ACIT, CIRCLE-18(2), NOIDA vs. NOIDA TOLL BRIDGE CO. LTD., NOIDA

In the result, appeal of the assessee is allowed

Bench: Shri N.K. Billaiya & Ms. Astha Chandra

reassessment proceedings waiving its right to challenge the same before the Constitutional Courts under writ jurisdiction; the objections of the appellant to assumption of jurisdiction by the Ld. AO. had become infructuous & needs to be given quietus. The challenge posed by the appellant to the assumption of jurisdiction by the Id. AO. u/s. 147 of I.T. Act, 1961 is, therefore

ACIT, CIRCLE-18(2), NOIDA vs. NOIDA TOLL BRIDGE CO. LTD., NOIDA

In the result, appeal of the assessee is allowed

Bench: Shri N.K. Billaiya & Ms. Astha Chandra

reassessment proceedings waiving its right to challenge the same before the Constitutional Courts under writ jurisdiction; the objections of the appellant to assumption of jurisdiction by the Ld. AO. had become infructuous & needs to be given quietus. The challenge posed by the appellant to the assumption of jurisdiction by the Id. AO. u/s. 147 of I.T. Act, 1961 is, therefore

ACIT, CIRCLE-18(2), NOIDA vs. NOIDA TOLL BRIDGE CO. LTD., NOIDA

In the result, appeal of the assessee is allowed

Bench: Shri N.K. Billaiya & Ms. Astha Chandra

reassessment proceedings waiving its right to challenge the same before the Constitutional Courts under writ jurisdiction; the objections of the appellant to assumption of jurisdiction by the Ld. AO. had become infructuous & needs to be given quietus. The challenge posed by the appellant to the assumption of jurisdiction by the Id. AO. u/s. 147 of I.T. Act, 1961 is, therefore

ACIT, CIRCLE-18(2), NOIDA vs. NOIDA TOLL BRIDGE CO. LTD., NOIDA

In the result, appeal of the assessee is allowed

Bench: Shri N.K. Billaiya & Ms. Astha Chandra

reassessment proceedings waiving its right to challenge the same before the Constitutional Courts under writ jurisdiction; the objections of the appellant to assumption of jurisdiction by the Ld. AO. had become infructuous & needs to be given quietus. The challenge posed by the appellant to the assumption of jurisdiction by the Id. AO. u/s. 147 of I.T. Act, 1961 is, therefore

SPORTS & CULTURAL CLUB (REGD),NOIDA vs. JCIT, NOIDA

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

Bench: Shri G.D. Agrawalbefore Shri G.D. Agrawal & And Before Shri Before Shri G.D. Agrawalg.D. Agrawal & And Shri Chandra Mohan Garg Shri Chandra Mohan Gargshri Chandra Mohan Garg Shri Chandra Mohan Garg

15A, Range Range-1, 2 & 3, Range Range 1, 2 & 3, 1, 2 & 3, 1, 2 & 3, Noida. Noida. Noida. Noida. Noida. Noida. Noida. Noida. PAN : AAAJS0280J. PAN : AAAJS0280J. PAN : AAAJS0280J. PAN : AAAJS0280J. (Appellant) (Respondent) Appellant by : Shri Ved Jain, Shri Ashish Chadha and Shri Ashish Goel, CAs. Respondent by : Ms. Paramita Tripathy, CIT-DR. Date of hearing

ADDL. CIT, GHAZIABAD vs. M/S AMRIT CORP LTD., GHAZIABAD

Appeal stand allowed for statistical purposes

Bench: Shri S.V. Mehrotra & Shri Sudhanshu Srivastavaay: 2007-08 Ay: 2008-09

reassessment proceedings, the Hon’ble High Court did hold in Para 33 and 34 of the order as under:- 33. Section 45(2), as referred hereinabove, provides the profit or gain arising from the transfer by way of conversion by the owner of the capital asset into, or its treatment by him as, stock-in- trade of a business carried

ADDL. CIT, GHAZIABAD vs. M/S. AMRIT CORP LTD., GHAZIABAD

Appeal stand allowed for statistical purposes

Bench: Shri S.V. Mehrotra & Shri Sudhanshu Srivastavaay: 2007-08 Ay: 2008-09

reassessment proceedings, the Hon’ble High Court did hold in Para 33 and 34 of the order as under:- 33. Section 45(2), as referred hereinabove, provides the profit or gain arising from the transfer by way of conversion by the owner of the capital asset into, or its treatment by him as, stock-in- trade of a business carried

