BEST BULL STOCK TRADING PVT LTD.,NEW DELHI vs. ACIT CENTRAL CIRCLE-18, DELHI

In the result, the appeals of the revenue in ITA No

Bench: Sh. C.N. Prasad & Sh. M. Balaganesh

reassessment or recomputation may be taken. Section 251 reads as follows: Powers of the 70 [Joint Commissioner (Appcals) or the) Commissioner (Appeals). 251. (1) In disposing of an appeal, the Commissioner (Appeals) shall have the following powers- (a) in an appeal against an order of assessment, he may confirm, reduce, enhance or annul the assessment: [Provided that where such appeal

EBRO INDIA PVT.LTD. ,DELHI vs. ACIT CIRCLE-7(1), DELHI

In the result, the ground no 4 raised by the assessee is allowed

Bench: SHRI S.RIFAUR RAHMAN (Accountant Member), SHRI YOGESH KUMAR U.S. (Accountant Member)

72. Reliance in this regard may be made to the decision of the Mumbai Bench of the Tribunal in the case of Vodafone India Limited v DCIT: ITA No. 1835/Mum/2018. In that case, share capital was received by the assessee from its existing Mauritius based shareholders on subscription to right issue of shares. The assessing officer added the said capital

DHARAMVIR KHOSLA ,. vs. DCIT CC-5, NEW DELHI , .

The appeals are allowed for statistical purposes and ld

72,686/- as against TDS allowed in the computation at Rs.24,37,186/-.\nThus, here again AO did not apply his own mind and simply followed\nintimation u/s 143(1) of the Act and Rs.8,35,000/- was shortly allowed. The\nreason given in the intimation at Page 22 by referring to 3 TAN Numbers as\nalso mentioned at page

(Now known as Sony India Limited)

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 the proceedings of which have been completed before the 1st day of October, 2009. (3) Where during the course of any proceeding for the assessment of income

DHARAMVIR KHOSLA,. vs. DCIT CC-5, NEW DELHI , .

The appeals are allowed for statistical purposes and ld

72,686/- as against TDS allowed in the computation at Rs.24,37,186/-.\nThus, here again AO did not apply his own mind and simply followed\nintimation u/s 143(1) of the Act and Rs.8,35,000/- was shortly allowed. The\nreason given in the intimation at Page 22 by referring to 3 TAN Numbers as\nalso mentioned at page

AMOL AWASTHI,NEW DELHI vs. DCIT, C.C.1, NEW DELHI

In the result, appeals are allowed, as indicated

Bench: Shri Saktijit Dey & Shri M Balaganesh

Section 153C read with Section 153A of the Act. 97. Proceeding then to List II, we find that the petitions placed in that list pertain to cases where the hand over occurred in FYs 2022-23 and 2023-24. Consequently, the relevant AYs' would be AY 2023-24 and AY 2024-25 respectively. In light of the principles enunciated

AMOL AWASTHI,NEW DELHI vs. DCIT, C.C.1, NEW DELHI

In the result, appeals are allowed, as indicated

Bench: Shri Saktijit Dey & Shri M Balaganesh

Section 153C read with Section 153A of the Act. 97. Proceeding then to List II, we find that the petitions placed in that list pertain to cases where the hand over occurred in FYs 2022-23 and 2023-24. Consequently, the relevant AYs' would be AY 2023-24 and AY 2024-25 respectively. In light of the principles enunciated

AMOL AWASTHI,NEW DELHI vs. DCIT, C.C.1, NEW DELHI

In the result, appeals are allowed, as indicated

Bench: Shri Saktijit Dey & Shri M Balaganesh

Section 153C read with Section 153A of the Act. 97. Proceeding then to List II, we find that the petitions placed in that list pertain to cases where the hand over occurred in FYs 2022-23 and 2023-24. Consequently, the relevant AYs' would be AY 2023-24 and AY 2024-25 respectively. In light of the principles enunciated

