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59 results for “section 68”+ Section 35Aclear

Sorted by relevance

Delhi59Mumbai36Bangalore16Hyderabad10Chennai6Pune5Karnataka5Kolkata4Ahmedabad3Chandigarh2Telangana1Cochin1Jaipur1SC1

Key Topics

Section 143(3)36Addition to Income30Section 14A24Section 144C23Disallowance23Section 92C18Section 144C(13)17Transfer Pricing17Section 26314Section 148

GEO CONVEST LTD vs. DCIT CIRCLE-12 (1),

In the result, appeals filed by the assessee in ITA Nos

ITA 1927/DEL/2008[2002-2003]Status: DisposedITAT Delhi17 Jan 2017AY 2002-2003

Bench: Sh. H.S. Sidhu & Sh. O.P. Kant

Section 143(2)Section 143(3)Section 195Section 271(1)(c)Section 9(1)(vii)

35A to 35E of the Act or cannot be allowed under the provisions of the income tax Act. The assessee is also agreed that on 20/12/2001 the company installed and put to commercial use 50 seats of the call centre and the remaining 92 seats were still under installation/implementation and thus business commenced on 20/12/2001. However, the contention

DCIT CIRCLE-12 (1) vs. GEO CONNECT LTD,

In the result, appeals filed by the assessee in ITA Nos

Showing 1–20 of 59 · Page 1 of 3

13
Deduction11
Comparables/TP11
ITA 2088/DEL/2008[2002-2003]Status: DisposedITAT Delhi17 Jan 2017AY 2002-2003

Bench: Sh. H.S. Sidhu & Sh. O.P. Kant

Section 143(2)Section 143(3)Section 195Section 271(1)(c)Section 9(1)(vii)

35A to 35E of the Act or cannot be allowed under the provisions of the income tax Act. The assessee is also agreed that on 20/12/2001 the company installed and put to commercial use 50 seats of the call centre and the remaining 92 seats were still under installation/implementation and thus business commenced on 20/12/2001. However, the contention

M/S GEO CONNECT LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result, appeals filed by the assessee in ITA Nos

ITA 127/DEL/2011[2003-04]Status: DisposedITAT Delhi17 Jan 2017AY 2003-04

Bench: Sh. H.S. Sidhu & Sh. O.P. Kant

Section 143(2)Section 143(3)Section 195Section 271(1)(c)Section 9(1)(vii)

35A to 35E of the Act or cannot be allowed under the provisions of the income tax Act. The assessee is also agreed that on 20/12/2001 the company installed and put to commercial use 50 seats of the call centre and the remaining 92 seats were still under installation/implementation and thus business commenced on 20/12/2001. However, the contention

ACIT, NEW DELHI vs. M/S. GEO CONNECT LTD., NEW DELHI

In the result, appeals filed by the assessee in ITA Nos

ITA 5851/DEL/2011[2002-03]Status: DisposedITAT Delhi17 Jan 2017AY 2002-03

Bench: Sh. H.S. Sidhu & Sh. O.P. Kant

Section 143(2)Section 143(3)Section 195Section 271(1)(c)Section 9(1)(vii)

35A to 35E of the Act or cannot be allowed under the provisions of the income tax Act. The assessee is also agreed that on 20/12/2001 the company installed and put to commercial use 50 seats of the call centre and the remaining 92 seats were still under installation/implementation and thus business commenced on 20/12/2001. However, the contention

DCIT, NEW DELHI vs. M/S. ALFA BHOJ LTD, NEW DELHI

In the result, the appeal of the assessee is allowed in part for statistical purposes

ITA 1384/DEL/2009[2002-03]Status: DisposedITAT Delhi31 Aug 2018AY 2002-03

Bench: Shri N.K. Billaiya & Shri Kuldip Singh[Assessment Year: 2002-03] The Dy. C.I.T Vs. M/S Alfa Bhoj Ltd Central Circle – 13 4-A, Pusa Road New Delhi New Delhi Pan : Aaaca 1066 F [Assessment Year: 2002-03]

For Appellant: Shri K.R. Manjani, AdvFor Respondent: Smt. Aparna Karan, CIT-DR
Section 142(1)Section 153ASection 245D

