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

270A of the Act, thereby resulting in violation of mandatory provisions of section 144C of the Act. 16 PCIT vs Wickwood Development Limited ITA 451/2024 2008-09  The assessee is company incorporated in BVI on 13.05.1991.  A search and seizure operations under section 132 of the Act was conducted on 22.03.2012 in M/s Focus Energy group.  Thereafter, a notice under

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

270A of the Act, thereby resulting in violation of mandatory provisions of section 144C of the Act. 16 PCIT vs Wickwood Development Limited ITA 451/2024 2008-09  The assessee is company incorporated in BVI on 13.05.1991.  A search and seizure operations under section 132 of the Act was conducted on 22.03.2012 in M/s Focus Energy group.  Thereafter, a notice under

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

270A of the Act, thereby resulting in violation of mandatory provisions of section 144C of the Act. 16 PCIT vs Wickwood Development Limited ITA 451/2024 2008-09  The assessee is company incorporated in BVI on 13.05.1991.  A search and seizure operations under section 132 of the Act was conducted on 22.03.2012 in M/s Focus Energy group.  Thereafter, a notice under

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

147 of the Act. The Ld. CIT (A) also held 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

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

147 of the Act. The Ld. CIT (A) also held 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

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

147 of the Act. The Ld. CIT (A) also held 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

BOOKING.COM B.V.,THE NETHERLANDS vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE 1(1)(2), INTERNATIONAL TAXATION, DELHI

In the result, the appeal of the assessee is allowed

Bench: Shri M Balaganesh & Shri Vimal Kumarbooking.Com B.V. Vs. Acit, Circle -1(1)(2) Oosterdokskade 163, International Taxation, 1011 Dl, Amsterdam, The Civic Centre, Minto Road, Netherlands, New Delhi – 110002 Haryana 122002 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aagcb2395A Appellant .. Respondent

U/s 148A/148/147 have been wrongly initiated. 4. On considering the replies ld. AO passed draft assessment order dated 29.03.2024. The assessee filed objections to the draft assessment order on 26.04.2024 before ld. DRP under Section 144C(5) of the Act. Through, order dated 31.12.2024 DRP-1, New Delhi, rejected objections of the assessee and P a g e | 6 Booking.com

SMS GROUP GMBH,NEW DELHI vs. ACIT CIRCLE - 3(1)(2) INTL. TAXATION, NEW DELHI

In the result, the appeal of the assessee in ITA No

Bench: Shri M. Balaganesh & Shri Vimal Kumar

147 of the Act. 10.2 I have also gone through copies of invoices pertaining to receipts from Jindal Steel and Power Ltd. and it is seen that receipt of 949,600 Euro (Rs. 5,27,63,546) pertains to supply of equipment for an Electric Arc Furnace. The other two receipts of 235,000 and 30,600 Euros amounting

SMS GROUP GMBH,NEW DELHI vs. ACIT, CIRCLE-3(1)(2) INT. TAXATION, NEW DELHI

In the result, the appeal of the assessee in ITA No

Bench: Shri M. Balaganesh & Shri Vimal Kumar

147 of the Act. 10.2 I have also gone through copies of invoices pertaining to receipts from Jindal Steel and Power Ltd. and it is seen that receipt of 949,600 Euro (Rs. 5,27,63,546) pertains to supply of equipment for an Electric Arc Furnace. The other two receipts of 235,000 and 30,600 Euros amounting

SMS GROUP GMBH,NEW DELHI vs. ACIT, CIRCLE 3(1)(2), INTERNATIONAL TXATION, NEW DELHI

In the result, the appeal of the assessee in ITA No

Bench: Shri M. Balaganesh & Shri Vimal Kumar

147 of the Act. 10.2 I have also gone through copies of invoices pertaining to receipts from Jindal Steel and Power Ltd. and it is seen that receipt of 949,600 Euro (Rs. 5,27,63,546) pertains to supply of equipment for an Electric Arc Furnace. The other two receipts of 235,000 and 30,600 Euros amounting

