ARGOS HOLDINGS PTE. LTD.,SINGAPORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE INT TAX 1(1)(1), DELHI, DELHI

In the result, appeal filed by the assessee is partly allowed

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.

reassessment proceedings, initiated on the basis of such notices, are legally unsustainable and devoid of jurisdiction. III. Foreign Portfolio Investor Status; Withholding under Section 194LD; Exemption from Return Filing under Section 115A

KISAN INTERNATIONAL TRADING FZE,NEW DELHI vs. ACIT, INT. TAX 2(1)(2), DELHI

In the result, the appeal field by the assessee is allowed

Bench: Shris.Rifaur Rahman & Shri Yogesh Kumar U.S.Kisan International Trading Fze, Vs. Acit, Circle C/O Shri Tarandeep Singh, Advocate Int. Tax 2(1)(2), C – 179, Mansarover Garden, Delhi. New Delhi – 110 015. (Pan :Aaeck0424D) (Appellant) (Respondent) Assessee By : Shri Tarandeep Singh, Advocate Shri Sandeep Yadav, Advocate Revenue By : Shri Vikram Singh Sharma, Sr. Dr Date Of Hearing : 21.08.2025 Date Of Order : 19.11.2025 Order Per S. Rifaur Rahman: 1. The Assessee Has Filed Appeal Against The Order Of The Learned Commissioner Of Income-Tax (Appeals), Delhi – 43 [“Ld. Cit(A)”, For Short] Dated 06.12.2024 For The Assessment Year 2012-13 Raising Following Grounds Of Appeal :- “1. That On Facts & In Law The Order Dated 06Th December 2024 Passed By The Commissioner Of Income Tax (Appeals) (Hereinafter Referred To As The "Cit(A)'} & Order Dated 23Rd December 2019 Passed By The Assessing Officer (Hereinafter Referred To As The "Ao") Are Bad In Law & Void Ab Initio.

reassess invoking provisions of section 147. He submitted that notice u/s 148 has not been served upon the assessee. It was further submitted that as per provisions of section 115A

COMPUTER MODELLING GROUP LIMITED,CANADA vs. ACIT, CIRCLE-1(2)(1), INT. TAXATION, NEW DELHI

In the result, all the four appeals of the assessee for AY 2012-13,

Bench: Shri G.S. Pannu, Hon’Ble & Ms. Astha Chandra

reassessment proceedings under sections 147/148 of the Act as valid. 5.2 On the issue of addition, the Ld. CIT (A) concurred with the directions dated 19.04.2023 of the Ld. DRP in respect of similar addition made in AY 2019-20 and 2020-21 wherein the decision of Hon'ble Supreme Court in the case of ONGC

COMPUTER MODELLING GROUP LIMITED,CANADA vs. DCIT CIRCLE INTERNATIONAL TAXATION 1(2)(1), NEW DELHI

In the result, all the four appeals of the assessee for AY 2012-13,

Bench: Shri G.S. Pannu, Hon’Ble & Ms. Astha Chandra

reassessment proceedings under sections 147/148 of the Act as valid. 5.2 On the issue of addition, the Ld. CIT (A) concurred with the directions dated 19.04.2023 of the Ld. DRP in respect of similar addition made in AY 2019-20 and 2020-21 wherein the decision of Hon'ble Supreme Court in the case of ONGC

COMPUTER MODELLING GROUP LIMITED,CANADA vs. ACIT INTERNATIONAL TAXATION CIRCLE 1(2)(1), NEW DELHI

In the result, all the four appeals of the assessee for AY 2012-13,

Bench: Shri G.S. Pannu, Hon’Ble & Ms. Astha Chandra

reassessment proceedings under sections 147/148 of the Act as valid. 5.2 On the issue of addition, the Ld. CIT (A) concurred with the directions dated 19.04.2023 of the Ld. DRP in respect of similar addition made in AY 2019-20 and 2020-21 wherein the decision of Hon'ble Supreme Court in the case of ONGC

DIRECTOR OF INCOME TAX vs. MC DONALDS CORPORATION

The appeals are dismissed

reassessment proceedings were completed on 28.05.2007. This time the income was held to be taxable in terms of section 115A

HISTORIC TBS ASIA LLC,NEW DELHI vs. DEPUTY COMMISSIONER OF INCOME-TAX, NEW DELHI

In the result, the appeal of the assessee in ITA No

Bench: Shri N.K. Billaiya & Shri Anubhav Sharma

reassessment proceedings is not in consonance with the provisions of section 147 of the Act. 11. The contentions of the assessee were dismissed by the Assessing Officer who proceeded by computing the total assessed income at Rs. 5,09,05,644/-. 12. Objections of the assessee did not find any favour with the DRP. 13. We have carefully perused

TRANS WORLD INTERNATIONAL LLC,WILMINGTON, DELAWARE, USA vs. DEPUTY COMMISSIONER OF INCOME TA, CIRCLE 3(1)(1), INTERNATIONAL TAXATION, CIVIC CENTRE, NEAR MINTO ROAD, NEW DELHI

In the result, the appeal of the assessee is allowed

Bench: Shri Vikas Awasthy & Shri Brajesh Kumar Singh

reassessment order passed by the Ld. Deputy Commissioner of Income-tax, Circle 3()O), International Taxation, New Delhi (Ld. AO') under section 147 read with section 144C(13) of the Income Tax Act, 1961 (the Act), in pursuance to the directions of the Learned Dispute Resolution Panel - 2, New Delhi (Ld. DRP'), assessing the income of the Appellant