35A, First Floor, Rajouri Garden, New Delhi Dinanath Luhaliwala 50,000 5,00,000 28.02.2002 28.02.2002 28.02.2002 Spinning Mills, A- 261, Shastri Nagar, Delhi- 110052 Shatarchi Finance & 2,00,000 20,00,000 28.02.2002 28.02.2002 28.02.2002 Leasing. 196/1, Pck. D-12, Sector-7, Rohini, Delhi Shatarchi Finance & 50,000 5,00,000 30.03.2002 30.03.2002 30.03.2002 Leasing. 196/1

ALFA BHOJ LTD,NEW DELHI vs. DCIT, NEW DELHI

In the result, the appeal of the assessee is allowed in part for statistical purposes

ITA 1057/DEL/2009[2002-03]Status: DisposedITAT Delhi31 Aug 2018AY 2002-03

Bench: Shri N.K. Billaiya & Shri Kuldip Singh[Assessment Year: 2002-03] The Dy. C.I.T Vs. M/S Alfa Bhoj Ltd Central Circle – 13 4-A, Pusa Road New Delhi New Delhi Pan : Aaaca 1066 F [Assessment Year: 2002-03]

For Appellant: Shri K.R. Manjani, AdvFor Respondent: Smt. Aparna Karan, CIT-DR
Section 142(1)Section 153ASection 245D

35A, First Floor, Rajouri Garden, New Delhi Dinanath Luhaliwala 50,000 5,00,000 28.02.2002 28.02.2002 28.02.2002 Spinning Mills, A- 261, Shastri Nagar, Delhi- 110052 Shatarchi Finance & 2,00,000 20,00,000 28.02.2002 28.02.2002 28.02.2002 Leasing. 196/1, Pck. D-12, Sector-7, Rohini, Delhi Shatarchi Finance & 50,000 5,00,000 30.03.2002 30.03.2002 30.03.2002 Leasing. 196/1

MUFG BANK LTD,NEW DELHI vs. ACIT (INTERNATIONAL TAXATION) CIRCLE-2(2)(1), NEW DELHI

In the result appeal of the assessee is partly allowed

ITA 7895/DEL/2019[2015-16]Status: DisposedITAT Delhi16 Oct 2020AY 2015-16

Bench: Shri Amit Shukla & Shri Prashant Maharishi(Through Video Conferencing) Mufg Bank Ltd, Vs. Acit (International Taxation), 5Th Floor, Worldmark 2, Asset 8, Circle-2(2)(1), Aerocity, Nh-8, New Delhi New Delhi Pan: Aabct3880D (Appellant) (Respondent)

For Appellant: Shri Nishant Thakkar, AdvFor Respondent: Shr Surender Pal, CIT DR
Section 143(3)Section 14ASection 244ASection 37(1)Section 44C

35A) of the act. The assessee company has not disallowed the proportionate expenditure incurred on the above income as per the provisions of Section 14 A of the income tax act. The assessee was asked to show cause as to why the disallowance of proportionate expenditure incurred by it not be calculated as per the provisions of Section

M/S. KRISHAK BHARTI COOPERATIVE LTD.,NEW DELHI vs. ACIT, NEW DELHI

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

ITA 2341/DEL/2017[2010-11]Status: DisposedITAT Delhi29 Dec 2021AY 2010-11

Bench: Shri Anil Chaturvedi & Shri Kul Bharat

Section 143(3)Section 14ASection 263

35A and 35B etc. Even in Chapter VI, deductions for set off or carry forward of loss is allowed. Fourthly and lastly, certain deductions were permissible under Chapter VII and Chapter VIII and which had been substantial or partly replaced and were placed under Chapter VIA. These were deductions which were reduced from the income computed in accordance with

ACIT,, NEW DELHI vs. M/S KRISHAK BHARATI COOPERATIVE LTD.,, NEW DELHI

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

ITA 2973/DEL/2017[2011-12]Status: DisposedITAT Delhi29 Dec 2021AY 2011-12

Bench: Shri Anil Chaturvedi & Shri Kul Bharat

Section 143(3)Section 14ASection 263

35A and 35B etc. Even in Chapter VI, deductions for set off or carry forward of loss is allowed. Fourthly and lastly, certain deductions were permissible under Chapter VII and Chapter VIII and which had been substantial or partly replaced and were placed under Chapter VIA. These were deductions which were reduced from the income computed in accordance with