AMRIT CORP LTD.,GHAZIABAD vs. ADDL. CIT, GHAZIABAD

Appeal stand allowed for statistical purposes

Bench: Shri S.V. Mehrotra & Shri Sudhanshu Srivastavaay: 2007-08 Ay: 2008-09

reassessment proceedings, the Hon’ble High Court did hold in Para 33 and 34 of the order as under:- 33. Section 45(2), as referred hereinabove, provides the profit or gain arising from the transfer by way of conversion by the owner of the capital asset into, or its treatment by him as, stock-in- trade of a business carried

AMRIT CORP LTD.,GHAZIABAD vs. ADDL. CIT, GHAZIABAD

Appeal stand allowed for statistical purposes

Bench: Shri S.V. Mehrotra & Shri Sudhanshu Srivastavaay: 2007-08 Ay: 2008-09

reassessment proceedings, the Hon’ble High Court did hold in Para 33 and 34 of the order as under:- 33. Section 45(2), as referred hereinabove, provides the profit or gain arising from the transfer by way of conversion by the owner of the capital asset into, or its treatment by him as, stock-in- trade of a business carried

SH. RAM KRISHAN GUPTA,HISAR vs. ITO, HISAR

In the result, the appeals of the assessees are allowed

Bench: Sh. N. K. Saini

15A, Ward-2, Hisar Hissar (APPELLANT) (RESPONDENT) PAN No. AFHPP5294F ITA No. 1577/Del/2016 : Asstt. Year : 2010-11 Bhupinder Kumar Bhatia, Vs Income Tax Officer, S/o-Shri Hari Charan Bhatia, Ward-1, H.No.-12A, Tower Enclave, Hissar Delhi Road, Near Vidyut Sadan Hisar (APPELLANT) (RESPONDENT) PAN No. ADRPB0178L ITA Nos. 1574 to 1577, 1580 & 1581/Del/2016 2 Jagdeep, B.S. Boora, K.S. Pannu

BHUPINDER KUMAR BHATIA,HISAR vs. ITO, HISAR

In the result, the appeals of the assessees are allowed

Bench: Sh. N. K. Saini

15A, Ward-2, Hisar Hissar (APPELLANT) (RESPONDENT) PAN No. AFHPP5294F ITA No. 1577/Del/2016 : Asstt. Year : 2010-11 Bhupinder Kumar Bhatia, Vs Income Tax Officer, S/o-Shri Hari Charan Bhatia, Ward-1, H.No.-12A, Tower Enclave, Hissar Delhi Road, Near Vidyut Sadan Hisar (APPELLANT) (RESPONDENT) PAN No. ADRPB0178L ITA Nos. 1574 to 1577, 1580 & 1581/Del/2016 2 Jagdeep, B.S. Boora, K.S. Pannu

SH. B.S. BOORA,HISAR vs. ITO, HISAR

In the result, the appeals of the assessees are allowed

Bench: Sh. N. K. Saini

15A, Ward-2, Hisar Hissar (APPELLANT) (RESPONDENT) PAN No. AFHPP5294F ITA No. 1577/Del/2016 : Asstt. Year : 2010-11 Bhupinder Kumar Bhatia, Vs Income Tax Officer, S/o-Shri Hari Charan Bhatia, Ward-1, H.No.-12A, Tower Enclave, Hissar Delhi Road, Near Vidyut Sadan Hisar (APPELLANT) (RESPONDENT) PAN No. ADRPB0178L ITA Nos. 1574 to 1577, 1580 & 1581/Del/2016 2 Jagdeep, B.S. Boora, K.S. Pannu

SH. JAGDEEP SINGH,HISAR vs. ITO, HISAR

In the result, the appeals of the assessees are allowed

Bench: Sh. N. K. Saini

15A, Ward-2, Hisar Hissar (APPELLANT) (RESPONDENT) PAN No. AFHPP5294F ITA No. 1577/Del/2016 : Asstt. Year : 2010-11 Bhupinder Kumar Bhatia, Vs Income Tax Officer, S/o-Shri Hari Charan Bhatia, Ward-1, H.No.-12A, Tower Enclave, Hissar Delhi Road, Near Vidyut Sadan Hisar (APPELLANT) (RESPONDENT) PAN No. ADRPB0178L ITA Nos. 1574 to 1577, 1580 & 1581/Del/2016 2 Jagdeep, B.S. Boora, K.S. Pannu

