INNOVATIVE TEXTILES LIMITED,DELHI vs. DCIT, CIRCLE-10(1), NEW DELHI

In the result, the appeal of the assessee is partly allowed

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.Innovative Textiles Limited, Vs. Dcit, Circle 10(1), 81, Vighyan Vihar, New Delhi. Delhi – 110 092. (Pan : Aaaci0473J) (Appellant) (Respondent) Assessee By : Shri Gautam Jain, Advocate Revenue By : Shri S.K. Jadhav, Cit Dr Date Of Hearing : 05.08.2025 Date Of Order : 24.09.2025 O R D E R Per S.Rifaur Rahman: 1. This Appeal Is Filed By The Assessee Against Assessment Order Dated 26.03.2022 Passed By The Income Tax Department/National Faceless Assessment Centre, Delhi U/S 143(3) Read With Section 144C(13)/144B Of The Income-Tax Act, 1961 (For Short ‘The Act”) For Assessment Year 2017-18 Pursuant To The Directions Of The Dispute Resolution Panel U/S 144C(5) Of The Act Raising Following Grounds Of Appeal :- “1. That The Orders Of The Learned Lower Tax Authorities Is/Are Contrary To The Law & Facts Of The Case.

section 115J.” 5. We observe that the coordinate Bench in the case of Cash Edge India Pvt. Ltd. (supra) had considered the exactly similar issue. For the sake of brevity, it is reproduced below :- “34. In this regard, the learned counsel for the assessee submitted that the AO has added the transfer pricing

M/S GUJARAT GUARDIAN LTD.,,NEW DELHI vs. DCIT,, NEW DELHI

Pricing regulations all the methods stand on equal footing.\n\n(d) The transaction of export of glass is closely linked with the overall operations of the assessee. It is submitted that the assessee was the first company to set up the float glass plant in India. Until that time float glass was not known in the Indian market

GUJARAT GUARDIAN LTD.,,NEW DELHI vs. DCIT, NEW DELHI

Pricing regulations all\nthe methods stand on equal footing.\n(d) The transaction of export of glass is closely linked with the\noverall operations of the assessee. It is submitted that the assessee\nwas the first company to set up the float glass plant in India. Until\nthat time float glass was not known in the Indian market and\nconventional

GUJARAT GUARDIAN LTD.,,NEW DELHI vs. DCIT, NEW DELHI

Pricing regulations all the methods stand on equal footing.\n\n(d) The transaction of export of glass is closely linked with the overall operations of the assessee. It is submitted that the assessee was the first company to set up the float glass plant in India. Until that time float glass was not known in the Indian market

DCIT, NEW DELHI vs. M/S. GUJRAT GUARDIAN LTD., NEW DELHI

Pricing regulations all\nthe methods stand on equal footing.\n(d) The transaction of export of glass is closely linked with the\noverall operations of the assessee. It is submitted that the assessee\nwas the first company to set up the float glass plant in India. Until\nthat time float glass was not known in the Indian market and\nconventional

GUJARAT GUARDIAN LTD.,NEW DELHI vs. DCIT, NEW DELHI

Pricing regulations all\nthe methods stand on equal footing.\n(d) The transaction of export of glass is closely linked with the\noverall operations of the assessee. It is submitted that the assessee\nwas the first company to set up the float glass plant in India. Until\nthat time float glass was not known in the Indian market and\nconventional

ACIT, NEW DELHI vs. M/S GUJARAT GUARDIAN LTD., NEW DELHI

Pricing regulations all\nthe methods stand on equal footing.\n(d) The transaction of export of glass is closely linked with the\noverall operations of the assessee. It is submitted that the assessee\nwas the first company to set up the float glass plant in India. Until\nthat time float glass was not known in the Indian market and\nconventional

DCIT, NEW DELHI vs. M/S GUJRAT GUARDIAN LTD.,, NEW DELHI

Pricing regulations all\nthe methods stand on equal footing.\n\n(d) The transaction of export of glass is closely linked with the\noverall operations of the assessee. It is submitted that the assessee\nwas the first company to set up the float glass plant in India. Until\nthat time float glass was not known in the Indian market

SHREE CHANDI MAA MAHAKALI PRACHIN MANDIR SIDH PEETH SAMITI,SONIPAT vs. CPC, BANGLORE

Pricing regulations all\nthe methods stand on equal footing.\n(d) The transaction of export of glass is closely linked with the\noverall operations of the assessee. It is submitted that the assessee\nwas the first company to set up the float glass plant in India. Until\nthat time float glass was not known in the Indian market and\nconventional