M/S. KRISHAK BHARTI COOPERATIVE LTD.,NEW DELHI vs. ACIT, NEW DELHI

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

ITA 2342/DEL/2017[2011-12]Status: DisposedITAT Delhi29 Dec 2021AY 2011-12

Bench: Shri Anil Chaturvedi & Shri Kul Bharat

Section 143(3)Section 14ASection 263

35A and 35B etc. Even in Chapter VI, deductions for set off or carry forward of loss is allowed. Fourthly and lastly, certain deductions were permissible under Chapter VII and Chapter VIII and which had been substantial or partly replaced and were placed under Chapter VIA. These were deductions which were reduced from the income computed in accordance with

ACIT,, NEW DELHI vs. M/S KRISHAK BHARATI COOPERATIVE LTD.,, NEW DELHI

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

ITA 2972/DEL/2017[2010-11]Status: DisposedITAT Delhi29 Dec 2021AY 2010-11

Bench: Shri Anil Chaturvedi & Shri Kul Bharat

Section 143(3)Section 14ASection 263

35A and 35B etc. Even in Chapter VI, deductions for set off or carry forward of loss is allowed. Fourthly and lastly, certain deductions were permissible under Chapter VII and Chapter VIII and which had been substantial or partly replaced and were placed under Chapter VIA. These were deductions which were reduced from the income computed in accordance with

HERO MOTOCORP LTD.,NEW DELHI vs. DCIT, CIRCLE- 11(1), NEW DELHI

Appeal of the assessee is partly allowed for statistical purpose

ITA 1351/DEL/2018[2009-10]Status: DisposedITAT Delhi23 Apr 2019AY 2009-10

Bench: Shri N. K. Billaiya & Ms Suchitra Kamble

For Appellant: Amount of Proposed international
Section 115JSection 143(3)Section 144C

Section 115JB of the Income Tax Act, 1961. In the present Assessment Year also the facts are similar and are squarely covered with the decision of the Tribunal for A.Ys. 2010-11, 2011-12, 2012-13 and 2013-14. Hence Ground Nos. 15 to 14.3 are allowed. 24. As regards Ground No. 16 to 16.2 is relating to Disallowance

HUMBOLDT WEDAG INDIA PVT. LTD.,NEW DELHI vs. ACIT, CIRCLE-10(1), DELHI

In the result, the appeal of the assesee is allowed

ITA 349/DEL/2022[2017-18]Status: DisposedITAT Delhi27 Apr 2022AY 2017-18

Bench: Shri R.K. Panda & Ms. Astha Chandraasstt. Year : 2017-18

For Appellant: Shri Ajit Jain, AdvocateFor Respondent: Shri Surender Pal, CIT(DR)
Section 143(3)Section 144CSection 253(7)Section 92CSection 92C(2)

35A of Appellate Tribunal Rules, 1963 for stay of recovery of demand of tax and interest amounting to Rs. 6,83,71,320/- pertaining to the assessment year (“AY”) 2017-18. The stay application came up for hearing on 25.02.2022. At the time of hearing the Ld. AR of the assessee explained that the issues involved in the appeal

AMADEUS INDIA PVT. LTD.,NEW DELHI vs. ACIT, CIRCLE- 2(2), NEW DELHI

In the result, ITA NO. 7691/Del/2017 stands allowed

ITA 7691/DEL/2017[2013-14]Status: DisposedITAT Delhi27 Feb 2019AY 2013-14

Bench: Shri N.S. Saini & Shri Sudhanshu Srivastava

For Appellant: Sh. Tarundeep Singh & Tarun Singh, AdvFor Respondent: Shri Sanjay I.Bara, CIT-DR & Sh. Sandeep Kr
Section 144CSection 92BSection 92F

35A March, 2015 Re-characterization of expenses Upheld at Para 64 page 48 of 142 and incurred for own business as a service para 147, page 111 to AE is not justified The burden is on the assessed to select and justify the method adopted and the arm’s length price declared under sub-section (3) to section

AMADEUS INDIA PVT. LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result, ITA NO. 7691/Del/2017 stands allowed

ITA 1662/DEL/2016[2011-12]Status: DisposedITAT Delhi27 Feb 2019AY 2011-12

Bench: Shri N.S. Saini & Shri Sudhanshu Srivastava

For Appellant: Sh. Tarundeep Singh & Tarun Singh, AdvFor Respondent: Shri Sanjay I.Bara, CIT-DR & Sh. Sandeep Kr
Section 144CSection 92BSection 92F

35A March, 2015 Re-characterization of expenses Upheld at Para 64 page 48 of 142 and incurred for own business as a service para 147, page 111 to AE is not justified The burden is on the assessed to select and justify the method adopted and the arm’s length price declared under sub-section (3) to section

