IMSI INDIA PVT. LTD.,NEW DELHI vs. ACIT, DEHRADUN

In the result, the appeals of the assessee are allowed

Bench: Sh. N. K. Saini, Am & Ms. Suchitra Kamble, Jm Ita No. 5856/Del/2011 : Asstt. Year : 2007-08 Ita No. 4277/Del/2012 : Asstt. Year : 2008-09 Ita No. 5744/Del/2012 : Asstt. Year : 2009-10 Ita No. 2506/Del/2013 : Asstt. Year : 2010-11 Imsi India Pvt. Ltd., Vs Deputy/Assistant Commissioner C/O Luthra & Luthra Law Offices, Of Income Tax, Circle-2, 103, Ashoka Estate, Barakhamba Dehradun, Uttranchal Road, New Delhi-110001 (Appellant) (Respondent) Pan No. Aabci1797A Assessee By : Sh. Ashwani Kumar, Sh. Sudhindra Jain & Sh. Alok Kumar Jain, Cas Revenue By : Sh. Amrit Lal, Sr. Dr Date Of Hearing : 15.09.2017 Date Of Pronouncement : 27.10.2017 Order Per N. K. Saini, Am: This Appeal By The Assessee For The Assessment Year 2007- 08 Is Directed Against The Order Dated 03.10.2011 Of Ld. Cit(A)-Ii, Dehradun & The Other Appeals Of The Assessee Are Directed Against The Separate Orders Dated 09.02.2012, 20.12.2011 & 30.11.2012 Passed By The Ld. Cit(A)-I, Dehradun For The Assessment Years 2008-09, 2009-10 & 2010-11 Respectively. 2. Since The Issue Involved Is Common In All These Appeals Which Were Heard Together So These Are Being Disposed Off By This Consolidated Order For The Sake Of Convenience & Brevity.

801C should he interpreted widely to include in its ambit all services related to ITC industry, whether provided/consumed within Uttarakhand or outside. It would be appreciated that service providers in the ICT industry are required to provide both onsite and offsite services, depending upon the nature of the projects and the requirements of the client. The projects on which

IMSI INDIA PVT. LTD.,NEW DELHI vs. DCIT, DEHRADUN

In the result, the appeals of the assessee are allowed

Bench: Sh. N. K. Saini, Am & Ms. Suchitra Kamble, Jm Ita No. 5856/Del/2011 : Asstt. Year : 2007-08 Ita No. 4277/Del/2012 : Asstt. Year : 2008-09 Ita No. 5744/Del/2012 : Asstt. Year : 2009-10 Ita No. 2506/Del/2013 : Asstt. Year : 2010-11 Imsi India Pvt. Ltd., Vs Deputy/Assistant Commissioner C/O Luthra & Luthra Law Offices, Of Income Tax, Circle-2, 103, Ashoka Estate, Barakhamba Dehradun, Uttranchal Road, New Delhi-110001 (Appellant) (Respondent) Pan No. Aabci1797A Assessee By : Sh. Ashwani Kumar, Sh. Sudhindra Jain & Sh. Alok Kumar Jain, Cas Revenue By : Sh. Amrit Lal, Sr. Dr Date Of Hearing : 15.09.2017 Date Of Pronouncement : 27.10.2017 Order Per N. K. Saini, Am: This Appeal By The Assessee For The Assessment Year 2007- 08 Is Directed Against The Order Dated 03.10.2011 Of Ld. Cit(A)-Ii, Dehradun & The Other Appeals Of The Assessee Are Directed Against The Separate Orders Dated 09.02.2012, 20.12.2011 & 30.11.2012 Passed By The Ld. Cit(A)-I, Dehradun For The Assessment Years 2008-09, 2009-10 & 2010-11 Respectively. 2. Since The Issue Involved Is Common In All These Appeals Which Were Heard Together So These Are Being Disposed Off By This Consolidated Order For The Sake Of Convenience & Brevity.

