KAUSHAL INFRAPROJECT INDUSTRIES INDIA LTD.,NEW DELHI vs. DCIT, NEW DELHI

Bench: : Shri Bhavnesh Saini & Dr. B.R.R. Kumar

iii) of the I.T. Act”. It was further submitted that similarly the most Appropriate Authority to determine the position of the land is Tehsildar of the Land Revenue Department who has categorically stated in his Certificate that the lands in question are situated at a distance of 9 KM from the local limits of Municipal Corporation of the Delhi

DCIT, NEW DELHI vs. M/S. KUSHAL INFRAPROJECT INDUSTRIES INDIA LTD., NEW DELHI

Bench: : Shri Bhavnesh Saini & Dr. B.R.R. Kumar

iii) of the I.T. Act”. It was further submitted that similarly the most Appropriate Authority to determine the position of the land is Tehsildar of the Land Revenue Department who has categorically stated in his Certificate that the lands in question are situated at a distance of 9 KM from the local limits of Municipal Corporation of the Delhi

THE PR. COMMISSIONER OF INCOME TAX-4 vs. GE MONEY FINANCIAL SERVICES PVT. LTD.

Bench: HON'BLE DR. JUSTICE S.MURALIDHAR,HON'BLE MR. JUSTICE NAJMI WAZIRI

Section 2(iii) approval in view of the interim order dated 10th January, 2017 of the Division Bench of this Court. However, this does not, in any manner, confer any right upon the petitioner. Similarly, the communication dated 20th October, 2016 issued by the Ministry of Mines does not come to the aid of the petitioner. By the said communication

MR. RANJEET SINGH,GURGAON vs. DCIT, NEW DELHI

Bench: Shri G.S. Pannu & Shri Amit Shukla(Through Video Conferencing) Assessment Year 2005-06

14 ITAs No.5512, 5513, 5546 & 5574/DEL/2011 appellant in terms of section 17(2)(iii) read with section 2(24)(iv). The appellant as a director of the company has been transferred shares at Rs.10/- per share, which is the face value and not the market value. Since M/s Eltek SGS Pvt. Ltd. was a profit making and dividend paying company

MR. KRISHNA KUMAR PANT,NEW DELHI vs. DCIT, NEW DELHI

Bench: Shri G.S. Pannu & Shri Amit Shukla(Through Video Conferencing) Assessment Year 2005-06

14 ITAs No.5512, 5513, 5546 & 5574/DEL/2011 appellant in terms of section 17(2)(iii) read with section 2(24)(iv). The appellant as a director of the company has been transferred shares at Rs.10/- per share, which is the face value and not the market value. Since M/s Eltek SGS Pvt. Ltd. was a profit making and dividend paying company

MR. SANJIV NARAYAN,NEW DELHI vs. DCIT, NEW DELHI

Bench: Shri G.S. Pannu & Shri Amit Shukla(Through Video Conferencing) Assessment Year 2005-06

14 ITAs No.5512, 5513, 5546 & 5574/DEL/2011 appellant in terms of section 17(2)(iii) read with section 2(24)(iv). The appellant as a director of the company has been transferred shares at Rs.10/- per share, which is the face value and not the market value. Since M/s Eltek SGS Pvt. Ltd. was a profit making and dividend paying company

MR. J.S. GUJRAL,GURGAON vs. DCIT, NEW DELHI

Bench: Shri G.S. Pannu & Shri Amit Shukla(Through Video Conferencing) Assessment Year 2005-06

14 ITAs No.5512, 5513, 5546 & 5574/DEL/2011 appellant in terms of section 17(2)(iii) read with section 2(24)(iv). The appellant as a director of the company has been transferred shares at Rs.10/- per share, which is the face value and not the market value. Since M/s Eltek SGS Pvt. Ltd. was a profit making and dividend paying company

COMMISSIONER OF INCOME TAX vs. ANKITECH PVT LTD

Bench: HON'BLE MR. JUSTICE A.K.SIKRI,HON'BLE MR. JUSTICE M.L. MEHTA

14 of the Act stipulates various heads of income, one of them being ―Income from Other Sources‖. As per Section 56 of the Act, dividend income is to be included under this head, viz., ―Income from Other Sources‖. Thus, the amount of dividend received by the shareholders is to be treated as income which is to be taxed under head

DCIT, NEW DELHI vs. M/S. BBC WORLD INDIA (P) LTD., NEW DELHI

In the result appeal of the assessee and the learned assessing officer are allowed for statistical purposes

Bench: Shri Kuldip Singh & Shri Prashant Maharishi

14. The Ld Dr vehemently opposed such additional ground stating that assessee has not raised such ground before the AO, CIT (A), Or TPO, therefore, same cannot be raised now. 15. We have carefully considered the rival contention. We find that the ground raised by the assessee in the cross objection is purely legal and goes to the root

PCIT-1, NEW DELHI vs. BEAM GLOBAL SPIRITS & WINE (INDIA) PVT. LTD.

