COMMSSIONER OF INCOME TAX DELHI-XVI vs. S.S. AHLUWALIA

120.‖ 34. On analyzing the new Section 124, it is viewed that as per sub- section (1), Assessing Officer has jurisdiction in respect of persons carrying on business or profession where such business or profession was being carried out or situated within the area or where the business or profession was carried on in different areas, if the principal place

RAJ SHEELA GROWTH FUND (P) LTD. vs. INCOME TAX OFFICER, WARD - 21(1), DELHI

Bench: HON'BLE MR. JUSTICE YASHWANT VARMA,HON'BLE MR. JUSTICE PURUSHAINDRA KUMAR KAURAV

4); (b)persons being individuals referred to in item (b) of column (6). a)All cases of persons referred to in corresponding entry in item (a) of column (5) whose names begin with the alphabet ―O‖ or ―P‖ or ―Q‖ or ―R‖ ; (b) all cases of individuals being managing director or director or manager or secretary in the companies referred

CIT vs. TEI TECHNOLOGIES PVT LTD

Bench: CASES PERTAINING TO SPL.DIVISION BENCHES

4) is also with reference to the undertaking. A business might have several undertakings and section 28 does not envisage computation of income of each such undertaking. In other words, the profits of the business of the undertaking cannot be computed in isolation. The profits are computed under the head "Profits and gains of business or profession", as under

CIT vs. TEI TECHNOLOGIES PVT LTD

Bench: CASES PERTAINING TO SPL.DIVISION BENCHES

4) is also with reference to the undertaking. A business might have several undertakings and section 28 does not envisage computation of income of each such undertaking. In other words, the profits of the business of the undertaking cannot be computed in isolation. The profits are computed under the head "Profits and gains of business or profession", as under

PR. COMMISSIONER OF INCOME TAX -7 vs. SUMITOMO CORPORATION INDIA (P) LTD.

Bench: HON'BLE MR. JUSTICE YASHWANT VARMA,HON'BLE MR. JUSTICE RAVINDER DUDEJA

120 was selected for scrutiny and notice was issued under section 143(2) of the Act.  Assessing Officer (AO) passed draft assessment order (DAO) dated 21.03.2014 under section 143(3) read with section 144C, making addition of Rs.4,70,99,145, which included transfer pricing adjustment of Rs.1,91,52,594 and disallowance of deduction under section

THE PR. COMMISSIONER OF INCOME TAX -6 vs. MICROSOFT INDIA ( R & D) PVT. LTD.

Bench: HON'BLE MR. JUSTICE VIPIN SANGHI,HON'BLE MR. JUSTICE SANJEEV NARULA

120 was selected for scrutiny and notice was issued under section 143(2) of the Act.  Assessing Officer (AO) passed draft assessment order (DAO) dated 21.03.2014 under section 143(3) read with section 144C, making addition of Rs.4,70,99,145, which included transfer pricing adjustment of Rs.1,91,52,594 and disallowance of deduction under section

THE PR. COMMISSIONER OF INCOME TAX -6 vs. MARUTI SUZUKI INDIA LTD.

Bench: HON'BLE MR. JUSTICE VIPIN SANGHI,HON'BLE MR. JUSTICE SANJEEV NARULA

120 was selected for scrutiny and notice was issued under section 143(2) of the Act.  Assessing Officer (AO) passed draft assessment order (DAO) dated 21.03.2014 under section 143(3) read with section 144C, making addition of Rs.4,70,99,145, which included transfer pricing adjustment of Rs.1,91,52,594 and disallowance of deduction under section

HCL AUSTRALIA SERVICES PTY LIMITED,DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, DELHI

In the result, similar grounds of appeal, in all the captioned

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

reassessment proceedings have been initiated and final assessment order has been passed in contravention of the procedure prescribed under section 151A of the Act. RECEIPTS OF THE APPELLANT FROM HCLT NOT TAXABLE IN INDIA 4. Issue squarely covered in favour of the Appellant by binding decision of the Tribunal 41 That, at the outset, the assessing officer erred on facts

HCL SINGAPORE PTE. LTD (SUCCESSOR TO AXON SOLUTIONS SINGAPORE PTE LIMITED),DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, DELHI

In the result, similar grounds of appeal, in all the captioned

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

reassessment proceedings have been initiated and final assessment order has been passed in contravention of the procedure prescribed under section 151A of the Act. RECEIPTS OF THE APPELLANT FROM HCLT NOT TAXABLE IN INDIA 4. Issue squarely covered in favour of the Appellant by binding decision of the Tribunal 41 That, at the outset, the assessing officer erred on facts

