DCIT CENTRAL CIRCLE-14, NEW DELHI vs. SH. VIJAY KUMAR SONI, NEW DELHI

The appeal of the Revenue is dismissed as infructuous

Bench: Dr. B. R. R. Kumarsh. Sudhir Kumarita No. 1883/Del/2023 : Asstt. Year : 2017-18 Bijay Kumar Soni, Vs Dcit, C/O Anil Jain Dd & Co., Central Circle-14, 611, Surya Kiran Building, 19, New Delhi-110055 K. G. Marg, New Delhi-110001 (Appellant) (Respondent) Pan No. Aolps5917H Ita No. 2144/Del/2023 : Asstt. Year : 2017-18 Dcit, Vs Bijay Kumar Soni, Central Circle-14, 61/14, Block No. 61, Ram Jas, New Delhi-110055 Karol Bagh, New Delhi-110005 (Appellant) (Respondent) Pan No. Aolps5917H Assessee By : Sh. Anil Jain, Ca Revenue By : Ms. Monika Dhami, Cit-Dr Date Of Hearing: 01.08.2023 Date Of Pronouncement: 06.09.2023 Order Per Dr. B. R. R. Kumar:

1) of section 245M, the period of limitation available under this section to the Assessing Officer for making an order of assessment, reassessment or recomputation, as the case may be, shall, after the exclusion of the period under sub-section (5) of the said section, be not less than one year; and where such period of ITA Nos. 1883 & 2144/Del/2023

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

1) of section 245M, the period of limitation available under this section to the Assessing Officer for making an order of assessment, reassessment or recomputation, as the case may be, shall, after the exclusion of the period under sub-section (5) of the said section, be not less than one year; and where such period of limitation is less than

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

1) of section 245M, the period of limitation available under this section to the Assessing Officer for making an order of assessment, reassessment or recomputation, as the case may be, shall, after the exclusion of the period under sub-section (5) of the said section, be not less than one year; and where such period of limitation is less than

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

1) of section 245M, the period of limitation available under this section to the Assessing Officer for making an order of assessment, reassessment or recomputation, as the case may be, shall, after the exclusion of the period under sub-section (5) of the said section, be not less than one year; and where such period of limitation is less than

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

244A of the Act from first day of AY i.e. 1 April 2021 till the date of receipt of actual refund in the bank account of the Appellant. 3. We shall take up AY 2012-13 as the lead case. Our findings on the main issues recorded in AY 2012-13 shall apply mutatis-mutandis to the common issues

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

244A of the Act from first day of AY i.e. 1 April 2021 till the date of receipt of actual refund in the bank account of the Appellant. 3. We shall take up AY 2012-13 as the lead case. Our findings on the main issues recorded in AY 2012-13 shall apply mutatis-mutandis to the common issues

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

244A of the Act from first day of AY i.e. 1 April 2021 till the date of receipt of actual refund in the bank account of the Appellant. 3. We shall take up AY 2012-13 as the lead case. Our findings on the main issues recorded in AY 2012-13 shall apply mutatis-mutandis to the common issues

PROVIDENT INV. & INDUSTRIES (P) LTD.,NEW DELHI vs. ITO, NEW DELHI

In the result ground No. 5 of the appeal of the assessee is dismissed

Bench: Shri H.S.Sidhu & Shri Prashant Maharishiprovident Inv & Industries P Ltd, Vs. Ito, Ward-14(2), 4Th Floor, Ito, A-49, Mohan Cooperative Industrial Estate, Mathura Road, New Delhi Cr Building, New Delhi Pan:Aabcj4816P (Appellant) (Respondent)

b) one year from the end of the financial year in which a return or a revised return relating to the assessment year commencing on the 1st day of April, 1988, or any earlier assessment year, is filed under sub- section (4) or sub-section (5) or section 139, whichever is later. (2) No order or assessment, reassessment or recomputation

THE BANK OF TOKYO MISTUBISHI UFJ LTD.,,NEW DELHI vs. DCIT (INTERNATIONAL TAXATION), NEW DELHI

In the result, appeal of the assessee is partly allowed

Bench: Shri N.K. Saini & Before Mr. Bhavnesh Saini

244A of the Act amounting to Rs. 80,69,683/-) was determined as refundable to the assessee vide intimation dated 7th October, 2009 and the refund was subsequently adjusted against the tax demand for the AY 2007-08. It was further submitted that where no refund is due to the assessee on regular assessment, the assessee is liable

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.

