M/S. RJ CORP LTD.,NEW DELHI vs. ACIT, NEW DELHI

In the result, the appeal of the assessee on this ground is allowed

Bench: Dr. B. R. R. Kumarsh. Yogesh Kumar Us

price at which the conversion of investment took place wouldbe chargeable under the head income from business. Since, the conversion and subsequent sale have taken place during the same previous year, the sale proceeds become taxable under the head capital gain, unless the appellant has adopted different rates for conversion & subsequent transfers. 4.5.5 However as pointed

M/S. RJ CORP LTD.,NEW DELHI vs. ACIT, NEW DELHI

In the result, the appeal of the assessee on this ground is allowed

Bench: Dr. B. R. R. Kumarsh. Yogesh Kumar Us

price at which the conversion of investment took place wouldbe chargeable under the head income from business. Since, the conversion and subsequent sale have taken place during the same previous year, the sale proceeds become taxable under the head capital gain, unless the appellant has adopted different rates for conversion & subsequent transfers. 4.5.5 However as pointed

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

Appeal of the Revenue is dismissed

Bench: Shri Narendra Kumar Billaiya & Shri Kul Bharat

price could not have been made under that section. Further, the Tribunal held that the transactions were entered by the assessee on account of commercial expediency and when the recipients had paid tax on payments received from the assessee company, disallowance could not be made by applying provisions of section 40A(2) of the Act. It would be pertinent

DCM SHRIRAM LIMITED,DELHI vs. ASSESSMENT UNIT, DELHI

Price and no adjustment\nwas proposed on these transactions. With respect to specified\ndomestic transactions, the TPO observed that the deduction\nclaimed under section 80IA of the Act on the profits from power\ngeneration units needs to be reduced and observed that the transfer\nof electricity generated by power generating units to other\nmanufacturing units

DCM SHRIRAM LTD,NEW DELHI vs. ACIT, CIRCLE-7(1), NEW DELHI

Price and no adjustment\nwas proposed on these transactions. With respect to specified\ndomestic transactions, the TPO observed that the deduction\nclaimed under section 80IA of the Act on the profits from power\ngeneration units needs to be reduced and observed that the transfer\nof electricity generated by power generating units to other\nmanufacturing units

DCIT, NEW DELHI vs. DCM SHRIRAM LTD, NEW DELHI

Price and no adjustment\nwas proposed on these transactions. With respect to specified\ndomestic transactions, the TPO observed that the deduction\nclaimed under section 80IA of the Act on the profits from power\ngeneration units needs to be reduced and observed that the transfer\nof electricity generated by power generating units to other\nmanufacturing units

DCM SHRIIRAM LIMITED,NEW DELHI vs. NEAC, NEW DELHI

Price and no adjustment\nwas proposed on these transactions. With respect to specified\ndomestic transactions, the TPO observed that the deduction\nclaimed under section 80IA of the Act on the profits from power\ngeneration units needs to be reduced and observed that the transfer\nof electricity generated by power generating units to other\nmanufacturing units

THE PR. COMMISSIONER OF INCOME TAX -4 vs. HEADSTRONG SERVICES INDIA PVT. LTD.

14A) The provisions of this section shall not apply to any assessment or reassessment order passed by the Assessing Officer with the prior approval of the [Principal Commissioner or] Commissioner as provided in sub-section (12) of section 144BA.] (15) For the purposes of this section,— (a) "Dispute Resolution Panel" means a collegium comprising of three Principal Commissioners or Commissioners

ACIT, CIRCLE-18(2), NEW DELHI vs. NIIT TECHNOLOGIES LTD.,, NEW DELHI

Appeal is allowed for statistical

Bench: Shri S Rifaur Rahman & Ms. Madhumita Royita Nos.2889 & 2890/Del/2018 (Assessment Years: 2009-10 & 2010-11)

14A of the Act made while calculating Book Profit u/s 115JB of the Act by ignoring the fact that clause (f) of Explanation 1 to section 115JB(2) of the Act, introduced by Finance Act 2006 is applicable to the assessee for the year under consideration ? 5. The appellant craves leave for reserving the right to amend, modify, alter

ACIT, CIRCLE-18(2), NEW DELHI vs. NIIT TECHNOLOGIES LTD.,, NEW DELHI

Appeal is allowed for statistical

Bench: Shri S Rifaur Rahman & Ms. Madhumita Royita Nos.2889 & 2890/Del/2018 (Assessment Years: 2009-10 & 2010-11)

