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

3, 2009 further clarified as to what the judgment meant. “Delay condoned in S.L.P.(C) No...CC 10437/2009. Leave granted. In income tax matters, it is well settled that if the question is not properly framed, then, at times, confusion arises resulting in wrong answers. The present batch of Civil Appeals is an illustration of the proposition mentioned herein-above

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

3, 2009 further clarified as to what the judgment meant. “Delay condoned in S.L.P.(C) No...CC 10437/2009. Leave granted. In income tax matters, it is well settled that if the question is not properly framed, then, at times, confusion arises resulting in wrong answers. The present batch of Civil Appeals is an illustration of the proposition mentioned herein-above

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

3, 2009 further clarified as to what the judgment meant. “Delay condoned in S.L.P.(C) No...CC 10437/2009. Leave granted. In income tax matters, it is well settled that if the question is not properly framed, then, at times, confusion arises resulting in wrong answers. The present batch of Civil Appeals is an illustration of the proposition mentioned herein-above

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

244A, the provisions of the fourth proviso shall apply accordingly.] Explanation 2.— For the purposes of this section, where, by an order referred to in clause (i) of sub-section (6),— (a) any income is excluded from the total income of the assessee for an assessment year, then, an assessment of such income for Digitally Signed By:KAMLESH

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

244A, the provisions of the fourth proviso shall apply accordingly.] Explanation 2.— For the purposes of this section, where, by an order referred to in clause (i) of sub-section (6),— (a) any income is excluded from the total income of the assessee for an assessment year, then, an assessment of such income for Digitally Signed By:KAMLESH

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

244A, the provisions of the fourth proviso shall apply accordingly.] Explanation 2.— For the purposes of this section, where, by an order referred to in clause (i) of sub-section (6),— (a) any income is excluded from the total income of the assessee for an assessment year, then, an assessment of such income for Digitally Signed By:KAMLESH

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(1)(b) amounting to Rs.156,25,56,450/- had been granted to it whereas interest on tax till 27.09.2002 comes to Rs. 185,94,44,075. It was also contended by the assessee that interest u/s 244A(1)(b) on amount of refund of Rs.16,27,64,646 (from 16.02.2010 to 19.07.2011), Rs.255,85,61,853/- (from

INSILCO LIMITED,GURGAON vs. ACIT, NEW DELHI

Appeal is allowed

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

3. That the CIT(A) erred in not considering and discussing submissions made by the appellant before him I regard to validity of order dated 24- 12-2005 passed by the AO u/s 154 of the Act. 4. Without prejudice to grounds herein above, the C1T(A) also erred in directing the Assessing Officer to examine applicability of sub-section

PROVIDENT INV. & INDUSTRIES (P) LTD.,NEW DELHI vs. ITO, NEW DELHI

In the result ground No. 5 of the appeal of the assessee is dismissed

Bench: Shri H.S.Sidhu & Shri Prashant Maharishiprovident Inv & Industries P Ltd, Vs. Ito, Ward-14(2), 4Th Floor, Ito, A-49, Mohan Cooperative Industrial Estate, Mathura Road, New Delhi Cr Building, New Delhi Pan:Aabcj4816P (Appellant) (Respondent)

244A, this proviso shall also apply accordingly. Explanation 2.— Where, by an order referred to in clause (ii) of sub-section (3), any income is excluded from the total income of the assessee for an assessment year, then, an assessment of such income for another assessment year shall, for the purposes of section 150 and this section

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

TURNER BROADCASTING SYSTEM ASIA PACIFIC INC.,NEW DELHI vs. DCIT (INTERNATIONAL TAXATION), NEW DELHI

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

Bench: Shri Amit Shukla & Shri B.R.R. Kumar

244A of the Act. 6. That on the facts and circumstances of the case and in law, the Ld.AO erred in initiating penalty proceedings under Section 271(1)(c) of the Act. Grounds of Appeal for AY 2012-13 1. That on the facts and circumstances of the case and in law, the impugned assessment order passed

TURNER BROADCASTING SYSTEM ASIA PACIFIC INC.,NEW DELHI vs. DCIT (INTERNATIONAL TAXATION), NEW DELHI

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

Bench: Shri Amit Shukla & Shri B.R.R. Kumar

244A of the Act. 6. That on the facts and circumstances of the case and in law, the Ld.AO erred in initiating penalty proceedings under Section 271(1)(c) of the Act. Grounds of Appeal for AY 2012-13 1. That on the facts and circumstances of the case and in law, the impugned assessment order passed

TURNER BROADCASTING SYSTEM ASIA PACIFIC, INC.,NEW DELHI vs. DCIT, NEW DELHI

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

Bench: Shri Amit Shukla & Shri B.R.R. Kumar

244A of the Act. 6. That on the facts and circumstances of the case and in law, the Ld.AO erred in initiating penalty proceedings under Section 271(1)(c) of the Act. Grounds of Appeal for AY 2012-13 1. That on the facts and circumstances of the case and in law, the impugned assessment order passed

TURNER BROADCASTING SYSTEMASIA PACIFIC, INC.,NEW DELHI vs. DDIT, NEW DELHI

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

Bench: Shri Amit Shukla & Shri B.R.R. Kumar

244A of the Act. 6. That on the facts and circumstances of the case and in law, the Ld.AO erred in initiating penalty proceedings under Section 271(1)(c) of the Act. Grounds of Appeal for AY 2012-13 1. That on the facts and circumstances of the case and in law, the impugned assessment order 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

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

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

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

3. Whether on the facts and circumstances of the case & in law, the Ld. CIT(A) erred in directing the A.O. to allow interest u/s 244A to the assessee for the month in which payments /adjustments were made on the last day of the month? 4. Whether on the facts and circumstances of the case

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

3. Whether on the facts and circumstances of the case & in law, the Ld. CIT(A) erred in directing the A.O. to allow interest u/s 244A to the assessee for the month in which payments /adjustments were made on the last day of the month? 4. Whether on the facts and circumstances of the case