ITO, NEW DELHI vs. M/S. SUKHNA REAL ESTATE PVT. LTD., GHAZIABAD

Bench: Shri Amit Shukla & Shri Prashant Maharishi

section 68 on the ground that appellant company has filed to prove the identity, creditworthiness and genuineness of the transactions. i) Grounds challenging the confirmation/deletion by the Ld. C.I.T(A)of additions made by the A.O u/s 68 on account of alleged unexplained credit in the form of share capital/ share premium and/or loans & advances (as the case

ITO, WARD-7(1), NEW DELHI vs. DELIGHT RESORTS P.LTD, GHAZIABAD

Bench: Shri Amit Shukla & Shri Prashant Maharishi

section 68 on the ground that appellant company has filed to prove the identity, creditworthiness and genuineness of the transactions. i) Grounds challenging the confirmation/deletion by the Ld. C.I.T(A)of additions made by the A.O u/s 68 on account of alleged unexplained credit in the form of share capital/ share premium and/or loans & advances (as the case

JINGLE BELLS ALUMINIUM,NEW DELHI vs. ITO WARD - 13(3), NEW DELHI

Bench: Shri Amit Shukla & Shri Prashant Maharishi

section 68 on the ground that appellant company has filed to prove the identity, creditworthiness and genuineness of the transactions. i) Grounds challenging the confirmation/deletion by the Ld. C.I.T(A)of additions made by the A.O u/s 68 on account of alleged unexplained credit in the form of share capital/ share premium and/or loans & advances (as the case

ITO WARD - 13(3), NEW DELHI vs. JINGLE BELLS ALUMINIUM PVT. LTD., NEW DELHI

Bench: Shri Amit Shukla & Shri Prashant Maharishi

section 68 on the ground that appellant company has filed to prove the identity, creditworthiness and genuineness of the transactions. i) Grounds challenging the confirmation/deletion by the Ld. C.I.T(A)of additions made by the A.O u/s 68 on account of alleged unexplained credit in the form of share capital/ share premium and/or loans & advances (as the case

ITO, NEW DELHI vs. M/S. SINTEX CONSUMERS ELECTRONICS PVT. LTD., DELHI

Bench: Shri Amit Shukla & Shri Prashant Maharishi

section 68 on the ground that appellant company has filed to prove the identity, creditworthiness and genuineness of the transactions. i) Grounds challenging the confirmation/deletion by the Ld. C.I.T(A)of additions made by the A.O u/s 68 on account of alleged unexplained credit in the form of share capital/ share premium and/or loans & advances (as the case

ACIT, NEW DELHI vs. M/S. STAR LIGHT CONSUMER ELECTRONICS PVT. LTD., NEW DELHI

Bench: Shri Amit Shukla & Shri Prashant Maharishi

section 68 on the ground that appellant company has filed to prove the identity, creditworthiness and genuineness of the transactions. i) Grounds challenging the confirmation/deletion by the Ld. C.I.T(A)of additions made by the A.O u/s 68 on account of alleged unexplained credit in the form of share capital/ share premium and/or loans & advances (as the case

KASPER INFORMATION TECHNOLOGY P.LTD,NEW DELHI vs. ITO, WARD-14(2), NEW DELHI

Bench: Shri Amit Shukla & Shri Prashant Maharishi

section 68 on the ground that appellant company has filed to prove the identity, creditworthiness and genuineness of the transactions. i) Grounds challenging the confirmation/deletion by the Ld. C.I.T(A)of additions made by the A.O u/s 68 on account of alleged unexplained credit in the form of share capital/ share premium and/or loans & advances (as the case

LANDSKY REAL ESTATES P.LTD,NEW DELHI vs. ITO, WARD-15(1), NEW DELHI

Bench: Shri Amit Shukla & Shri Prashant Maharishi

section 68 on the ground that appellant company has filed to prove the identity, creditworthiness and genuineness of the transactions. i) Grounds challenging the confirmation/deletion by the Ld. C.I.T(A)of additions made by the A.O u/s 68 on account of alleged unexplained credit in the form of share capital/ share premium and/or loans & advances (as the case

M/S GLOBUS REAL INFRA PVT. LTD.,,NEW DELHI vs. DCIT, NEW DELHI

Bench: Shri Amit Shukla & Shri Prashant Maharishi

section 68 on the ground that appellant company has filed to prove the identity, creditworthiness and genuineness of the transactions. i) Grounds challenging the confirmation/deletion by the Ld. C.I.T(A)of additions made by the A.O u/s 68 on account of alleged unexplained credit in the form of share capital/ share premium and/or loans & advances (as the case

ITO WARD - 14(2), NEW DELHI vs. KASPER INFORMATION TECHNOLOGY PVT LTD, NEW DELHI

Bench: Shri Amit Shukla & Shri Prashant Maharishi

section 68 on the ground that appellant company has filed to prove the identity, creditworthiness and genuineness of the transactions. i) Grounds challenging the confirmation/deletion by the Ld. C.I.T(A)of additions made by the A.O u/s 68 on account of alleged unexplained credit in the form of share capital/ share premium and/or loans & advances (as the case