801C should he interpreted widely to include in its ambit all services related to ITC industry, whether provided/consumed within Uttarakhand or outside. It would be appreciated that service providers in the ICT industry are required to provide both onsite and offsite services, depending upon the nature of the projects and the requirements of the client. The projects on which

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

Appeal of the assessee is partly allowed for statistical purpose

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

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

DCIT, NEW DELHI vs. M/S DHARAMPAL SATYAPAL LTD.,, DELHI

Bench: Shri H. S. Sidhu & Shri Prashant Maharishi

801C. 8. Whether on facts & in circumstances of case, Ld. CIT(A) has erred in ^ law & on facts in deleting addition of Rs. 19,34,839/- made by AO on account of prior period expenses. Dharampal Satyapal Ltd Vs, DCIT ITA No. 3738, 3739/Del/2016 (A) & ITA No. 3882 & 3883/Del/2016(R) Assessment Year: 2010-11 & 2011-12 9. Whether on facts

JCIT SPL. RANGE-12, NEW DELHI vs. ARIHANTA INDUSTRIES, DELHI

In the result, both the appeals of the Revenue are allowed

Bench: Sh. Saktijit Deydr. B. R. R. Kumar

801C for profits derived from manufacturing activity were found to be entirely bogus. 6. The Ld. CIT(A) erred in law by not considering the facts that the during the assessment proceedings, the AO issued summons u/s 131 of the Act to sales parties in order to get confirmations and to substantiate the genuineness of the transactions but all remain

M/S. DHARAMPAL SATYAPAL LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result, the appeal of the assessee is allowed and the appeal of the revenue is dismissed

Bench: Shri A.T. Varkey & Shri Prashant Maharishi

b) Ld. CIT(A) has erred in confirming the action of Ld. AO in loading of manufacturing expenses at the estimated rate of 37.85% and charging of profit margin @ 10% on the amount of goods called Kathha (Catechu) which gets processed through job worker and not allowing the deduction u/s 801B/801C in this regard. (c) Ld. CIT(A) has erred

DCIT, NEW DELHI vs. M/S. DHARAMPAL SATYAPAL LTD., DELHI

In the result, the appeal of the assessee is allowed and the appeal of the revenue is dismissed

Bench: Shri A.T. Varkey & Shri Prashant Maharishi

b) Ld. CIT(A) has erred in confirming the action of Ld. AO in loading of manufacturing expenses at the estimated rate of 37.85% and charging of profit margin @ 10% on the amount of goods called Kathha (Catechu) which gets processed through job worker and not allowing the deduction u/s 801B/801C in this regard. (c) Ld. CIT(A) has erred

DCIT, CENTRAL CIRCLE-20, DELHI vs. LOTUS HERBALS PVT. LTD, DELHI

In the result, appeal of the Revenue in appeal No

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

68 taxmann.com 410 (Delhi-Trib.) - M/s LalsonsJewellers Ltd. v. ACTT ITA No.5241/Del/2004 (Del) In view of above, the assesse had discharged its onus establishing genuineness of AMP expenses and even the parties to whom notice(s) were served under section 133(6) had also furnished its reply and the AO has failed to point out discrepancy in the documents

DCIT, CC-20, DELHI vs. LOTUS HERBALS PVT. LTD., DELHI

In the result, appeal of the Revenue in appeal No

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

68 taxmann.com 410 (Delhi-Trib.) - M/s LalsonsJewellers Ltd. v. ACTT ITA No.5241/Del/2004 (Del) In view of above, the assesse had discharged its onus establishing genuineness of AMP expenses and even the parties to whom notice(s) were served under section 133(6) had also furnished its reply and the AO has failed to point out discrepancy in the documents

DCIT, CC-20, DELHI vs. LOTUS HERBALS PVT. LTD., DELHI

In the result, appeal of the Revenue in appeal No

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

68 taxmann.com 410 (Delhi-Trib.) - M/s LalsonsJewellers Ltd. v. ACTT ITA No.5241/Del/2004 (Del) In view of above, the assesse had discharged its onus establishing genuineness of AMP expenses and even the parties to whom notice(s) were served under section 133(6) had also furnished its reply and the AO has failed to point out discrepancy in the documents

DCIT, CC-20, DELHI vs. LOTUS HERBALS PVT. LTD., DELHI

In the result, appeal of the Revenue in appeal No

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

68 taxmann.com 410 (Delhi-Trib.) - M/s LalsonsJewellers Ltd. v. ACTT ITA No.5241/Del/2004 (Del) In view of above, the assesse had discharged its onus establishing genuineness of AMP expenses and even the parties to whom notice(s) were served under section 133(6) had also furnished its reply and the AO has failed to point out discrepancy in the documents