GUJRAT GUARDIAN LTD.,NEW DELHI vs. DCIT, NEW DELHI

Pricing regulations all\nthe methods stand on equal footing.\n(d) The transaction of export of glass is closely linked with the\noverall operations of the assessee. It is submitted that the assessee\nwas the first company to set up the float glass plant in India. Until\nthat time float glass was not known in the Indian market and\nconventional

NALWA STEEL POWER LIMITED,NEW DELHI vs. ACIT, CIRCLE- 13(3), NEW DELHI

In the result, ITA No. 5548/Del/2017 of the Revenue is dismissed

Bench: Dr. Brr Kumar & Shri Yogesh Kumar U.S.Assessment Year: 2011-12

price of power for the purposes of computing deduction admissible to power units u/s 80-1A of the I.T. Act. We find the assessee in the instant case has sold the electricity to its captive plant 7 ITA No.5548 & 4941/Del./2017 Nalwa Steel & Power Ltd. at the rate of Rs.3.92 per unit i.e. rate at which CSEB was selling

DCIT, CIRCLE- 17(2), NEW DELHI vs. NALWA STEEL AND POWER LTD., NEW DELHI

In the result, ITA No. 5548/Del/2017 of the Revenue is dismissed

Bench: Dr. Brr Kumar & Shri Yogesh Kumar U.S.Assessment Year: 2011-12

price of power for the purposes of computing deduction admissible to power units u/s 80-1A of the I.T. Act. We find the assessee in the instant case has sold the electricity to its captive plant 7 ITA No.5548 & 4941/Del./2017 Nalwa Steel & Power Ltd. at the rate of Rs.3.92 per unit i.e. rate at which CSEB was selling

ORIENTAL BANK OF COMMERCE,GURGAON vs. ACIT, SPL. RANGE-07, NEW DELHI

In the result, the appeal filed by the Assessee stands allowed

Bench: Shri Anil Chaturvedi & Shri N.K. Choudhryassessment Year: 2016-17

price is higher than the face value, 12 ‘the premium should be amortized for the remaining period of maturity of the security’. From the above, it is clear that the premium has to be amortized for the remaining period of maturity of the security. The learned authorized representative fairly conceded that details of such premium splitting over the remaining period

ACIT, CIRCLE- 19(1), NEW DELHI vs. ORIENTAL BANK OF COMMERCE, GURGAON

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

Bench: Sh. A. D. Jain, Vice-Dr. B. R. R. Kumarita No. 1581/Del/2017 : Asstt. Year : 2012-13 Ita No. 1582/Del/2017 : Asstt. Year : 2013-14 Ita No. 1583/Del/2017 : Asstt. Year : 2014-15 Ita No. 1199/Del/2018 : Asstt. Year : 2015-16 Oriental Bank Of Commerce, Vs Addl. Cit, Central Accounts Office, Plot No. 5, Range-13 (Present Range-19) Sector-32, Institutional Area, New Delhi Gurgaon-122001 Dcit/Acit, Circle-19(1), New Delhi (Appellant) (Respondent) Pan No. Aaaco0191M

price is higher than the face value, ‘the premium should be amortized for the remaining period of maturity of the security’. From the above, it is clear that the premium has to be amortized for the remaining period of maturity of the security. The learned authorized representative fairly conceded that details of such premium splitting over the remaining period

ORIENTAL BANK OF COMMERCE,GURGAON vs. ADDL. CIT, NEW DELHI

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

Bench: Sh. A. D. Jain, Vice-Dr. B. R. R. Kumarita No. 1581/Del/2017 : Asstt. Year : 2012-13 Ita No. 1582/Del/2017 : Asstt. Year : 2013-14 Ita No. 1583/Del/2017 : Asstt. Year : 2014-15 Ita No. 1199/Del/2018 : Asstt. Year : 2015-16 Oriental Bank Of Commerce, Vs Addl. Cit, Central Accounts Office, Plot No. 5, Range-13 (Present Range-19) Sector-32, Institutional Area, New Delhi Gurgaon-122001 Dcit/Acit, Circle-19(1), New Delhi (Appellant) (Respondent) Pan No. Aaaco0191M

price is higher than the face value, ‘the premium should be amortized for the remaining period of maturity of the security’. From the above, it is clear that the premium has to be amortized for the remaining period of maturity of the security. The learned authorized representative fairly conceded that details of such premium splitting over the remaining period

