COMMISSIONER OF INCOME TAX INTERNATIONAL TAXATION- 2, NEW DELHI vs. HYUNDAI ROTEM COMPANY

The appeal is dismissed

Bench: HON'BLE MR. JUSTICE V. KAMESWAR RAO,HON'BLE MR. JUSTICE VINOD KUMAR

21. Thus, if the provisions of section 144C as mandated by the statute are not strictly adhered to the entire object of providing fo ran alternate redressal mechanism in the form of Dispute Resolution Panel stand defeated. That is not the intention of the Legislature when the provision was introduced in the Act. Section 144C(10) of the Act provide

JINDAL STEEL & POWER LTD.,DELHI vs. DCIT, GURGAON

In the result, the appeal filed by the assessee is allowed for statistical

Bench: Shri R. K. Panda & Smt. Beena A. Pillaiassessment Year : 2005-06 Jindal Steel & Power Ltd., Dcit, Circle- 1(1), Jindal Centre, Gurgaon. 12, Bhikaji Cama Place, Vs. Delhi.

21. In the assessment years 2003-04 and 2004-05, despite the fact that the MBF Unit was eligible for deduction under section 80IB(5)(ii) of the Act since the said unit suffered losses. no deduction was claimed in the return of income. The said losses were completely set off by appellant with the taxable income for the respective

FRESENIUS KABI ONCOLOGY LTD,NEW DELHI vs. ITO, WARD-9(3), NEW DELHI

In the result appeal of the assessee is allowed

Bench: Shri Prakash Chand Yadav & Shri Manish Agarwalfresenius Kabi Oncology Ltd. Income Tax Officer, B-310, Som Dutt Chamber, Ward-9(3), Bhikaji Cama Place, Vs. New Delhi. New Delhi-110066. Pan-Aabcd7720L (Appellant) (Respondent)

reassessment or recomputation under sub-section (3) of section 143 or under section 144 or under section 147, as the case may be, with respect to the cases referred to in sub-section (2), shall be made in a faceless manner as per the following procedure, namely:— (i) the National Faceless Assessment Centre shall assign the case selected

ARIBA INDIA PRIVATE LIMITED,DELHI vs. ASSISTANT COMMISSIONER OF INCOME TAX, DELHI

In the result, appeal of the assessee is allowed

Bench: SHRI YOGESH KUMAR U.S (Judicial Member), SHRI MANISH AGARWAL (Accountant Member)

reassessment or recomputation under sub-section (3) of section 143 or under section 144 or under section 147, as the case may be, with respect to the cases referred to in sub-section (2), shall be made in a faceless manner as per the following procedure, namely:— (i) the National Faceless Assessment Centre shall assign the case selected

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

sections (3), (5) and (5-A)], be completed— (i) where the assessment, reassessment or recomputation is made Digitally Signed By:KAMLESH KUMAR Signing Date:02.09.2024 17:04:21

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

sections (3), (5) and (5-A)], be completed— (i) where the assessment, reassessment or recomputation is made Digitally Signed By:KAMLESH KUMAR Signing Date:02.09.2024 17:04:21

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

sections (3), (5) and (5-A)], be completed— (i) where the assessment, reassessment or recomputation is made Digitally Signed By:KAMLESH KUMAR Signing Date:02.09.2024 17:04:21

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

5) The order made under sub-section (4) shall be final. (6) No appeal under [Section 246] or Section 246A or an application for revision under Section 264 shall be admissible against the order of assessment or reassessment, referred to in clause (a) of subsection (1), in a case where an order under sub- section (4) has been made accepting

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.

5) It shall not be necessary for an assessee referred to in sub-section (1) to furnish under sub-section (1) of section 139 a return of his or its income if— (a) his or its total income in respect of which he or it is assessable under this Act during the previous year consisted only of income referred

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.

5) It shall not be necessary for an assessee referred to in sub-section (1) to furnish under sub-section (1) of section 139 a return of his or its income if— (a) his or its total income in respect of which he or it is assessable under this Act during the previous year consisted only of income referred

DEPUTY COMMISSIONER, DELHI vs. RAVINDRA SINGH, GREATER NOIDA

In the result, the Appeals of the Revenue in I

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwali.T.A. No. 2456/Del/2023 (A.Y 2011-12) I.T.A. No. 2457/Del/2023 (A.Y 2012-13) I.T.A. No. 2458/Del/2023 (A.Y 2013-14) I.T.A. No. 2459/Del/2023 (A.Y 2014-15)

reassess taking into consideration the other material in respect of completed assessments/unabated assessments. thereby, in respect of DCIT Vs. Ravindra Singh completed/unabated assessments, no addition can be made by the AD in absence of Meaning any incriminating material found during the course of search under Section 132 or requisition under Section 132A of the Act, 1961. However, the completed/unabated assessments

