MARUTI SUZUKI INDIA LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result, the appeals of the assessee are allowed and the appeals of the revenue are dismissed

Bench: Sh. Amit Shukladr. B. R. R. Kumar(E-Court Module) Ita No. 2553/Del/2013 : Asstt. Year : 1999-00 Maruti Suzuki India Ltd., Vs Commissioner Of Income Tax Plot No. 1, Nelson Mandela Road, (Appeals)-Ix, Income Tax Vasant Kunj, New Delhi-110070 Office, Laxmi Nagar, New Delhi (Appellant) (Respondent) Pan No. Aaacm0829Q Ita No. 2641/Del/2013 : Asstt. Year : 1999-00 Dcit, Vs Maruti Suzuki India Ltd., Circle-6(1), Plot No. 1, Nelson Mandela Road, New Delhi Vasant Kunj, New Delhi-110070 (Appellant) (Respondent) Pan No. Aaacm0829Q Ita No. 468/Del/2014 : Asstt. Year : 1994-95 Maruti Suzuki India Ltd., Vs Jcit(Osd), Plot No. 1, Nelson Mandela Road, Circle-6(1), Vasant Kunj, New Delhi-110070 New Delhi (Appellant) (Respondent) Pan No. Aaacm0829Q

Section 244A(1) is not applicable to the cases (A.Ys. 1999-2000 and 1994-95) before us. The ground no.3 of the assessee is treated as allowed. ITA No. 2641/Del/2013 (Departmental Appeal): 65. The AO did not allow interest to the assessee on the amounts of tax paid on 31.01.2003 and 28.02.2003 on the grounds that a few hours

MARUTI SUZUKI INDIA LTD.,NEW DELHI vs. JCIT (OSD), NEW DELHI

In the result, the appeals of the assessee are allowed and the appeals of the revenue are dismissed

Bench: Sh. Amit Shukladr. B. R. R. Kumar(E-Court Module) Ita No. 2553/Del/2013 : Asstt. Year : 1999-00 Maruti Suzuki India Ltd., Vs Commissioner Of Income Tax Plot No. 1, Nelson Mandela Road, (Appeals)-Ix, Income Tax Vasant Kunj, New Delhi-110070 Office, Laxmi Nagar, New Delhi (Appellant) (Respondent) Pan No. Aaacm0829Q Ita No. 2641/Del/2013 : Asstt. Year : 1999-00 Dcit, Vs Maruti Suzuki India Ltd., Circle-6(1), Plot No. 1, Nelson Mandela Road, New Delhi Vasant Kunj, New Delhi-110070 (Appellant) (Respondent) Pan No. Aaacm0829Q Ita No. 468/Del/2014 : Asstt. Year : 1994-95 Maruti Suzuki India Ltd., Vs Jcit(Osd), Plot No. 1, Nelson Mandela Road, Circle-6(1), Vasant Kunj, New Delhi-110070 New Delhi (Appellant) (Respondent) Pan No. Aaacm0829Q

Section 244A(1) is not applicable to the cases (A.Ys. 1999-2000 and 1994-95) before us. The ground no.3 of the assessee is treated as allowed. ITA No. 2641/Del/2013 (Departmental Appeal): 65. The AO did not allow interest to the assessee on the amounts of tax paid on 31.01.2003 and 28.02.2003 on the grounds that a few hours

DCIT, NEW DELHI vs. M/S MARUTI SUZUKI INDIA LTD.,, NEW DELHI

In the result, the appeals of the assessee are allowed and the appeals of the revenue are dismissed

Bench: Sh. Amit Shukladr. B. R. R. Kumar(E-Court Module) Ita No. 2553/Del/2013 : Asstt. Year : 1999-00 Maruti Suzuki India Ltd., Vs Commissioner Of Income Tax Plot No. 1, Nelson Mandela Road, (Appeals)-Ix, Income Tax Vasant Kunj, New Delhi-110070 Office, Laxmi Nagar, New Delhi (Appellant) (Respondent) Pan No. Aaacm0829Q Ita No. 2641/Del/2013 : Asstt. Year : 1999-00 Dcit, Vs Maruti Suzuki India Ltd., Circle-6(1), Plot No. 1, Nelson Mandela Road, New Delhi Vasant Kunj, New Delhi-110070 (Appellant) (Respondent) Pan No. Aaacm0829Q Ita No. 468/Del/2014 : Asstt. Year : 1994-95 Maruti Suzuki India Ltd., Vs Jcit(Osd), Plot No. 1, Nelson Mandela Road, Circle-6(1), Vasant Kunj, New Delhi-110070 New Delhi (Appellant) (Respondent) Pan No. Aaacm0829Q

Section 244A(1) is not applicable to the cases (A.Ys. 1999-2000 and 1994-95) before us. The ground no.3 of the assessee is treated as allowed. ITA No. 2641/Del/2013 (Departmental Appeal): 65. The AO did not allow interest to the assessee on the amounts of tax paid on 31.01.2003 and 28.02.2003 on the grounds that a few hours