ACIT, NEW DELHI vs. VRINDA FARMS PRIVATE LIMITED, NEW DELHI

In the result, the appeal of the Revenue as well as cross objections of the assessee are dismissed

Bench: Shris.Rifaur Rahman & Shri Yogesh Kumar U.S.Acit, Central Circle 4, Vs. Vrinda Farms Private Limited, New Delhi. 43, Community Centre, Bhageria House, Zakir Nagar, New Friends Colony, New Delhi – 110 025. (Pan : Aaacv0355L) Co Nos.13 & 19/Del/2025 (In Ita No.4849/Del/2024) (Assessment Year: 2016-17) Vrinda Farms Private Limited, Vs. Acit, Central Circle 4, 43, Community Centre, New Delhi. Bhageria House, Zakir Nagar, New Friends Colony, New Delhi – 110 025. (Pan : Aaacv0355L) (Appellant) (Respondent) Assessee By : Shri Biren Shah, Ca Revenue By : Shri Dheeraj Kumar Jain, Sr. Dr Date Of Hearing : 02.09.2025 Date Of Order : 29.10.2025 Order Per S.Rifaur Rahman: 1. This Appeal Is Filed By The Revenue Against The Order Of Ld. Commissioner Of Income Tax (Appeals)-23, New Delhi [“Ld. Cit(A)”, For Short]

section 68 has been duly discharged by assessee by submitting the following documents before AO as well as CIT(A): 1 Copy of Confirmation of Accounts 2 Copy of Bank statements of Lender 3 Audited Financials of Lender 4 Copy of ITR Acknowledgement of Lenders 5 133(6) responses filed by Lenders  All these details have been filed creditor wise

TRANS WORLD INTERNATIONAL LLC,WILMINGTON, DELAWARE, USA vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 3(1)(1), INTERNATIONAL TAXATION, NEW DELHI

In the result, the appeal of the assessee is allowed

reassessment order passed by the Ld. Deputy\nCommissioner of Income-tax, Circle 3()O), International Taxation,\nNew Delhi (Ld. AO') under section 147 read with section\n144C(13) of the Income Tax Act, 1961 (the Act), in pursuance to\nthe directions of the Learned Dispute Resolution Panel - 2, New\nDelhi (Ld. DRP'), assessing the income of the Appellant

TRANS WORLD INTERNATIONAL LLC,DELAWARE, USA vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE (INTERNATIONAL TAXATION) - 3(1)(1), NEW DELHI

In the result, the appeal of the assessee is allowed

reassessment order passed by the Ld. Deputy\nCommissioner of Income-tax, Circle 3()O), International Taxation,\nNew Delhi (Ld. AO') under section 147 read with section\n144C(13) of the Income Tax Act, 1961 (the Act), in pursuance to\nthe directions of the Learned Dispute Resolution Panel - 2, New\nDelhi (Ld. DRP'), assessing the income of the Appellant

ACIT, NEW DELHI vs. FILATAX INIDA LIMITED, DELHI

section 148A. The\n\nrelevant observations of the hon'ble high court as contained in para 29\nto 32 of the order reads as under:\n\n29. In our considered opinion, and bearing in mind the import of Explanation 3\nas well as the language in which Section 147 of the Act stands couched,\nwe find no justification to differ

FR. SAUTER AG,NEW DELHI vs. ITO WARD INTERNATIONAL TAX 1(3)(2), NEW DELHI

In the result, the Appeal in ITA No

Bench: Shri Shamim Yahya & Shri Kul Bharat[Assessment Year : 2012-13]

Reassessment proceedings are bad-in- law 1.1. On the facts and in the circumstances of the case and in law, the Ld. AO has erred in initiating the re-assessment proceedings under the Act in respect of AY 2012-13, in the absence of any income escaping assessment. 1.2. On the facts and circumstances of the case

MONISHA DHAWAN (THROUGH LEGAL HEIR NAYANA DHAVAN),NEW DELHI vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE 28(1), DELHI, NEW DELHI

In the result, the appeal of the assessee is allowed

Bench: Ms Madhumita Roy & Shri Brajesh Kumar Singhassessment Year : 2013-14 Monisha Dhawan (Through Legal Vs. Acit, Heir Nayana Dhavan), Circle-28(1), 115A, First Floor, Delhi. Jorbagh, New Delhi – 110 003. Pan: Bbupd2464B (Appellant) (Respondent) Assessee By : Shri Salil Kapoor, Advocate & Shri Utkarsa Gupta, Advocate Revenue By : Shri Manish Gupta, Sr. Dr Date Of Hearing : 07.01.2026 Date Of Pronouncement : 07.01.2026

115A, First Floor, Delhi. Jorbagh, New Delhi – 110 003. PAN: BBUPD2464B (Appellant) (Respondent) Assessee by : Shri Salil Kapoor, Advocate & Shri Utkarsa Gupta, Advocate Revenue by : Shri Manish Gupta, Sr. DR Date of Hearing : 07.01.2026 Date of Pronouncement : 07.01.2026 ORDER PER MADHUMITA ROY, JM: The instant appeal filed by the Assessee is directed against the order dated

ACIT, NEW DELHI vs. FILATEX INDIA LIMITED, DELHI

115A(1)(b)(A) and 115A(1)(b)(B) of the\nIncome Tax Act. The assessee was required to deduct Tax at source on\nPage | 47\nITA Nos.4635, 5000, 2060, 4999, 4648, 3988,\n2061, 1455, 2062 & 1456/Del/2024\n& C.O.Nos.11, 32, 33, 34/Del/2025 & 89, 90 & 91/Del/2024\nthe remittance amounting to Rs.87,34,375/- and thus after obtaining\nthe approval from