ORIENTAL BANK OF COMMERCE,GURGAON vs. DCIT, NEW DELHI

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

Bench: Sh. A. D. Jain, Vice-Dr. B. R. R. Kumarita No. 1581/Del/2017 : Asstt. Year : 2012-13 Ita No. 1582/Del/2017 : Asstt. Year : 2013-14 Ita No. 1583/Del/2017 : Asstt. Year : 2014-15 Ita No. 1199/Del/2018 : Asstt. Year : 2015-16 Oriental Bank Of Commerce, Vs Addl. Cit, Central Accounts Office, Plot No. 5, Range-13 (Present Range-19) Sector-32, Institutional Area, New Delhi Gurgaon-122001 Dcit/Acit, Circle-19(1), New Delhi (Appellant) (Respondent) Pan No. Aaaco0191M

price is higher than the face value, ‘the premium should be amortized for the remaining period of maturity of the security’. From the above, it is clear that the premium has to be amortized for the remaining period of maturity of the security. The learned authorized representative fairly conceded that details of such premium splitting over the remaining period

ORIENTAL BANK OF COMMERCE,GURGAON vs. DCIT, NEW DELHI

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

Bench: Sh. A. D. Jain, Vice-Dr. B. R. R. Kumarita No. 1581/Del/2017 : Asstt. Year : 2012-13 Ita No. 1582/Del/2017 : Asstt. Year : 2013-14 Ita No. 1583/Del/2017 : Asstt. Year : 2014-15 Ita No. 1199/Del/2018 : Asstt. Year : 2015-16 Oriental Bank Of Commerce, Vs Addl. Cit, Central Accounts Office, Plot No. 5, Range-13 (Present Range-19) Sector-32, Institutional Area, New Delhi Gurgaon-122001 Dcit/Acit, Circle-19(1), New Delhi (Appellant) (Respondent) Pan No. Aaaco0191M

price is higher than the face value, ‘the premium should be amortized for the remaining period of maturity of the security’. From the above, it is clear that the premium has to be amortized for the remaining period of maturity of the security. The learned authorized representative fairly conceded that details of such premium splitting over the remaining period

ACIT, NEW DELHI vs. M/S. ORIENTAL BANK OF COMMERCE, GURGAON

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

Bench: Sh. A. D. Jain, Vice-Dr. B. R. R. Kumarita No. 1581/Del/2017 : Asstt. Year : 2012-13 Ita No. 1582/Del/2017 : Asstt. Year : 2013-14 Ita No. 1583/Del/2017 : Asstt. Year : 2014-15 Ita No. 1199/Del/2018 : Asstt. Year : 2015-16 Oriental Bank Of Commerce, Vs Addl. Cit, Central Accounts Office, Plot No. 5, Range-13 (Present Range-19) Sector-32, Institutional Area, New Delhi Gurgaon-122001 Dcit/Acit, Circle-19(1), New Delhi (Appellant) (Respondent) Pan No. Aaaco0191M

price is higher than the face value, ‘the premium should be amortized for the remaining period of maturity of the security’. From the above, it is clear that the premium has to be amortized for the remaining period of maturity of the security. The learned authorized representative fairly conceded that details of such premium splitting over the remaining period

ACIT, NEW DELHI vs. M/S. ORIENTAL BANK OF COMMERCE, GURGAON

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

Bench: Sh. A. D. Jain, Vice-Dr. B. R. R. Kumarita No. 1581/Del/2017 : Asstt. Year : 2012-13 Ita No. 1582/Del/2017 : Asstt. Year : 2013-14 Ita No. 1583/Del/2017 : Asstt. Year : 2014-15 Ita No. 1199/Del/2018 : Asstt. Year : 2015-16 Oriental Bank Of Commerce, Vs Addl. Cit, Central Accounts Office, Plot No. 5, Range-13 (Present Range-19) Sector-32, Institutional Area, New Delhi Gurgaon-122001 Dcit/Acit, Circle-19(1), New Delhi (Appellant) (Respondent) Pan No. Aaaco0191M

price is higher than the face value, ‘the premium should be amortized for the remaining period of maturity of the security’. From the above, it is clear that the premium has to be amortized for the remaining period of maturity of the security. The learned authorized representative fairly conceded that details of such premium splitting over the remaining period