Bench: HON'BLE MR. JUSTICE HARISH VAIDYANATHAN SHANKAR,HON'BLE MR. JUSTICE YASHWANT VARMA

iii), includes a fixed place of business through which the business of the enterprise is wholly or partly carried on; (iv) "specified date" means the date one month prior to the due date for furnishing the return of income under sub-section (1) of section 139 for the relevant assessment year;] (v) "transaction" includes an arrangement, understanding or action

PCIT-1, NEW DELHI vs. BEAM GLOBAL SPIRITS & WINE (INDIA)PVT.LTD.

Bench: HON'BLE MR. JUSTICE HARISH VAIDYANATHAN SHANKAR,HON'BLE MR. JUSTICE YASHWANT VARMA

iii), includes a fixed place of business through which the business of the enterprise is wholly or partly carried on; (iv) "specified date" means the date one month prior to the due date for furnishing the return of income under sub-section (1) of section 139 for the relevant assessment year;] (v) "transaction" includes an arrangement, understanding or action

(Now known as Sony India Limited)

Sections (1) and (2) to Section 92C are applicable to the assessed, as well as the Assessing Officer invoking power under Sub-Section (3) to Section 92C of the Act. As noted above, sub-section (2) to Section 92C stipulates that most appropriate method, out of the methods specified in sub-section (1) shall be applied to determine

DCM SHRIIRAM LTD.,NEW DELHI vs. ADDL.CIT, SPECIAL RANGE- 3 , NEW DELHI

In the result appeal of assessee is partly allowed

Bench: Shri Kul Bharat & Shri Prashant Maharishi(Through Video Conferencing)

transfer-pricing officer. iii. With respect to the disallowance u/s 14 A of the act, the learned DRP directed the learned assessing officer to compute the indirect interest expenditure Under rule 8D (2) (ii) of the act only with respect to the dividend bearing investment and further for the purpose of rule 8D (2) (iii) the disallowance made

CIT vs. M/S TELETUBE ELECTRONICS LTD

The appeal of the Assessee is allowed

III would have zero life by 2004. Therefore, in terms of the lease agreement, the assets to be reverted to the Assessee would only have scrap value. Consequently, the lease was a transfer attracting capital gains but only in relation to transfer of movable assets. Thus short term capital gains were attracted under Section 50 of the Act. Order

TELETUBE ELECTRONICS LTD

The appeal of the Assessee is allowed

III would have zero life by 2004. Therefore, in terms of the lease agreement, the assets to be reverted to the Assessee would only have scrap value. Consequently, the lease was a transfer attracting capital gains but only in relation to transfer of movable assets. Thus short term capital gains were attracted under Section 50 of the Act. Order

TELETUBE ELECTRONICS LTD

The appeal of the Assessee is allowed

III would have zero life by 2004. Therefore, in terms of the lease agreement, the assets to be reverted to the Assessee would only have scrap value. Consequently, the lease was a transfer attracting capital gains but only in relation to transfer of movable assets. Thus short term capital gains were attracted under Section 50 of the Act. Order

JINDAL STAINLESS LTD.,HISAR vs. DCIT, NEW DELHI

Accordingly, ground number 2 of the appeal of the learned AO for 2007 – 08 is dismissed

Bench: Smt Diva Singh & Shri Prashant Maharishi

iii) the adjusted price arrived at under sub-clause (ii) is taken to be an arm's length price in respect of the property transferred or services provided in the international transaction;‖(emphasis supplied) For the purpose of application of CUP method, prices charged in an international transaction are required to be compared with the prices charged for comparable uncontrolled

DCIT, NEW DELHI vs. M/S JSL LTD.,, HISAR

Accordingly, ground number 2 of the appeal of the learned AO for 2007 – 08 is dismissed

Bench: Smt Diva Singh & Shri Prashant Maharishi

iii) the adjusted price arrived at under sub-clause (ii) is taken to be an arm's length price in respect of the property transferred or services provided in the international transaction;‖(emphasis supplied) For the purpose of application of CUP method, prices charged in an international transaction are required to be compared with the prices charged for comparable uncontrolled