SMS GROUP GMBH,DELHI vs. ACIT.CIRCLE-3(1)(2), NEW DELHI

In the result, the appeal of the assessee in ITA No

Bench: Shri M. Balaganesh & Shri Vimal Kumar

147 of the Act. 10.2 I have also gone through copies of invoices pertaining to receipts from Jindal Steel and Power Ltd. and it is seen that receipt of 949,600 Euro (Rs. 5,27,63,546) pertains to supply of equipment for an Electric Arc Furnace. The other two receipts of 235,000 and 30,600 Euros amounting

SMS GROUP GMBH,NEW DELHI vs. ACIT, CIRCLE-3(1)(2), INT. TAXATION, NEW DELHI

In the result, the appeal of the assessee in ITA No

Bench: Shri M. Balaganesh & Shri Vimal Kumar

147 of the Act. 10.2 I have also gone through copies of invoices pertaining to receipts from Jindal Steel and Power Ltd. and it is seen that receipt of 949,600 Euro (Rs. 5,27,63,546) pertains to supply of equipment for an Electric Arc Furnace. The other two receipts of 235,000 and 30,600 Euros amounting

COMPAREX INDIA P.LTD,NEW DELHI vs. ITO, CIRCLE-4(2), NEW DELHI

In the result, the appeal filed by the assessee is partly allowed

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

270A of the Act in the final assessment order passed for relevant AY.” 5. Further, assessee filed following additional grounds of appeal with the application under Rule 11 of the ITAT Rules, 1962:- “Pertaining to Transfer Pricing matters 16. On facts and circumstances of the case and in law, the Ld. AO erred by not passing the final assessment order

M/S. HOUSING AND URBAN DEVELOPMENT CORPORATION LTD.(HUDCO),NEW DELHI vs. DCIT, NEW DELHI

Appeals of the assessee stands allowed

Bench: Shri R.K. Panda & Shri Sudhanshu Srivastava

147 of the Income Tax Act, 1961] 11. It may be that in a given case and in most cases it is so done a notice proposing the revisional exercise is given to the assessee indicating therein broadly or even specifically the grounds on which the exercise is felt necessary. But there is nothing in the Section (Section

M/S. HOUSING AND URBAN DEVELOPMENT CORPORATION LTD.(HUDCO),NEW DELHI vs. DCIT, NEW DELHI

Appeals of the assessee stands allowed

Bench: Shri R.K. Panda & Shri Sudhanshu Srivastava

147 of the Income Tax Act, 1961] 11. It may be that in a given case and in most cases it is so done a notice proposing the revisional exercise is given to the assessee indicating therein broadly or even specifically the grounds on which the exercise is felt necessary. But there is nothing in the Section (Section

M/S. HOUSING AND URBAN DEVELOPMENT CORPORATION LTD.(HUDCO),NEW DELHI vs. DCIT, NEW DELHI

Appeals of the assessee stands allowed

Bench: Shri R.K. Panda & Shri Sudhanshu Srivastava

147 of the Income Tax Act, 1961] 11. It may be that in a given case and in most cases it is so done a notice proposing the revisional exercise is given to the assessee indicating therein broadly or even specifically the grounds on which the exercise is felt necessary. But there is nothing in the Section (Section

HOUSING & URBAN DEVELOPMENT CORPORATION LTD.,NEW DELHI vs. DCIT, NEW DELHI

Appeals of the assessee stands allowed

Bench: Shri R.K. Panda & Shri Sudhanshu Srivastava

147 of the Income Tax Act, 1961] 11. It may be that in a given case and in most cases it is so done a notice proposing the revisional exercise is given to the assessee indicating therein broadly or even specifically the grounds on which the exercise is felt necessary. But there is nothing in the Section (Section

AEP INVESTMENTS (MAURITIUS) LIMITED,MAURITIUS vs. ACIT CIRCLE INTL. TAXATION 1(1)(1), NEW DELHI

In the result, the appeal of the assessee is allowed

Bench: Shri Kul Bharat & Dr. B. R. R. Kumar

9. That on the facts and in the circumstances of the case, the assessing officer has erred in initiating penalty proceedings under section 270A of the Act. 10. That on the facts and in the circumstances of the case, the assessing officer has erred in initiating penalty proceedings under section 271F of the Act. 3 AEP Investments (Mauritius