SH. K.S. PANNU,HISAR vs. ITO, HISAR

In the result, the appeals of the assessees are allowed

Bench: Sh. N. K. Saini

15A, Ward-2, Hisar Hissar (APPELLANT) (RESPONDENT) PAN No. AFHPP5294F ITA No. 1577/Del/2016 : Asstt. Year : 2010-11 Bhupinder Kumar Bhatia, Vs Income Tax Officer, S/o-Shri Hari Charan Bhatia, Ward-1, H.No.-12A, Tower Enclave, Hissar Delhi Road, Near Vidyut Sadan Hisar (APPELLANT) (RESPONDENT) PAN No. ADRPB0178L ITA Nos. 1574 to 1577, 1580 & 1581/Del/2016 2 Jagdeep, B.S. Boora, K.S. Pannu

SH. KAPOOR SINGH,HISAR vs. ITO, HISAR

In the result, the appeals of the assessees are allowed

Bench: Sh. N. K. Saini

15A, Ward-2, Hisar Hissar (APPELLANT) (RESPONDENT) PAN No. AFHPP5294F ITA No. 1577/Del/2016 : Asstt. Year : 2010-11 Bhupinder Kumar Bhatia, Vs Income Tax Officer, S/o-Shri Hari Charan Bhatia, Ward-1, H.No.-12A, Tower Enclave, Hissar Delhi Road, Near Vidyut Sadan Hisar (APPELLANT) (RESPONDENT) PAN No. ADRPB0178L ITA Nos. 1574 to 1577, 1580 & 1581/Del/2016 2 Jagdeep, B.S. Boora, K.S. Pannu

DRAGON BUILDERS & DEVELOPERS LLP,NEW DELHI vs. ITO WARD - 38(1), NEW DELHI

Bench: Shri Amit Shukla & Shri M. Balaganeshdragon Builders & Developers Llp, Vs. Ito, House No. 1, Back Portion, 3Rd Ward-38(1), Floor, Pocket No. 15A, Sector-24, New Delhi Rohini New Delhi (Appellant) (Respondent) Pan:Aalfd0789L Assessee By : Ms. Mansi Jain, Ca Revenue By: Shri Vivek Kumar Upadhyay, Sr. Dr Date Of Hearing 14/02/2024 Date Of Pronouncement 24/04/2024

15A, Sector-24, New Delhi Rohini New Delhi (Appellant) (Respondent) PAN:AALFD0789L Assessee by : Ms. Mansi Jain, CA Revenue by: Shri Vivek Kumar Upadhyay, Sr. DR Date of Hearing 14/02/2024 Date of pronouncement 24/04/2024 O R D E R PER M. BALAGANESH, A. M.: 1. The appeal in ITA No.1945/Del/2020 for AY 2011-12, arises out of order

ACIT, NEW DELHI vs. SH. AAKASH GOYAL, DELHI

In the result, both the appeal as well as the Cross Objection are

Bench: Shri R.S. Syal & Smt. Beena A. Pillaiassessment Year : 2006-07

15A, New Mandoli Industrial Area, Saboli, Shahdara, Delhi. PAN: AEDPG1868D (Appellant) (Respondent) CO No.139/Del/2018 Assessee By : Shri C.S. Anand, Advocate Department By : Shri S.R. Senapati, Sr. DR Date of Hearing : 01.10.2018 Date of Pronouncement : 01.10.2018 ORDER PER R.S. SYAL, VP: This appeal by the Revenue and the Cross Objection by the assessee are directed against the order dated 30.07.2015 passed

ADIT, DEHRADUN vs. M/S. HALLIBURTON OFFSHORE SERVICES INC., DEHRADUN

Bench: Shri I.C.Sudhir & Shri Prashant Maharishiadit, Halliburton Offshore Services International Taxation, Inc. , Vs. 13-A,Subhash Road, C/O. Nangia & Company, Ca, Aayakar Bhawan, 75/7, Rajpur Road, Dehradun Dehradun Pan:Aaach5154M (Appellant) (Respondent) Halliburton Offshore Services Addl. Cit, Inc. , International Taxation, Vs. C/O. Nangia & Company, Ca, Subhash Road, Suite-4A, Plaza M-6, Jasola, Dehradun New Delhi Pan:Aaach5154M (Appellant) (Respondent) Halliburton Offshore Services Inc. , Adit, C/O. Nangia & Company, Ca, International Taxation, Vs. Suite-4A, Plaza M-6, Jasola, 13-A,Subhash Road, New Delhi Aayakar Bhawan, Pan:Aaach5154M Dehradun (Appellant) (Respondent) Halliburton Offshore Services Inc. Vs Ddit (International Taxation)

Section 40(a)(i), inserted vide Finance Act, 1988 w.e.f. 1.4.89, payment in respect of royalty, fees technical services or other sums chargeable under the Income Tax Act would not get the benefit of deduction if the assessee fails to deduct TAS in respect of payments outside India which are chargeable under the IT. Act. This provision ensures effective compliance