However, despite being aware of the non- applicability of the Global Agreement to the subject assessment year, the assessing officer recorded adverse findings and concluded that LM India constituted Fixed Place

PUSHPA RANI,DELHI vs. ACIT CENTRAL CIRCLE-9, DELHI

In the result, the appeal of the assessee is dismissed

Bench: Shri Kul Bharat & Shri Pradip Kumar Kedia

X, Part- II, New Delhi on franchise basis and she was also earning rent of Rs.33,619/- per month. The AO further noted that the assessee did not submit any supporting evidences therefore, he estimated the income from play school at Rs.7,50,000/-, rent received of Rs.4,00,000/- and interest income of Rs.3,25,000/-. Thus

PUSHPA RANI,DELHI vs. ACIT CENTRAL CIRCLE-9, DELHI

In the result, the appeal of the assessee is dismissed

Bench: Shri Kul Bharat & Shri Pradip Kumar Kedia

X, Part- II, New Delhi on franchise basis and she was also earning rent of Rs.33,619/- per month. The AO further noted that the assessee did not submit any supporting evidences therefore, he estimated the income from play school at Rs.7,50,000/-, rent received of Rs.4,00,000/- and interest income of Rs.3,25,000/-. Thus

PUSHPA RANI,DELHI vs. ACIT CENTRAL CIRCLE-9, DELHI

In the result, the appeal of the assessee is dismissed

Bench: Shri Kul Bharat & Shri Pradip Kumar Kedia

X, Part- II, New Delhi on franchise basis and she was also earning rent of Rs.33,619/- per month. The AO further noted that the assessee did not submit any supporting evidences therefore, he estimated the income from play school at Rs.7,50,000/-, rent received of Rs.4,00,000/- and interest income of Rs.3,25,000/-. Thus

PUSHPA RANI,DELHI vs. ACIT CENTRAL CIRCLE-9, DELHI

In the result, the appeal of the assessee is dismissed

Bench: Shri Kul Bharat & Shri Pradip Kumar Kedia

X, Part- II, New Delhi on franchise basis and she was also earning rent of Rs.33,619/- per month. The AO further noted that the assessee did not submit any supporting evidences therefore, he estimated the income from play school at Rs.7,50,000/-, rent received of Rs.4,00,000/- and interest income of Rs.3,25,000/-. Thus

PUSHPA RANI,DELHI vs. ACIT CENTRAL CIRCLE-9, DELHI

In the result, the appeal of the assessee is dismissed

Bench: Shri Kul Bharat & Shri Pradip Kumar Kedia

X, Part- II, New Delhi on franchise basis and she was also earning rent of Rs.33,619/- per month. The AO further noted that the assessee did not submit any supporting evidences therefore, he estimated the income from play school at Rs.7,50,000/-, rent received of Rs.4,00,000/- and interest income of Rs.3,25,000/-. Thus