GIESECKE & DEVRIENT (INDIA) PVT. LTD.,GURGAON vs. ADDL. CIT, SPECIAL RANGE- 04, NEW DELHI

In the result, appeal of the assessee in ITA No

Bench: Shri N.K. Billaiya & Ms. Suchitra Kamble[A.Y 2013-14] Giesecke & Devrient [India] Pvt Ltd Vs. The Addl. C.I.T Corporate Office, Plot No. 57, Special Range -04 Sector 44, Gurgaon New Delhi Pan: Aabcg 4223 D [Appellant] [Respondent]

transfer pricing study, TNMM was taken as the most appropriate method for benchmarking trading segment dealing with imports from AEs. The appellant reported NPM from distribution of smart cards at 5.26% and compared the same with three years weighted average working capital adjusted NPM of independent comparables at 0.28%. 7. The TPO was not satisfied with the selection of comparables

HYATT INTERNATIONAL SOUTHWEST ASIA LTD. vs. ACIT(INTERNATIONAL TAXATION)-2(1)(1), NEW DELHI

Bench: HON'BLE MR. JUSTICE VIBHU BAKHRU,HON'BLE MR. JUSTICE AMIT MAHAJAN

44A of the Act. Digitally Signed By:DUSHYANT RAWAL Signing Date:03.01.2024 Signature Not Verified ITA Nos. 216/2020 and Other Connected Matters Page 20 of 61 REASONS & CONCLUSION Re: Question No. (iv) 33. One of the principal contentions advanced by the Assessee is that even if it is assumed that the Assessee has a PE in India, there

HYATT INTERNATIONAL SOUTHWEST ASIA LTD vs. ASSISTANT DIRECTOR OF INCOME TAX

Bench: HON'BLE MR. JUSTICE VIBHU BAKHRU,HON'BLE MR. JUSTICE AMIT MAHAJAN

44A of the Act. Digitally Signed By:DUSHYANT RAWAL Signing Date:03.01.2024 Signature Not Verified ITA Nos. 216/2020 and Other Connected Matters Page 20 of 61 REASONS & CONCLUSION Re: Question No. (iv) 33. One of the principal contentions advanced by the Assessee is that even if it is assumed that the Assessee has a PE in India, there

HYATT INTERNATIONAL-SOUTHWEST ASIA LTD. vs. DEPUTY COMMISSIONER OF INCOME TAX

Bench: HON'BLE MR. JUSTICE VIBHU BAKHRU,HON'BLE MR. JUSTICE AMIT MAHAJAN

44A of the Act. Digitally Signed By:DUSHYANT RAWAL Signing Date:03.01.2024 Signature Not Verified ITA Nos. 216/2020 and Other Connected Matters Page 20 of 61 REASONS & CONCLUSION Re: Question No. (iv) 33. One of the principal contentions advanced by the Assessee is that even if it is assumed that the Assessee has a PE in India, there

HYATT INTERNATIONAL-SOUTHWEST ASIA LTD vs. ASSISTANT COMMISSIONER OF INCOME TAX

Bench: HON'BLE MR. JUSTICE VIBHU BAKHRU,HON'BLE MR. JUSTICE AMIT MAHAJAN

44A of the Act. Digitally Signed By:DUSHYANT RAWAL Signing Date:03.01.2024 Signature Not Verified ITA Nos. 216/2020 and Other Connected Matters Page 20 of 61 REASONS & CONCLUSION Re: Question No. (iv) 33. One of the principal contentions advanced by the Assessee is that even if it is assumed that the Assessee has a PE in India, there

HYATT INTERNATIONAL SOUTHWEST ASIA LTD vs. ADDITIONAL DIRECTOR OF INCOME TAX

Bench: HON'BLE MR. JUSTICE VIBHU BAKHRU,HON'BLE MR. JUSTICE AMIT MAHAJAN

44A of the Act. Digitally Signed By:DUSHYANT RAWAL Signing Date:03.01.2024 Signature Not Verified ITA Nos. 216/2020 and Other Connected Matters Page 20 of 61 REASONS & CONCLUSION Re: Question No. (iv) 33. One of the principal contentions advanced by the Assessee is that even if it is assumed that the Assessee has a PE in India, there