KASPER INFORMATION TECHNOLOGY PVT. LTD.,NEW DELHI vs. ITO WARD-14(2), NEW DELHI

Bench: Shri Amit Shukla & Shri Prashant Maharishi

section 68 on the ground that appellant company has filed to prove the identity, creditworthiness and genuineness of the transactions. i) Grounds challenging the confirmation/deletion by the Ld. C.I.T(A)of additions made by the A.O u/s 68 on account of alleged unexplained credit in the form of share capital/ share premium and/or loans & advances (as the case

ITO, WARD-7(1), NEW DELHI vs. DELIGHT RESORTS P.LTD, NEW DELHI

Bench: Shri Amit Shukla & Shri Prashant Maharishi

section 68 on the ground that appellant company has filed to prove the identity, creditworthiness and genuineness of the transactions. i) Grounds challenging the confirmation/deletion by the Ld. C.I.T(A)of additions made by the A.O u/s 68 on account of alleged unexplained credit in the form of share capital/ share premium and/or loans & advances (as the case

ITO, NEW DELHI vs. M/S ANGEL CEMENT PVT. LTD.,, GHAZIABAD

Bench: Shri Amit Shukla & Shri Prashant Maharishi

section 68 on the ground that appellant company has filed to prove the identity, creditworthiness and genuineness of the transactions. i) Grounds challenging the confirmation/deletion by the Ld. C.I.T(A)of additions made by the A.O u/s 68 on account of alleged unexplained credit in the form of share capital/ share premium and/or loans & advances (as the case

ITO, NEW DELHI vs. M/S. SUPREME PLACEMENT SERVICES PVT. LTD., NEW DELHI

Bench: Shri Amit Shukla & Shri Prashant Maharishi

section 68 on the ground that appellant company has filed to prove the identity, creditworthiness and genuineness of the transactions. i) Grounds challenging the confirmation/deletion by the Ld. C.I.T(A)of additions made by the A.O u/s 68 on account of alleged unexplained credit in the form of share capital/ share premium and/or loans & advances (as the case

ITO, NEW DELHI vs. M/S STYLISH CONSTRUCTION PVT. LTD.,, NEW DELHI

Bench: Shri Amit Shukla & Shri Prashant Maharishi

section 68 on the ground that appellant company has filed to prove the identity, creditworthiness and genuineness of the transactions. i) Grounds challenging the confirmation/deletion by the Ld. C.I.T(A)of additions made by the A.O u/s 68 on account of alleged unexplained credit in the form of share capital/ share premium and/or loans & advances (as the case

ACIT, NEW DELHI vs. M/S. SUR BUILDCON PVT. LTD., NEW DELHI

Bench: Shri Amit Shukla & Shri Prashant Maharishi

section 68 on the ground that appellant company has filed to prove the identity, creditworthiness and genuineness of the transactions. i) Grounds challenging the confirmation/deletion by the Ld. C.I.T(A)of additions made by the A.O u/s 68 on account of alleged unexplained credit in the form of share capital/ share premium and/or loans & advances (as the case

ITO, NEW DELHI vs. M/S. SUKHNA STEEL PVT. LTD., NEW DELHI

Bench: Shri Amit Shukla & Shri Prashant Maharishi

section 68 on the ground that appellant company has filed to prove the identity, creditworthiness and genuineness of the transactions. i) Grounds challenging the confirmation/deletion by the Ld. C.I.T(A)of additions made by the A.O u/s 68 on account of alleged unexplained credit in the form of share capital/ share premium and/or loans & advances (as the case

DAE LEASING (IRELAND) 17 LIMITED,IRELAND vs. ACIT, CIRCLE- 1(2)(2) INT. TAX, DELHI

In the result, appeals of the assesses are allowed, pro tanto

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishraआअसं.994/िद"ी/2025(िन.व. 2022-23) Kosi Aviation Leasing Ltd., C/O Dmd Advocates, 30, Nizamuddin East, New Delhi 110013 ...... अपीलाथ"/Appellant Pan : Aaick-6199-B बनाम Vs. Assistant Commissioner Of Income Tax, International Taxation, Circle 2(1)(2), Civic Centre, ....."ितवादी/Respondent Minto Road, New Delhi 110002 आअसं.1027/िद"ी/2025(िन.व. 2022-23) Hoohly Aviation Leasing Ltd., C/O Dmd Advocates, 30, Nizamuddin East, New Delhi 110013 ...... अपीलाथ"/Appellant Pan : Aafch-6609-C बनाम Vs. Assistant Commissioner Of Income Tax, International Taxation, Circle 2(1)(1), Civic Centre, ....."ितवादी/Respondent Minto Road, New Delhi 110002 आअसं.1070/िद"ी/2025(िन.व. 2022-23) Luni Aviation Leasing Ltd., C/O Dmd Advocates, 30, Nizamuddin East, New Delhi 110013 ...... अपीलाथ"/Appellant Pan : Aaecl-5180-H बनाम Vs. Assistant Commissioner Of Income Tax, International Taxation, Circle 2(2)(1), Civic Centre, ....."ितवादी/Respondent Minto Road, New Delhi 110002

Section 90(1) notification, the assessee would, in any event, be entitled to treaty protection. The relief claimed aligns squarely with the treaty's object and purpose. We accordingly so hold.” 24. Thus, the Coordinate Bench on the issue of operation of MLI gave a conclusive finding that in the absence of specific notification in accordance with section