DCIT, CENTRAL CIRCLE-20, NEW DELHI vs. LOTUS HERBALS P.LTD, DELHI

In the result, appeal of the Revenue in appeal No

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

68 taxmann.com 410 (Delhi-Trib.) - M/s LalsonsJewellers Ltd. v. ACTT ITA No.5241/Del/2004 (Del) In view of above, the assesse had discharged its onus establishing genuineness of AMP expenses and even the parties to whom notice(s) were served under section 133(6) had also furnished its reply and the AO has failed to point out discrepancy in the documents

COSMIC INFORMATICS PVT. LTD.,NEW DELHI vs. ACIT CENTRAL CIRCLE - 2, NEW DELHI

In the result, appeal of the Revenue in appeal No

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

68 taxmann.com 410 (Delhi-Trib.) - M/s LalsonsJewellers Ltd. v. ACTT ITA No.5241/Del/2004 (Del) In view of above, the assesse had discharged its onus establishing genuineness of AMP expenses and even the parties to whom notice(s) were served under section 133(6) had also furnished its reply and the AO has failed to point out discrepancy in the documents

COSMIC INFORMATICS PVT. LTD.,NEW DELHI vs. ACIT CENTRAL CIRCLE - 2, NEW DELHI

In the result, appeal of the Revenue in appeal No

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

68 taxmann.com 410 (Delhi-Trib.) - M/s LalsonsJewellers Ltd. v. ACTT ITA No.5241/Del/2004 (Del) In view of above, the assesse had discharged its onus establishing genuineness of AMP expenses and even the parties to whom notice(s) were served under section 133(6) had also furnished its reply and the AO has failed to point out discrepancy in the documents

RALLISON ELECTRICALS PVT. LTD.,NEW DELHI vs. ADDL. CIT, NEW DELHI

Appeals of the assessee are partly allowed and that of the Department is dismissed

Bench: Shri I. C. Sudhir & Shri O. P. Kant

68,080/- on apportionment of expenses including that of depreciation on the basis of manufacturing turnover of Baddi unit to gross manufacturing turnover of all manufacturing units including Baddi unit. c) That the Learned CIT (Appeals) has grossly erred in confirming the estimated reduction of Rs.27,34,294/- from the profits of the Baddi unit eligible for deduction under section

M/S. RANA BAR P. LTD.,NEW DELHI vs. ITO, NEW DELHI

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

Bench: N.K. Billaiya & Ms. Astha Chandraasstt. Year: 2009-10

B-5, Tagore Market, Ward 15(2), Kirti Nagar, New Delhi. New Delhi PAN AABCR9085Q (Appellant) (Respondent) Assessee by: Shri Ankit Gupta, Advocate Department by : Shri P.N. Barnwal, CIT-DR Date of Hearing 06/12/2023 Date of 06/12/2023 pronouncement O R D E R PER ASTHA CHANDRA, JM The appeal filed by the assessee is directed against the order dated

M/S DABUR INDIA LTD.,,DELHI vs. ACIT, NEW DELHI

In the result appeal of the assessee is partly allowed for statistical purposes and that of the department is dismissed

Bench: Sh. N. K. Saini, Am & Sh. Sudhanshu Srivastava, Jm Ita No. 3257/Del/2013 : Asstt. Year : 2006-07 Dabur India Ltd., Vs Asstt. Commissioner Of Income 8/3, Asaf Ali Road, Tax, Central Circle-22, New Delhi New Delhi (Appellant) (Respondent) Pan No. Aaacd0474C

801C of the Act, 1961? 7. The appellant craves leave, to add, alter or amend any ground of appeal raised above at the time of the hearing.” 5. Ground Nos. 1 to 7 of the assessee’s appeal which are co-related and Ground Nos. 1 & 2 of the departmental appeal relate to the chargeability of the royalty from

DCIT, NEW DELHI vs. M/S DABUR INDIA LTD,, NEW DELHI

In the result appeal of the assessee is partly allowed for statistical purposes and that of the department is dismissed

Bench: Sh. N. K. Saini, Am & Sh. Sudhanshu Srivastava, Jm Ita No. 3257/Del/2013 : Asstt. Year : 2006-07 Dabur India Ltd., Vs Asstt. Commissioner Of Income 8/3, Asaf Ali Road, Tax, Central Circle-22, New Delhi New Delhi (Appellant) (Respondent) Pan No. Aaacd0474C

801C of the Act, 1961? 7. The appellant craves leave, to add, alter or amend any ground of appeal raised above at the time of the hearing.” 5. Ground Nos. 1 to 7 of the assessee’s appeal which are co-related and Ground Nos. 1 & 2 of the departmental appeal relate to the chargeability of the royalty from