14A of the Act made while calculating Book Profit u/s 115JB of the Act by ignoring the fact that clause (f) of Explanation 1 to section 115JB(2) of the Act, introduced by Finance Act 2006 is applicable to the assessee for the year under consideration ? 5. The appellant craves leave for reserving the right to amend, modify, alter

NIIT TECHNOLOGIES LTD.,NEW DELHI vs. ACIT, CIRCLE-18(2), NEW DELHI

Appeal is allowed for statistical

Bench: Shri S Rifaur Rahman & Ms. Madhumita Royita Nos.2889 & 2890/Del/2018 (Assessment Years: 2009-10 & 2010-11)

14A of the Act made while calculating Book Profit u/s 115JB of the Act by ignoring the fact that clause (f) of Explanation 1 to section 115JB(2) of the Act, introduced by Finance Act 2006 is applicable to the assessee for the year under consideration ? 5. The appellant craves leave for reserving the right to amend, modify, alter

NIIT TECHNOLOGIES LTD.,,NEW DELHI vs. ACIT, CIRCLE-18(2), NEW DELHI

Appeal is allowed for statistical

Bench: Shri S Rifaur Rahman & Ms. Madhumita Royita Nos.2889 & 2890/Del/2018 (Assessment Years: 2009-10 & 2010-11)

14A of the Act made while calculating Book Profit u/s 115JB of the Act by ignoring the fact that clause (f) of Explanation 1 to section 115JB(2) of the Act, introduced by Finance Act 2006 is applicable to the assessee for the year under consideration ? 5. The appellant craves leave for reserving the right to amend, modify, alter

DCIT, CIRCLE- 21(1), NEW DELHI vs. RELIGARE FINVEST LTD., NEW DELHI

In the result, -Appeal in ITA No

Bench: Dr. B. R. R. Kumar & Shri Yogesh Kumar U.S.

14A of the Act in the case of the assessee to the extent of excepted income. In the facts and circumstances of the case, we do not find any error in the order of the Ld. CIT(A) on the issue in dispute in following a binding precedent of the jurisdictional High Court. and accordingly, we uphold the same

ACIT (OSD), CIRCLE- 21(1), NEW DELHI vs. RELIGARE FINVEST LTD., NEW DELHI

In the result, -Appeal in ITA No

Bench: Dr. B. R. R. Kumar & Shri Yogesh Kumar U.S.

14A of the Act in the case of the assessee to the extent of excepted income. In the facts and circumstances of the case, we do not find any error in the order of the Ld. CIT(A) on the issue in dispute in following a binding precedent of the jurisdictional High Court. and accordingly, we uphold the same

RELIGARE FINVEST LTD.,NEW DELHI vs. DCIT, CIRCLE- 21(1), NEW DELHI

In the result, -Appeal in ITA No

Bench: Dr. B. R. R. Kumar & Shri Yogesh Kumar U.S.

14A of the Act in the case of the assessee to the extent of excepted income. In the facts and circumstances of the case, we do not find any error in the order of the Ld. CIT(A) on the issue in dispute in following a binding precedent of the jurisdictional High Court. and accordingly, we uphold the same

RELIGARE FINVEST LTD.,NEW DELHI vs. DCIT, CIRCLE- 21(1), NEW DELHI

In the result, -Appeal in ITA No

Bench: Dr. B. R. R. Kumar & Shri Yogesh Kumar U.S.

14A of the Act in the case of the assessee to the extent of excepted income. In the facts and circumstances of the case, we do not find any error in the order of the Ld. CIT(A) on the issue in dispute in following a binding precedent of the jurisdictional High Court. and accordingly, we uphold the same

RELIGARE FINVEST LTD.,NEW DELHI vs. ACIT, CIRCLE- 21(1), NEW DELHI

In the result, -Appeal in ITA No

Bench: Dr. B. R. R. Kumar & Shri Yogesh Kumar U.S.

14A of the Act in the case of the assessee to the extent of excepted income. In the facts and circumstances of the case, we do not find any error in the order of the Ld. CIT(A) on the issue in dispute in following a binding precedent of the jurisdictional High Court. and accordingly, we uphold the same

ACIT, CIRCLE- 21(1), NEW DELHI vs. RELIGARE FINVEST LTD.,, NEW DELHI

In the result, -Appeal in ITA No

Bench: Dr. B. R. R. Kumar & Shri Yogesh Kumar U.S.

14A of the Act in the case of the assessee to the extent of excepted income. In the facts and circumstances of the case, we do not find any error in the order of the Ld. CIT(A) on the issue in dispute in following a binding precedent of the jurisdictional High Court. and accordingly, we uphold the same