OIL AND NATURAL GAS CORPORATION LTD.,DEHRADUN vs. DCIT, DEHRADUN

Bench: Sh. Amit Shukladr. B. R. R. Kumar(E-Court Module) Ita No. 1434/Del/2017 : Asstt. Year : 1991-92 Oil & Natural Gas Corporation Ltd., Vs Dcit, Deputy General Manager (F&A)-Ctd, Circle-1, Corporate Tax Division, Room No. Dehradun-248001 244, Old Secretariat Building, Tel Bhawan, Dehradun-248003 (Appellant) (Respondent) Pan No. Aaaco1598A Assessee By : Sh. Ajay Vohra, Sr. Adv. Revenue By : Ms. Pramita M. Biswas, Cit Dr Date Of Hearing: 23.06.2020 Date Of Pronouncement: 28.09.2020

section 244A of the Act on short refund of interest of Rs. 29,68,87,603/- granted on 30.09.2002 (date

INSILCO LIMITED,GURGAON vs. ACIT, NEW DELHI

Appeal is allowed

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

section 244A of the Act, whereas, it was neither the subject matter of appeal before him nor he had power under law to set up a new case and set aside the order u/s 251 of the Act. 5. That the order passed by CIT(A) is void, bad unjustified, against the provision of law and without giving

MARUTI SUZUKI INDIA LTD.,NEW DELHI vs. JCIT (OSD), NEW DELHI

In the result, appeals filed by Revenue are dismissed and appeals filed by

Bench: Shri Sudhanshu Srivastava & Shri Anadee Nath Misshra

Section 244A of I.T. Act for the full Page 5 of 10 ITA Nos.- 469/Del/2014 and others. Maruti Suzuki India Ltd. month even if tax is paid by the assessee on the last day of the month. Vide ITA Nos. 600/Del/2014, 601/Del/2014 and 602/Del/2014 for Assessment Years 1995-96, 1996- 97, and 1997-98 respectively filed by Revenue against

MARUTI SUZUKI INDIA LTD.,NEW DELHI vs. JCIT (OSD), NEW DELHI

In the result, appeals filed by Revenue are dismissed and appeals filed by

Bench: Shri Sudhanshu Srivastava & Shri Anadee Nath Misshra

Section 244A of I.T. Act for the full Page 5 of 10 ITA Nos.- 469/Del/2014 and others. Maruti Suzuki India Ltd. month even if tax is paid by the assessee on the last day of the month. Vide ITA Nos. 600/Del/2014, 601/Del/2014 and 602/Del/2014 for Assessment Years 1995-96, 1996- 97, and 1997-98 respectively filed by Revenue against

DCIT, NEW DELHI vs. M/S. MARUTI SUZUKI INDIA LTD., NEW DELHI

In the result, appeals filed by Revenue are dismissed and appeals filed by

Bench: Shri Sudhanshu Srivastava & Shri Anadee Nath Misshra

Section 244A of I.T. Act for the full Page 5 of 10 ITA Nos.- 469/Del/2014 and others. Maruti Suzuki India Ltd. month even if tax is paid by the assessee on the last day of the month. Vide ITA Nos. 600/Del/2014, 601/Del/2014 and 602/Del/2014 for Assessment Years 1995-96, 1996- 97, and 1997-98 respectively filed by Revenue against

DCIT, NEW DELHI vs. M/S. MARUTI SUZUKI INDIA LTD., NEW DELHI

In the result, appeals filed by Revenue are dismissed and appeals filed by

Bench: Shri Sudhanshu Srivastava & Shri Anadee Nath Misshra

Section 244A of I.T. Act for the full Page 5 of 10 ITA Nos.- 469/Del/2014 and others. Maruti Suzuki India Ltd. month even if tax is paid by the assessee on the last day of the month. Vide ITA Nos. 600/Del/2014, 601/Del/2014 and 602/Del/2014 for Assessment Years 1995-96, 1996- 97, and 1997-98 respectively filed by Revenue against

MARUTI SUZUKI INDIA LTD.,NEW DELHI vs. JCIT (OSD), NEW DELHI

In the result, appeals filed by Revenue are dismissed and appeals filed by

Bench: Shri Sudhanshu Srivastava & Shri Anadee Nath Misshra

Section 244A of I.T. Act for the full Page 5 of 10 ITA Nos.- 469/Del/2014 and others. Maruti Suzuki India Ltd. month even if tax is paid by the assessee on the last day of the month. Vide ITA Nos. 600/Del/2014, 601/Del/2014 and 602/Del/2014 for Assessment Years 1995-96, 1996- 97, and 1997-98 respectively filed by Revenue against

SUKH DARSHAN SINGH,DELHI vs. ITO WARD.43(2) , DELHI

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

Bench: SHRI S.RIFAUR RAHMAN (Accountant Member)

Section 271 for initiating penalty u/s 271(1)(c) of the Income Tax Act, 1961 for concealing/furnishing inaccurate particulars of income Give credit of pre-paid taxes. Charge interest u/s 234A/234B/234C/234D and withdraw interest u/s 244A, if allowed earlier, as per provisions of the Income Tax Act, 1961. Issue a copy of this order to the assessee.” 4. With

INSILCO LIMITED vs. COMMISSIONER OF INCOME TAX-IV NEW DELHI

Bench: It?

