DCIT, NEW DELHI vs. M/S. DHARAMPAL SATYAPAL LTD., DELHI

In the result, the appeal of the assessee is allowed and the appeal of the revenue is dismissed

Bench: Shri A.T. Varkey & Shri Prashant Maharishi

147 of the Act. It will be appreciated that the issue of claim of deduction u/s 80IC was examined in great detail at the time of original assessment and assessment pursuant to order u/s 264 after examining various replies and details filed during the course of assessment and as such the impugned reassessment

DCIT, NEW DELHI vs. M/S. DSL SOFTWARE LTD., NEW DELHI

In the result, all the three appeals of the Revenue and cross objection of the assessee are dismissed

Bench: : Shri Amit Shukla & Shri L.P. Sahu

reassessment to reconsider the claim of deduction u/s 10A/ 80HHE of the Act tantamount to review of view earlier taken/ change of opinion and deserves to be quashed. The Supreme Court in the case of CIT vs Foramer France: 264 ITR 567 (SC), affirmed the decision of the Allahabad High Court in the case of Foramer France

DCIT, NEW DELHI vs. M/S. DSL SOFTWARE LTD., NEW DELHI

In the result, all the three appeals of the Revenue and cross objection of the assessee are dismissed

Bench: : Shri Amit Shukla & Shri L.P. Sahu

reassessment to reconsider the claim of deduction u/s 10A/ 80HHE of the Act tantamount to review of view earlier taken/ change of opinion and deserves to be quashed. The Supreme Court in the case of CIT vs Foramer France: 264 ITR 567 (SC), affirmed the decision of the Allahabad High Court in the case of Foramer France

ACIT, NEW DELHI vs. M/S. DSL SOFTWARE LTD., NEW DELHI

In the result, all the three appeals of the Revenue and cross objection of the assessee are dismissed

Bench: : Shri Amit Shukla & Shri L.P. Sahu

reassessment to reconsider the claim of deduction u/s 10A/ 80HHE of the Act tantamount to review of view earlier taken/ change of opinion and deserves to be quashed. The Supreme Court in the case of CIT vs Foramer France: 264 ITR 567 (SC), affirmed the decision of the Allahabad High Court in the case of Foramer France

M/S NEW DELHI TELEVISION LTD.,,NEW DELHI vs. ACIT, NEW DELHI

In the result, both the appeals of the assessee are allowed

Bench: : Shri I.C. Sudhir & Shri L.P. Sahu

u/s 147 of the Act vide written objections dated 12th November 2010 which were disposed of by the Ld. AO vide order dated 03.12.2010. Thereafter, vide reassessment order dated 24th December, 2010 the AO reassessed the total income of the assessee at Rs.14,94,40,960/- after restricting the claim for deduction

NEW DELHI TELEVISION LTD.,NEW DELHI vs. CIT, NEW DELHI

In the result, both the appeals of the assessee are allowed

Bench: : Shri I.C. Sudhir & Shri L.P. Sahu

u/s 147 of the Act vide written objections dated 12th November 2010 which were disposed of by the Ld. AO vide order dated 03.12.2010. Thereafter, vide reassessment order dated 24th December, 2010 the AO reassessed the total income of the assessee at Rs.14,94,40,960/- after restricting the claim for deduction

SHRI VALMIK THAPAR,NEW DELHI vs. DCIT, NEW DELHI

Appeals are disposed of by this common order as indicated above

Bench: Hon’Ble Justice P.P. Bhatt & Shri Prashant Maharishi(Through Video Conferencing) Shri Valmik Thapar, Vs. Acit, 19, Kautilya Marg, Circle-53(1), New Delhi New Delhi (Appellant) (Respondent) Shri Valmik Thapar, Vs. Dcit, M/S. R. N. Khanna & Company, Ca, Circle-32(1), 14-15F, Shivam House, Connaught New Delhi Place, New Delhi Pan: Aacpt7098K (Appellant) (Respondent) Acit, Vs. Shri Valmik Thapar, Circle-53(1), 19, Kautilya Marg, New Delhi New Delhi Pan: Aacpt7098K (Appellant) (Respondent) Assessee By : Shri Salil Agarwal, Senior Advocate Along With Shri Shailesh Gupta, Shri Mahur Agarwal, Advocates Revenue By: Shri H. K. Choudhary, Cit Dr Date Of Hearing 11/06/2021 (Last Hearing) Date Of Pronouncement 11/06/2021. O R D E R Per Prashant Maharishi, A. M. 1. These Are Three Appeals For Two Assessment Years Pertaining To One Assessee, Mr. Valmik Thapar, A Resident, Individual [Assessee]. Assessee Filed Ita Number

147 of the income tax act, 1961 initiated. Notice u/s 148 of the income tax act, 1961 is being issued.” 16. Reasons Recorded were attached with the notice u/s 148 of the act. Assessee submitted a letter dated 7 March 2012 stating that the return filed by the assessee on 26th of July 2010 may kindly be treated as return