HYATT INTERNATIONAL SOUTHWEST ASIA LTD vs. DEPUTY COMMISSIONER OF INCOME TAX

Bench: HON'BLE MR. JUSTICE VIBHU BAKHRU,HON'BLE MR. JUSTICE AMIT MAHAJAN

44A of the Act. Digitally Signed By:DUSHYANT RAWAL Signing Date:03.01.2024 Signature Not Verified ITA Nos. 216/2020 and Other Connected Matters Page 20 of 61 REASONS & CONCLUSION Re: Question No. (iv) 33. One of the principal contentions advanced by the Assessee is that even if it is assumed that the Assessee has a PE in India, there

ADIT (E), NEW DELHI vs. FORTUNE SOCIETY FOR DEVELOPMENT AND PROMOTION OF INTERNATIONAL BUSINESS, NEW DELHI

In the result ground No. 2

Bench: Shri I.C.Sudhir & Shri Prashant Maharishiadit(E), Vs. Fortune Society For Tc-Ii, New Delhi Development & Promotion Of International Business, G-4, Community Centre, Naraina Vihar, New Delhi Pan:Aaatf0849L (Appellant) (Respondent)

transferring from the excess of income over expenditure account to these 2 different accounts. Therefore according to us there is no infirmity in the order of the Ld. CIT (A) in holding that assessee has not applied the profit for noncharitable purposes. In the result ground No. 1 of the appeal of the revenue is dismissed. 6. With respect

VENUS FINANCIAL SERVICES LTD.,NEW DELHI vs. ACIT, NEW DELHI

The appeal is allowed

Bench: Shri I.C. Sudhir & Shri Inturi Rama Rao Assessment Year: 2009-10 Venus Financial Services Ltd., Vs. Assistant Cit, (Now Merged With Avantha Realty Ltd.) Circle 17(1), Thapar House, 124 Janpath, New Delhi. New Delhi. (Pan: Aaacv3258L) (Appellant) (Respondent) Appellant By: Shri P.C. Yadav, Adv. Respondent By: Shri J.P. Chandrekar, Sr. Dr Date Of Hearing : 01 .07.2015 Date Of Pronouncement: 28 :09.2015 Order Per I.C. Sudhir:The Assessee Has Impugned First Appellate Order On The Following Grounds: 1) That The Order Of The Learned Cit(Appeals) Is Bad In Law & On Facts.

transferred in the name of other party and the consideration was received by cheque. In support, he referred page Nos. 67 and 68 of the paper book which are copies of shares certificate. 8. The Learned AR submitted further that long term capital gain or loss is to be computed in the manner laid down in section

DCIT CENTRAL CIRCLE- 19, NEW DELHI vs. KRBL LIMITED, DELHI

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

Bench: Sh. A.D. Jaindr. B. R. R. Kumarita No. 1196/Del/2020 : Asstt. Year: 2010-11 Ita No. 1197/Del/2020 : Asstt. Year: 2011-12

44A, 44B, 51 and 53). Thus, it has been confirmed by the Samiti that the Form 6R filled in by the appellant is not the only evidence to prove that the sellers were farmers but there are various other records required to be maintained by the samiti mandatorily which prove that the sales were made by the farmers

DCIT CENTRAL CIRCLE- 19, NEW DELHI vs. KRBL LIMITED, DELHI

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

Bench: Sh. A.D. Jaindr. B. R. R. Kumarita No. 1196/Del/2020 : Asstt. Year: 2010-11 Ita No. 1197/Del/2020 : Asstt. Year: 2011-12

44A, 44B, 51 and 53). Thus, it has been confirmed by the Samiti that the Form 6R filled in by the appellant is not the only evidence to prove that the sellers were farmers but there are various other records required to be maintained by the samiti mandatorily which prove that the sales were made by the farmers