AMADEUS INDIA PVT. LTD.,NEW DELHI vs. ACIT, NEW DELHI

In the result, ITA NO. 7691/Del/2017 stands allowed

ITA 1811/DEL/2017[2012-13]Status: DisposedITAT Delhi27 Feb 2019AY 2012-13

Bench: Shri N.S. Saini & Shri Sudhanshu Srivastava

For Appellant: Sh. Tarundeep Singh & Tarun Singh, AdvFor Respondent: Shri Sanjay I.Bara, CIT-DR & Sh. Sandeep Kr
Section 144CSection 92BSection 92F

35A March, 2015 Re-characterization of expenses Upheld at Para 64 page 48 of 142 and incurred for own business as a service para 147, page 111 to AE is not justified The burden is on the assessed to select and justify the method adopted and the arm’s length price declared under sub-section (3) to section

ARGOS HOLDINGS PTE. LTD.,SINGAPORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE INT TAX 1(1)(1), DELHI, DELHI

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

ITA 3633/DEL/2025[2017-18]Status: DisposedITAT Delhi06 Nov 2025AY 2017-18

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.

For Appellant: Shri S.K. Tulsiyan, AdvocateFor Respondent: Shri Saroj Kumar Dubey, CIT DR
Section 144C(5)Section 147Section 148Section 148ASection 151Section 194LSection 1ISection 260Section 6(3)Section 6(3)(ii)

68 (which authorizes the AO to enquire into source of funds of Appellant's lender) was inserted only w.e.f. April 1. 2023 (vide Finance Act, 2022). Ground No.7: That on the facts and circumstances of the cases the Ld. AO erred in law in treating the investment amounting to INR 4,48,00,00,000 made in SVHPL as undisclosed

ARGOS HOLDINGS PTE. LTD.,SINGAPORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE INT TAX 1(1)(1), DELHI, DELHI

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

ITA 3632/DEL/2025[2015-16]Status: DisposedITAT Delhi06 Nov 2025AY 2015-16

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.

For Appellant: Shri S.K. Tulsiyan, AdvocateFor Respondent: Shri Saroj Kumar Dubey, CIT DR
Section 144C(5)Section 147Section 148Section 148ASection 151Section 194LSection 1ISection 260Section 6(3)Section 6(3)(ii)

68 (which authorizes the AO to enquire into source of funds of Appellant's lender) was inserted only w.e.f. April 1. 2023 (vide Finance Act, 2022). Ground No.7: That on the facts and circumstances of the cases the Ld. AO erred in law in treating the investment amounting to INR 4,48,00,00,000 made in SVHPL as undisclosed

DCIT, NEW DELHI vs. M/S. SONY INDIA PVT. LTD., NEW DELHI

In the result, appeal filed by the assessee is partly allowed as indicated above and appeal filed by the revenue is dismissed

ITA 1166/DEL/2015[2010-11]Status: DisposedITAT Delhi30 Aug 2024AY 2010-11

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

For Appellant: Shri Nageshwar Rao, AdvocateFor Respondent: Shri Rajesh Kumar, CIT DR
Section 143Section 143(2)Section 143(3)Section 92C

68,65,15,988/-. 30. Without prejudice to above, that on the facts and circumstances of the case and in law, the Hon'ble DRP /Ld.AO have erred by including ‘advertisement and sales promotion expenses’ and ‘rebates and discounts’ of INR 258,42,17,000 and INR 128,77,05,032 respectively in the allocated expenditure without considering the fact

SONY INDIA PRIVATE LIMITED,NEW DELHI vs. DEPUTY COMMISSIONER OF INCOME-TAX, NEW DELHI

In the result, appeal filed by the assessee is partly allowed as indicated above and appeal filed by the revenue is dismissed

ITA 1026/DEL/2015[2010-11]Status: DisposedITAT Delhi30 Aug 2024AY 2010-11

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

For Appellant: Shri Nageshwar Rao, AdvocateFor Respondent: Shri Rajesh Kumar, CIT DR
Section 143Section 143(2)Section 143(3)Section 92C

68,65,15,988/-. 30. Without prejudice to above, that on the facts and circumstances of the case and in law, the Hon'ble DRP /Ld.AO have erred by including ‘advertisement and sales promotion expenses’ and ‘rebates and discounts’ of INR 258,42,17,000 and INR 128,77,05,032 respectively in the allocated expenditure without considering the fact