DEPUTY COMMISSIONER , DELHI vs. RAVINDRA SINGH, GREATER NOIDA

In the result, the Appeals of the Revenue in I

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwali.T.A. No. 2456/Del/2023 (A.Y 2011-12) I.T.A. No. 2457/Del/2023 (A.Y 2012-13) I.T.A. No. 2458/Del/2023 (A.Y 2013-14) I.T.A. No. 2459/Del/2023 (A.Y 2014-15)

reassess taking into consideration the other material in respect of completed assessments/unabated assessments. thereby, in respect of DCIT Vs. Ravindra Singh completed/unabated assessments, no addition can be made by the AD in absence of Meaning any incriminating material found during the course of search under Section 132 or requisition under Section 132A of the Act, 1961. However, the completed/unabated assessments

DEPUTY COMMISSIONER, DELHI vs. RAVINDRA SINGH, GREATER NOIDA

In the result, the Appeals of the Revenue in I

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwali.T.A. No. 2456/Del/2023 (A.Y 2011-12) I.T.A. No. 2457/Del/2023 (A.Y 2012-13) I.T.A. No. 2458/Del/2023 (A.Y 2013-14) I.T.A. No. 2459/Del/2023 (A.Y 2014-15)

reassess taking into consideration the other material in respect of completed assessments/unabated assessments. thereby, in respect of DCIT Vs. Ravindra Singh completed/unabated assessments, no addition can be made by the AD in absence of Meaning any incriminating material found during the course of search under Section 132 or requisition under Section 132A of the Act, 1961. However, the completed/unabated assessments

SEEMA GOEL,DELHI vs. CIT A, DELHI

The appeals of the assessee are allowed

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

5. Initiation of Penalty Proceedings Under Section 271(1)(c) is Premature o The initiation of penalty proceedings for alleged concealment of income is premature and without proper justification. PRAYER: The appellant respectfully prays that:  The addition of ₹1,54,00,000/- as undisclosed short-term capital gain be deleted.  The interest levied under Sections 234A, 234B, and 234C

SEEMA GOEL,DELHI vs. CIT A, DELHI

The appeals of the assessee are allowed

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

5. Initiation of Penalty Proceedings Under Section 271(1)(c) is Premature o The initiation of penalty proceedings for alleged concealment of income is premature and without proper justification. PRAYER: The appellant respectfully prays that:  The addition of ₹1,54,00,000/- as undisclosed short-term capital gain be deleted.  The interest levied under Sections 234A, 234B, and 234C

K K SPUN INDIA LIMITED,DELHI vs. DCIT, JHANDEWALAN DELHI

The appeals of the assessee are allowed

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

5. Initiation of Penalty Proceedings Under Section 271(1)(c) is Premature o The initiation of penalty proceedings for alleged concealment of income is premature and without proper justification. PRAYER: The appellant respectfully prays that:  The addition of ₹1,54,00,000/- as undisclosed short-term capital gain be deleted.  The interest levied under Sections 234A, 234B, and 234C

K K SPUN INDIA LIMITED,DELHI vs. DCIT CENTRAL CIRCLE-2 NEW DELHI, JHANDEWALAN DELHI

The appeals of the assessee are allowed

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

5. Initiation of Penalty Proceedings Under Section 271(1)(c) is Premature o The initiation of penalty proceedings for alleged concealment of income is premature and without proper justification. PRAYER: The appellant respectfully prays that:  The addition of ₹1,54,00,000/- as undisclosed short-term capital gain be deleted.  The interest levied under Sections 234A, 234B, and 234C

CHIRAG KIRPAL,DELHI vs. ASSISTANT COMMISSIONER OF INCOME TAX, INTERNATIONAL TAXATION, GURGAON

In the result, the appeal of the assessee is allowed

Bench: Shri M. Balaganesh & Shri Vimal Kumarchirag Kirpal, Vs. Acit, C/O. Anuj Bhatia, C-3, Bali International Taxation, Nagar, New Raja Garden, Gurgaon New Delhi (Appellant) (Respondent) Pan: Bwxpk8788D Assessee By : Shri. S. K. Gupta, Ca Revenue By: Shri M. S. Nethrapal, Cit Dr Date Of Hearing 17/09/2025 Date Of Pronouncement 30/09/2025

5) of the Act on 4-12- 2024 confirming the action of the Learned AO. Accordingly, final assessment order stood passed by the DCIT (International Taxation), Gurgoan under section 147 read with section 144C(13) of the Act on 21-02- 2025 determining total income of the Assessee at Rs. 65,02,482/-. Aggrieved, the Assessee is in appeal before