SH. VALMIK THAPAR,NEW DELHI vs. ACIT, NEW DELHI

Appeals are disposed of by this common order as indicated above

Bench: Hon’Ble Justice P.P. Bhatt & Shri Prashant Maharishi(Through Video Conferencing) Shri Valmik Thapar, Vs. Acit, 19, Kautilya Marg, Circle-53(1), New Delhi New Delhi (Appellant) (Respondent) Shri Valmik Thapar, Vs. Dcit, M/S. R. N. Khanna & Company, Ca, Circle-32(1), 14-15F, Shivam House, Connaught New Delhi Place, New Delhi Pan: Aacpt7098K (Appellant) (Respondent) Acit, Vs. Shri Valmik Thapar, Circle-53(1), 19, Kautilya Marg, New Delhi New Delhi Pan: Aacpt7098K (Appellant) (Respondent) Assessee By : Shri Salil Agarwal, Senior Advocate Along With Shri Shailesh Gupta, Shri Mahur Agarwal, Advocates Revenue By: Shri H. K. Choudhary, Cit Dr Date Of Hearing 11/06/2021 (Last Hearing) Date Of Pronouncement 11/06/2021. O R D E R Per Prashant Maharishi, A. M. 1. These Are Three Appeals For Two Assessment Years Pertaining To One Assessee, Mr. Valmik Thapar, A Resident, Individual [Assessee]. Assessee Filed Ita Number

147 of the income tax act, 1961 initiated. Notice u/s 148 of the income tax act, 1961 is being issued.” 16. Reasons Recorded were attached with the notice u/s 148 of the act. Assessee submitted a letter dated 7 March 2012 stating that the return filed by the assessee on 26th of July 2010 may kindly be treated as return

ACIT, NEW DELHI vs. SH. VALMIK THAPAR, NEW DELHI

Appeals are disposed of by this common order as indicated above

Bench: Hon’Ble Justice P.P. Bhatt & Shri Prashant Maharishi(Through Video Conferencing) Shri Valmik Thapar, Vs. Acit, 19, Kautilya Marg, Circle-53(1), New Delhi New Delhi (Appellant) (Respondent) Shri Valmik Thapar, Vs. Dcit, M/S. R. N. Khanna & Company, Ca, Circle-32(1), 14-15F, Shivam House, Connaught New Delhi Place, New Delhi Pan: Aacpt7098K (Appellant) (Respondent) Acit, Vs. Shri Valmik Thapar, Circle-53(1), 19, Kautilya Marg, New Delhi New Delhi Pan: Aacpt7098K (Appellant) (Respondent) Assessee By : Shri Salil Agarwal, Senior Advocate Along With Shri Shailesh Gupta, Shri Mahur Agarwal, Advocates Revenue By: Shri H. K. Choudhary, Cit Dr Date Of Hearing 11/06/2021 (Last Hearing) Date Of Pronouncement 11/06/2021. O R D E R Per Prashant Maharishi, A. M. 1. These Are Three Appeals For Two Assessment Years Pertaining To One Assessee, Mr. Valmik Thapar, A Resident, Individual [Assessee]. Assessee Filed Ita Number

147 of the income tax act, 1961 initiated. Notice u/s 148 of the income tax act, 1961 is being issued.” 16. Reasons Recorded were attached with the notice u/s 148 of the act. Assessee submitted a letter dated 7 March 2012 stating that the return filed by the assessee on 26th of July 2010 may kindly be treated as return

RUBY SINGH ,NEW DELHI vs. DCIT, CENTRAL CIRCLE-8, NEW DELHI

In the result, all the seven captioned appeals filed by the assessee stand dismissed in the aforesaid manner

Bench: Shri Chandra Mohan Garg & Shri M. Balaganesh, Accoutant Member

reassessment proceedings u/s. 147 of the Act and issuance of said notice u/s. 148, therefore, our conclusion drawn for assessment year 2013-14 (supra) would apply mutatis mutandis to the identical and similar grounds no. 2 to 2.2 of assessee in other 06 appeals. Consequently, grounds no. 2 to 2.2 of the assessee in other 06 appeals

RUBY SINGH,NEW DELHI vs. DCIT, CENTRAL CIRCLE-8, NEW DELHI

In the result, all the seven captioned appeals filed by the assessee stand dismissed in the aforesaid manner

Bench: Shri Chandra Mohan Garg & Shri M. Balaganesh, Accoutant Member

reassessment proceedings u/s. 147 of the Act and issuance of said notice u/s. 148, therefore, our conclusion drawn for assessment year 2013-14 (supra) would apply mutatis mutandis to the identical and similar grounds no. 2 to 2.2 of assessee in other 06 appeals. Consequently, grounds no. 2 to 2.2 of the assessee in other 06 appeals

RUBY SINGH,NEW DELHI vs. DCIT, CENTRAL CIRCLE-8, NEW DELHI

In the result, all the seven captioned appeals filed by the assessee stand dismissed in the aforesaid manner

Bench: Shri Chandra Mohan Garg & Shri M. Balaganesh, Accoutant Member

reassessment proceedings u/s. 147 of the Act and issuance of said notice u/s. 148, therefore, our conclusion drawn for assessment year 2013-14 (supra) would apply mutatis mutandis to the identical and similar grounds no. 2 to 2.2 of assessee in other 06 appeals. Consequently, grounds no. 2 to 2.2 of the assessee in other 06 appeals