68 ITR 670(SC). The assessing officer in order to rectify the mistake of non- withdrawal of TDS credit in assessment year 1992-93 in order to rectify the mistake of non-withdrawal of TDS credit in assessment year 1992-93 in the order passed under section 254/143(3) on 25.02.2004, passed order under section 154 on 28th

M/S ACCESSION BUILDWELL PRIVATE LIMITED,NEW DELHI vs. DCIT, NEW DELHI

In the result, the appeal of the assesee is treated as allowed

Bench: Shri Anil Chaturvedi & Ms. Astha Chandraasstt. Year: 2012-13 Accession Buildwell Private Limited Vs. Dcit Ece House, 28, K.G. Marg, Circle-1(2), New Delhi -110 001 New Delhi. Pan (Appellant) (Respondent)

68,256/- on account of interest under section 244A of the Act which has been confirmed by the Ld. CIT(A). The Ld. AO noticed

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

68 taxmann.com 143 wherein the Hon’ble Court held as under: “29. Having stated the above, we must clarify that the income falling within Section 115A(1)(b) the Act which does not fall within the four corners of Section 44DA(1) of the Act would also no taxable under Section 4488(1) of four corners

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

68 taxmann.com 143 wherein the Hon’ble Court held as under: “29. Having stated the above, we must clarify that the income falling within Section 115A(1)(b) the Act which does not fall within the four corners of Section 44DA(1) of the Act would also no taxable under Section 4488(1) of four corners

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

68 taxmann.com 143 wherein the Hon’ble Court held as under: “29. Having stated the above, we must clarify that the income falling within Section 115A(1)(b) the Act which does not fall within the four corners of Section 44DA(1) of the Act would also no taxable under Section 4488(1) of four corners

AT & T COMMUNICATION SERVICES INDIA PVT. LTD.,GURGAON vs. ACIT, NEW DELHI

Appeal stands dismissed

Bench: Shri R.K. Panda & Shri Sudhanshu Srivastavaassessment Year: 2008-09 At&T Communication Services Acit, India Pvt. Ltd., Circle-3(2), Vatika Triangle, 3Rd Floor, New Delhi. Vs Sushant Lok-1, Block-A, Gurgaon-122002 (Pan: Aacca8033E) Appellant Respondent Assessment Year: 2008-09 Acit, At&T Communication Services Circle-3(2), India Pvt. Ltd., Room No. 380B, Mohan Dev House, Vs Dc.R. Building, 13, Tolstoy Marg, I.P. Estate, New Delhi-110001 New Delhi. (Pan: Aacca8033E) Appellant Respondent

68,83,113 Addition on account of year end provisons 2.2 Prior to the passing of the final assessment order, since the assessee had entered into international transaction, a reference was made to the Transfer Pricing Officer (TPO) wherein the TPO had recommended an adjustment of Rs. 1,53,55,412/- with reference to the international transaction entered into

ACIT, NEW DELHI vs. M/S. AT & T COMMUNICATION SERVICES INDIA PVT. LTD., NEW DELHI

Appeal stands dismissed

Bench: Shri R.K. Panda & Shri Sudhanshu Srivastavaassessment Year: 2008-09 At&T Communication Services Acit, India Pvt. Ltd., Circle-3(2), Vatika Triangle, 3Rd Floor, New Delhi. Vs Sushant Lok-1, Block-A, Gurgaon-122002 (Pan: Aacca8033E) Appellant Respondent Assessment Year: 2008-09 Acit, At&T Communication Services Circle-3(2), India Pvt. Ltd., Room No. 380B, Mohan Dev House, Vs Dc.R. Building, 13, Tolstoy Marg, I.P. Estate, New Delhi-110001 New Delhi. (Pan: Aacca8033E) Appellant Respondent

68,83,113 Addition on account of year end provisons 2.2 Prior to the passing of the final assessment order, since the assessee had entered into international transaction, a reference was made to the Transfer Pricing Officer (TPO) wherein the TPO had recommended an adjustment of Rs. 1,53,55,412/- with reference to the international transaction entered into

AT & T GLOBAL NETWORK SERVICES (I) PVT LTD,GURGAON vs. ACIT, NEW DELHI

In the result appeal of the assessee in ITA No 1059/Del/2015 is partly allowed

Bench: Shri I. C. Sudhir & Shri Prashant Maharishiat & T Global Network Services Dcit, (India) Pvt Ltd., Circle-2(1), Vs. Vatika Lok-1, Block-A, Gurgaon New Delhi Pan:Aafca8810L (Appellant) (Respondent) Dcit, At & T Global Network Services Circle-2(1), (India) Pvt Ltd., Vs. New Delhi Vatika Lok-1, Block-A, Gurgaon Pan:Aafca8810L (Appellant) (Respondent)

244A of the Act. 9. Ground No. 9 - Initiation of penalty proceedings 9.1 On the facts and circumstances of the case and in law, the learned AO has erred in initiating penalty proceedings under section 271(l)(c) of the Act against the Appellant on account of the above adjustments made in the assessment order