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, 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

COMMISSIONER OF INCOME TAX

reassess under section 147 or pass an order enhancing the assessment or reducing a refund already made or otherwise increasing the liability of the assessee under section 154, for any assessment year beginning on or before the 1st day of April, 2001. xxxx 80-A. Deductions to be made in computing total income.—(1) In computing the total income

GUJARAT GUARDIAN LTD.,,NEW DELHI vs. DCIT, NEW DELHI

43A of the Act, which provisions are held to be prospective by the Hon'ble Delhi High Court in the case of Woodward Governor reported in 294 ITR 451, which decision has been further affirmed by the Hon'ble Supreme Court in the case of CIT Vs. Woordward Governor reported in 312 ITR 254 (SC). Therefore, we allow this ground

M/S GUJARAT GUARDIAN LTD.,,NEW DELHI vs. DCIT,, NEW DELHI

43A of the Act, which provisions are held to be prospective by the Hon'ble Delhi High Court in the case of Woodward Governor reported in 294 ITR 451, which decision has been further affirmed by the Hon'ble Supreme Court in the case of CIT Vs. Woordward Governor reported in 312 ITR 254 (SC). Therefore, we allow this ground

GUJARAT GUARDIAN LTD.,NEW DELHI vs. DCIT, NEW DELHI

43A of the Act is prospective\nand applicable w.e.f. 1.4.2003.\n15. Ld. D.R. could not provide any adverse ruling holding\notherwise against the assessee.\nFinding of the Bench:\n16. After considering the rival submissions, we are of the view that\nthe authorities have erred in relying upon the provisions of section\n43A of the Act, which provisions are held

DCIT, NEW DELHI vs. M/S GUJRAT GUARDIAN LTD.,, NEW DELHI

43A of the Act is prospective\nand applicable w.e.f. 1.4.2003.\n\n15. Ld. D.R. could not provide any adverse ruling holding\notherwise against the assessee.\n\nFinding of the Bench:\n\n16. After considering the rival submissions, we are of the view that\nthe authorities have erred in relying upon the provisions of section\n43A of the Act, which provisions

ACIT, NEW DELHI vs. M/S GUJARAT GUARDIAN LTD., NEW DELHI

43A of the Act is prospective\nand applicable w.e.f. 1.4.2003.\n\n15. Ld. D.R. could not provide any adverse ruling holding\notherwise against the assessee.\n\nFinding of the Bench:\n\n16. After considering the rival submissions, we are of the view that\nthe authorities have erred in relying upon the provisions of section\n43A of the Act, which provisions

DCIT, NEW DELHI vs. M/S. GUJRAT GUARDIAN LTD., NEW DELHI

43A of the Act is prospective\nand applicable w.e.f. 1.4.2003.\n\n15. Ld. D.R. could not provide any adverse ruling holding\notherwise against the assessee.\n\nFinding of the Bench:\n\n16. After considering the rival submissions, we are of the view that\nthe authorities have erred in relying upon the provisions of section\n43A of the Act, which provisions

GUJARAT GUARDIAN LTD.,,NEW DELHI vs. DCIT, NEW DELHI

43A of the Act is prospective\nand applicable w.e.f. 1.4.2003.\n\n15. Ld. D.R. could not provide any adverse ruling holding\notherwise against the assessee.\n\nFinding of the Bench:\n\n16. After considering the rival submissions, we are of the view that\nthe authorities have erred in relying upon the provisions of section\n43A of the Act, which provisions

SHREE CHANDI MAA MAHAKALI PRACHIN MANDIR SIDH PEETH SAMITI,SONIPAT vs. CPC, BANGLORE

43A of the Act is prospective\nand applicable w.e.f. 1.4.2003.\n\n15. Ld. D.R. could not provide any adverse ruling holding\notherwise against the assessee.\nFinding of the Bench:\n\n16. After considering the rival submissions, we are of the view that\nthe authorities have erred in relying upon the provisions of section\n43A of the Act, which provisions

GUJRAT GUARDIAN LTD.,NEW DELHI vs. DCIT, NEW DELHI

43A of the Act is prospective\nand applicable w.e.f. 1.4.2003.\n15. Ld. D.R. could not provide any adverse ruling holding\notherwise against the assessee.\nFinding of the Bench:\n16. After considering the rival submissions, we are of the view that\nITA Nos.4859/Del/2009; ITA Nos.157 to 159,\n4791,4856 &5358/Del/2010 & ITA No.2539/Del/2017\nGujarat Guardian Ltd., New Delhi\nPage

DIRECTOR OF INCOME TAX vs. ROYAL JORDANIAN AIRLINES

The appeals are disposed of and the writ petitions are allowed in the

reassessment proceedings which should be refunded to the appellant, if already collected”. 10. Aggrieved by the above order of the CIT (A), both the Revenue and RJA filed appeals before the ITAT. In RJA’s five appeals, the issue raised was the refusal by the CIT (A) to grant refund in respect of the taxes that had already been paid

DIRECTOR OF INCOME TAX vs. ROYAL JORDANIAN AIRLINES

The appeals are disposed of and the writ petitions are allowed in the

reassessment proceedings which should be refunded to the appellant, if already collected”. 10. Aggrieved by the above order of the CIT (A), both the Revenue and RJA filed appeals before the ITAT. In RJA’s five appeals, the issue raised was the refusal by the CIT (A) to grant refund in respect of the taxes that had already been paid

DIRECTOR OF INCOME TAX vs. ROYAL JORDANIAN AIRLINES

The appeals are disposed of and the writ petitions are allowed in the

reassessment proceedings which should be refunded to the appellant, if already collected”. 10. Aggrieved by the above order of the CIT (A), both the Revenue and RJA filed appeals before the ITAT. In RJA’s five appeals, the issue raised was the refusal by the CIT (A) to grant refund in respect of the taxes that had already been paid

DIRECTOR OF INCOME TAX vs. ROYAL JORDANIAN AIRLINES

The appeals are disposed of and the writ petitions are allowed in the

reassessment proceedings which should be refunded to the appellant, if already collected”. 10. Aggrieved by the above order of the CIT (A), both the Revenue and RJA filed appeals before the ITAT. In RJA’s five appeals, the issue raised was the refusal by the CIT (A) to grant refund in respect of the taxes that had already been paid

DIRECTOR OF INCOME TAX vs. ROYAL JORDANIAN AIRLINES

The appeals are disposed of and the writ petitions are allowed in the

reassessment proceedings which should be refunded to the appellant, if already collected”. 10. Aggrieved by the above order of the CIT (A), both the Revenue and RJA filed appeals before the ITAT. In RJA’s five appeals, the issue raised was the refusal by the CIT (A) to grant refund in respect of the taxes that had already been paid