RUBY SINGH,DELHI vs. DCIT, CENTRAL CIRCLE-8, NEW DELHI

In the result, all the seven captioned appeals filed by the assessee stand dismissed in the aforesaid manner

Bench: Shri Chandra Mohan Garg & Shri M. Balaganesh, Accoutant Member

reassessment proceedings u/s. 147 of the Act and issuance of said notice u/s. 148, therefore, our conclusion drawn for assessment year 2013-14 (supra) would apply mutatis mutandis to the identical and similar grounds no. 2 to 2.2 of assessee in other 06 appeals. Consequently, grounds no. 2 to 2.2 of the assessee in other 06 appeals

RUBY SINGH ,NEW DELHI vs. DCIT, CENTRAL CIRCLE-8, NEW DELHI

In the result, all the seven captioned appeals filed by the assessee stand dismissed in the aforesaid manner

Bench: Shri Chandra Mohan Garg & Shri M. Balaganesh, Accoutant Member

reassessment proceedings u/s. 147 of the Act and issuance of said notice u/s. 148, therefore, our conclusion drawn for assessment year 2013-14 (supra) would apply mutatis mutandis to the identical and similar grounds no. 2 to 2.2 of assessee in other 06 appeals. Consequently, grounds no. 2 to 2.2 of the assessee in other 06 appeals

RUBY SINGH,NEW DELHI vs. DCIT, CENTRAL CIRCLE-8, NEW DELHI

In the result, all the seven captioned appeals filed by the assessee stand dismissed in the aforesaid manner

Bench: Shri Chandra Mohan Garg & Shri M. Balaganesh, Accoutant Member

reassessment proceedings u/s. 147 of the Act and issuance of said notice u/s. 148, therefore, our conclusion drawn for assessment year 2013-14 (supra) would apply mutatis mutandis to the identical and similar grounds no. 2 to 2.2 of assessee in other 06 appeals. Consequently, grounds no. 2 to 2.2 of the assessee in other 06 appeals

RUBY SINGH,NEW DELHI vs. DCIT, CENTRAL CIRCLE-8, NEW DELHI

In the result, all the seven captioned appeals filed by the assessee stand dismissed in the aforesaid manner

Bench: Shri Chandra Mohan Garg & Shri M. Balaganesh, Accoutant Member

reassessment proceedings u/s. 147 of the Act and issuance of said notice u/s. 148, therefore, our conclusion drawn for assessment year 2013-14 (supra) would apply mutatis mutandis to the identical and similar grounds no. 2 to 2.2 of assessee in other 06 appeals. Consequently, grounds no. 2 to 2.2 of the assessee in other 06 appeals

M/S. A.T. KEARNEY INDIA PRIVATE LIMITED,GURGAON vs. ITO, NEW DELHI

In the result the ground No

Bench: Smt Diva Singh & Shri Prashant Maharishiat Kearney India Private Ito, Limited, Ward-1(1), Vs. 6Th Floor, Tower-D, Global New Delhi Business Park, Gurgaon Pan:Aadca1436G (Appellant) (Respondent) At Kearney India Private Ito, Limited, Ward-1(1), Vs. 6Th Floor, Tower-D, Global New Delhi Business Park, Gurgaon Pan:Aadca1436G (Appellant) (Respondent)

147 of the Act and also confirmed deduction u/s 10A of the Act to Rs. 11374842/- as against claim of Rs. 39280361/-. On issue interest income chargeable as „income A T Kearney India Private Limited V ITO A Y 2005-06 & 2007-08 ITA no 510& 511 /Del/2014 Page 7 of 31 from other sources‟ he also confirmed the treatment

M/S. A.T. KEARNEY INDIA PRIVATE LIMITED,GURGAON vs. ITO, NEW DELHI

In the result the ground No

Bench: Smt Diva Singh & Shri Prashant Maharishiat Kearney India Private Ito, Limited, Ward-1(1), Vs. 6Th Floor, Tower-D, Global New Delhi Business Park, Gurgaon Pan:Aadca1436G (Appellant) (Respondent) At Kearney India Private Ito, Limited, Ward-1(1), Vs. 6Th Floor, Tower-D, Global New Delhi Business Park, Gurgaon Pan:Aadca1436G (Appellant) (Respondent)

147 of the Act and also confirmed deduction u/s 10A of the Act to Rs. 11374842/- as against claim of Rs. 39280361/-. On issue interest income chargeable as „income A T Kearney India Private Limited V ITO A Y 2005-06 & 2007-08 ITA no 510& 511 /Del/2014 Page 7 of 31 from other sources‟ he also confirmed the treatment

RRB ENERGY LTD.,NEW DELHI vs. ITO, NEW DELHI

Bench: Shri G. D. Agrawal, Hon’Ble & Shri Kuldip Singh

147 for the issuance of reassessment u/s 148 of the Act’. In order to decide this question first of all we have to determine ‘as to whether the issue of deduction