1. That the Commissioner of Income Tax (Appeals) ['CIT(A)'] erred on facts and in law in dismissing the appeal filed by the appellant against order dated 04.03.2013 passed under section 143(3)/147 of the Income-tax Act, 1961 ('the Act'), holding the same to be infructuous. 1.1 That the CIT(A) erred on facts

M/S. LG ELECTRONICS INC., KOREA (LGEK),NOIDA vs. DCIT (INTERNATIONAL TAXATION), NOIDA

In the result all the 9 appeals filed by the assessee are allowed with above direction for statistical purposes

Bench: Smt Diva Singh & Shri Prashant Maharishi

244A of the Act. 12. That the AO/DRP has grossly erred in law and facts in initiating the penalty under section 271(l)(c) of the Act and alleging that the Appellant has concealed the true and correct particulars of its taxable income and furnished inaccurate particulars of its income. 13. That the AO/ DRP has grossly erred

LG ELECTRONICS INC., KOREA (LGEK),NOIDA vs. DCIT, CIRCLE- NOIDA, INTERNATIONAL TAXATION, NOIDA

In the result all the 9 appeals filed by the assessee are allowed with above direction for statistical purposes

Bench: Smt Diva Singh & Shri Prashant Maharishi

244A of the Act. 12. That the AO/DRP has grossly erred in law and facts in initiating the penalty under section 271(l)(c) of the Act and alleging that the Appellant has concealed the true and correct particulars of its taxable income and furnished inaccurate particulars of its income. 13. That the AO/ DRP has grossly erred

LG ELECTRONICS INC., KOREA (LGEK),NOIDA vs. DCIT, CIRCLE- 2(2)(1), INTERNATIONAL TAXATION , NEW DELHI

In the result all the 9 appeals filed by the assessee are allowed with above direction for statistical purposes

Bench: Smt Diva Singh & Shri Prashant Maharishi

244A of the Act. 12. That the AO/DRP has grossly erred in law and facts in initiating the penalty under section 271(l)(c) of the Act and alleging that the Appellant has concealed the true and correct particulars of its taxable income and furnished inaccurate particulars of its income. 13. That the AO/ DRP has grossly erred

SHRI CHETAN SETH,NEW DELHI vs. ITO, NEW DELHI

Bench: Shri Satbeer Singh Godara & Shri Brajesh Kumar Singh

244A of the Act. 4. Additional grounds of appeal raised by the assessee are as under:- 1. Mechanical Sanction u/s 151(1) of Addl. Commissioner Range - 15: i) That the learned CIT(A) and Ld. AO have erred in law and on facts by making and upholding the re-assessment, without subjective sanction by the Addl. Commissioner, Range

CHETAN SETH,NEW DELHI vs. ITO,WARD-15(3), DELHI

Bench: Shri Satbeer Singh Godara & Shri Brajesh Kumar Singh

244A of the Act. 4. Additional grounds of appeal raised by the assessee are as under:- 1. Mechanical Sanction u/s 151(1) of Addl. Commissioner Range - 15: i) That the learned CIT(A) and Ld. AO have erred in law and on facts by making and upholding the re-assessment, without subjective sanction by the Addl. Commissioner, Range

SHRI CHETAN SETH,NEW DELHI vs. ITO, NEW DELHI

Bench: Shri Satbeer Singh Godara & Shri Brajesh Kumar Singh

244A of the Act. 4. Additional grounds of appeal raised by the assessee are as under:- 1. Mechanical Sanction u/s 151(1) of Addl. Commissioner Range - 15: i) That the learned CIT(A) and Ld. AO have erred in law and on facts by making and upholding the re-assessment, without subjective sanction by the Addl. Commissioner, Range

PUNIT KUMAR AGGARWAL,DELHI vs. ITO,WARD-36(2), DELHI

Bench: Shri Satbeer Singh Godara & Shri Brajesh Kumar Singh

244A of the Act. 4. Additional grounds of appeal raised by the assessee are as under:- 1. Mechanical Sanction u/s 151(1) of Addl. Commissioner Range - 15: i) That the learned CIT(A) and Ld. AO have erred in law and on facts by making and upholding the re-assessment, without subjective sanction by the Addl. Commissioner, Range

ISWAR CHAND DUBEY,DELHI vs. ITO,WARD-68 (1), DELHI

Bench: Shri Satbeer Singh Godara & Shri Brajesh Kumar Singh

244A of the Act. 4. Additional grounds of appeal raised by the assessee are as under:- 1. Mechanical Sanction u/s 151(1) of Addl. Commissioner Range - 15: i) That the learned CIT(A) and Ld. AO have erred in law and on facts by making and upholding the re-assessment, without subjective sanction by the Addl. Commissioner, Range

LOUIS DREYFUS COMMODITIES INDIA PVT. LTD.,GURGAON vs. DCIT, NEW DELHI

Bench: Shri Kuldip Singh & Shri Prashant Maharishi(Through Video Conference)

244A of the Act. 4. On the facts and circumstances of the case and in law, the Ld. AO has grossly erred in initiating penalty proceedings under Section 271 (1) (c) of the Act.” 2. Briefly stated the facts necessary for adjudication of the controversy at hand are : Louis Dreyfus Commodities India Private Limited (LD India), the taxpayer, a subsidiary