HCL TECHNOLOGIES NORWAY AS ,DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, DELHI

In the result, similar grounds of appeal, in all the captioned

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

reassessment proceedings have been initiated and final assessment order has been passed in contravention of the procedure prescribed under section 151A of the Act. RECEIPTS OF THE APPELLANT FROM HCLT NOT TAXABLE IN INDIA 4. Issue squarely covered in favour of the Appellant by binding decision of the Tribunal 41 That, at the outset, the assessing officer erred on facts

ACIT, CC-30, NEW DELHI vs. AMARJYOTI VANIJYA PVT. LTD., NEW DELHI

In the result, all the appeals of the Revenue are dismissed

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

reassess the income of the assessee in accordance with the provisions of section 153A. It is also a settled law that the satisfaction note itself must display the reasons or basis for the conclusion that the Assessing Officer of the searched person is satisfied that the seized documents belong to a person other than the searched person

ACIT, CC-30, NEW DELHI vs. AMARJYOTI VANIJYA PVT. LTD., NEW DELHI

In the result, all the appeals of the Revenue are dismissed

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

reassess the income of the assessee in accordance with the provisions of section 153A. It is also a settled law that the satisfaction note itself must display the reasons or basis for the conclusion that the Assessing Officer of the searched person is satisfied that the seized documents belong to a person other than the searched person

ACIT. CENTRAL CIRCLE- 30, NEW DELHI vs. AMARJYOTI VANIJYA (P) LTD., NEW DELHI

In the result, all the appeals of the Revenue are dismissed

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

reassess the income of the assessee in accordance with the provisions of section 153A. It is also a settled law that the satisfaction note itself must display the reasons or basis for the conclusion that the Assessing Officer of the searched person is satisfied that the seized documents belong to a person other than the searched person

ITO, WARD- 2(2), NEW DELHI vs. ALMAK FINANCE PVT. LTD., NEW DELHI

Bench: Shri H. S. Sidhu & Before Shri Prashant Maharishi

b) of the Act. The fact that jurisdiction over last known residence address of the deceased assessee lies with ITO Ward 2(1), Jaipur is also corroborated by the assessment order passed for same assessment year 2008-09 in case of the legal Heir, Shri Subhash Chand Ajmera who happens to share the same residential address as that

COMMISSIONER OF INCOME TAX (EXEMPTIONS) DELHI vs. SERVANTS OF PEOPLE SOCIETY

Bench: HON'BLE MR. JUSTICE MANMOHAN,HON'BLE MR. JUSTICE NAVIN CHAWLA

4 to 9 of the 2007 Rules. 16.6. The proper officer can raise doubts as to the truth or accuracy Digitally Signed By:KAMLESH KUMAR Signing Date:27.11.2024 18:20:25 Signature Not Verified CUSAA 26/2022 & connected matters Page 50 of 137 of the declared value on ―certain reasons‖ which could include the grounds specified in sub-clauses

COMMISSIONER OF INCOME TAX (EXEMPTIONS) DELHI vs. SERVANTS OF PEOPLE SOCIETY

Bench: HON'BLE MR. JUSTICE MANMOHAN,HON'BLE MR. JUSTICE NAVIN CHAWLA

4 to 9 of the 2007 Rules. 16.6. The proper officer can raise doubts as to the truth or accuracy Digitally Signed By:KAMLESH KUMAR Signing Date:27.11.2024 18:20:25 Signature Not Verified CUSAA 26/2022 & connected matters Page 50 of 137 of the declared value on ―certain reasons‖ which could include the grounds specified in sub-clauses

BALLU SINGH,GURGAON vs. ITO WARD -65(5), NEW DELHI

In the result, the appeal of the assessee is allowed

Bench: Shri Kul Bharat

reassessment or computation of income u/s 147. As per section 148, it is mandatory that the Assessing Officer shall serve on the assessee a notice required him to furnish a return. The expression “Assessing Officer” used in the section 148 means ‘the Assessing Officer vested with the jurisdiction over the assessee as stipulated in the definition

BALLU SINGH,GURGAON vs. ITO WARD -65(5), NEW DELHI

In the result, the appeal of the assessee is allowed

Bench: Shri Kul Bharat

reassessment or computation of income u/s 147. As per section 148, it is mandatory that the Assessing Officer shall serve on the assessee a notice required him to furnish a return. The expression “Assessing Officer” used in the section 148 means ‘the Assessing Officer vested with the jurisdiction over the assessee as stipulated in the definition