AMOL AWASTHI,NEW DELHI vs. DCIT, C.C.1, NEW DELHI

In the result, appeals are allowed, as indicated

Bench: Shri Saktijit Dey & Shri M Balaganesh

Section 153C read with Section 153A of the Act. 97. Proceeding then to List II, we find that the petitions placed in that list pertain to cases where the hand over occurred in FYs 2022-23 and 2023-24. Consequently, the relevant AYs' would be AY 2023-24 and AY 2024-25 respectively. In light of the principles enunciated

AMOL AWASTHI,NEW DELHI vs. DCIT, CENTRAL CIRCLE-1, NEW DELHI

In the result, appeals are allowed, as indicated

Bench: Shri Saktijit Dey & Shri M Balaganesh

Section 153C read with Section 153A of the Act. 97. Proceeding then to List II, we find that the petitions placed in that list pertain to cases where the hand over occurred in FYs 2022-23 and 2023-24. Consequently, the relevant AYs' would be AY 2023-24 and AY 2024-25 respectively. In light of the principles enunciated

AMOL AWASTHI,NEW DELHI vs. DCIT, CENTRAL CIRCLE-I, NEW DELHI

In the result, appeals are allowed, as indicated

Bench: Shri Saktijit Dey & Shri M Balaganesh

Section 153C read with Section 153A of the Act. 97. Proceeding then to List II, we find that the petitions placed in that list pertain to cases where the hand over occurred in FYs 2022-23 and 2023-24. Consequently, the relevant AYs' would be AY 2023-24 and AY 2024-25 respectively. In light of the principles enunciated

AMOL AWASTHI,NEW DELHI vs. DCIT, CENTRAL CIRCLE-1, NEW DELHI

In the result, appeals are allowed, as indicated

Bench: Shri Saktijit Dey & Shri M Balaganesh

Section 153C read with Section 153A of the Act. 97. Proceeding then to List II, we find that the petitions placed in that list pertain to cases where the hand over occurred in FYs 2022-23 and 2023-24. Consequently, the relevant AYs' would be AY 2023-24 and AY 2024-25 respectively. In light of the principles enunciated

DCIT, NEW DELHI vs. ISERVICES INVESTMENTS LTD., NEW DELHI

In the result, the Cross Objections of the assessee are allowed and consequently the appeals of the revenue are liable to be dismissed

Bench: Sh. Saktijit Deydr. B. R. R. Kumar

72,09,025/- declared by the assessee and allowing the same, while holding that the assessee company was not resident in India, thereby making the order self contradictory. 7. The Ld. Commissioner of Income Tax (Appeals) has erred in holding that provision of section 124(4) was applicable in this case and further that the order should have been passed

DCIT, NEW DELHI vs. M/S. I SERVICES INVESTMENT LTD., NEW DELHI

In the result, the Cross Objections of the assessee are allowed and consequently the appeals of the revenue are liable to be dismissed

Bench: Sh. Saktijit Deydr. B. R. R. Kumar

72,09,025/- declared by the assessee and allowing the same, while holding that the assessee company was not resident in India, thereby making the order self contradictory. 7. The Ld. Commissioner of Income Tax (Appeals) has erred in holding that provision of section 124(4) was applicable in this case and further that the order should have been passed

DCIT, NEW DELHI vs. M/S. I SERVICES INVESTMENT LTD., NEW DELHI

In the result, the Cross Objections of the assessee are allowed and consequently the appeals of the revenue are liable to be dismissed

Bench: Sh. Saktijit Deydr. B. R. R. Kumar

72,09,025/- declared by the assessee and allowing the same, while holding that the assessee company was not resident in India, thereby making the order self contradictory. 7. The Ld. Commissioner of Income Tax (Appeals) has erred in holding that provision of section 124(4) was applicable in this case and further that the order should have been passed

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. 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

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

COMMISSIONER OF INCOME TAX (CENTRAL)-I vs. CHETAN GUPTA

The appeal is dismissed but, in the facts and circumstances of the

1) is that reassessment shall not be made until there has been service.” However, the said decision does state that jurisdiction becomes vested in the AO to proceed with the assessment once notice is issued within a period of limitation. It also emphasized 2015:DHC:7656-DB ITA No.72 of 2014 Page 13 of 24 that no reassessment shall