KRBL LIMITED,DELHI vs. DCIT CENTRAL CIRCLE- 07, NEW DELHI

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

Bench: Sh. A.D. Jaindr. B. R. R. Kumarita No. 1196/Del/2020 : Asstt. Year: 2010-11 Ita No. 1197/Del/2020 : Asstt. Year: 2011-12

44A, 44B, 51 and 53). Thus, it has been confirmed by the Samiti that the Form 6R filled in by the appellant is not the only evidence to prove that the sellers were farmers but there are various other records required to be maintained by the samiti mandatorily which prove that the sales were made by the farmers

KRBL LIMITED,DELHI vs. DCIT CENTRAL CIRCLE- 07, NEW DELHI

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

Bench: Sh. A.D. Jaindr. B. R. R. Kumarita No. 1196/Del/2020 : Asstt. Year: 2010-11 Ita No. 1197/Del/2020 : Asstt. Year: 2011-12

44A, 44B, 51 and 53). Thus, it has been confirmed by the Samiti that the Form 6R filled in by the appellant is not the only evidence to prove that the sellers were farmers but there are various other records required to be maintained by the samiti mandatorily which prove that the sales were made by the farmers

DCIT CENTRAL CIRCLE- 19, NEW DELHI vs. KRBL LIMITED, DELHI

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

Bench: Sh. A.D. Jaindr. B. R. R. Kumarita No. 1196/Del/2020 : Asstt. Year: 2010-11 Ita No. 1197/Del/2020 : Asstt. Year: 2011-12

44A, 44B, 51 and 53). Thus, it has been confirmed by the Samiti that the Form 6R filled in by the appellant is not the only evidence to prove that the sellers were farmers but there are various other records required to be maintained by the samiti mandatorily which prove that the sales were made by the farmers

KRBL LIMITED,DELHI vs. DCIT CENTRAL CIRCLE- 07, NEW DELHI

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

Bench: Sh. A.D. Jaindr. B. R. R. Kumarita No. 1196/Del/2020 : Asstt. Year: 2010-11 Ita No. 1197/Del/2020 : Asstt. Year: 2011-12

44A, 44B, 51 and 53). Thus, it has been confirmed by the Samiti that the Form 6R filled in by the appellant is not the only evidence to prove that the sellers were farmers but there are various other records required to be maintained by the samiti mandatorily which prove that the sales were made by the farmers

KRBL LIMITED,DELHI vs. DCIT CENTRAL CIRCLE- 07, NEW DELHI

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

Bench: Sh. A.D. Jaindr. B. R. R. Kumarita No. 1196/Del/2020 : Asstt. Year: 2010-11 Ita No. 1197/Del/2020 : Asstt. Year: 2011-12

44A, 44B, 51 and 53). Thus, it has been confirmed by the Samiti that the Form 6R filled in by the appellant is not the only evidence to prove that the sellers were farmers but there are various other records required to be maintained by the samiti mandatorily which prove that the sales were made by the farmers

KRBL LIMITED,DELHI vs. DCIT CENTRAL CIRCLE- 07, NEW DELHI

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

Bench: Sh. A.D. Jaindr. B. R. R. Kumarita No. 1196/Del/2020 : Asstt. Year: 2010-11 Ita No. 1197/Del/2020 : Asstt. Year: 2011-12

44A, 44B, 51 and 53). Thus, it has been confirmed by the Samiti that the Form 6R filled in by the appellant is not the only evidence to prove that the sellers were farmers but there are various other records required to be maintained by the samiti mandatorily which prove that the sales were made by the farmers

DCIT CENTRAL CIRCLE- 19, NEW DELHI vs. KRBL LIMITED, DELHI

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

Bench: Sh. A.D. Jaindr. B. R. R. Kumarita No. 1196/Del/2020 : Asstt. Year: 2010-11 Ita No. 1197/Del/2020 : Asstt. Year: 2011-12

44A, 44B, 51 and 53). Thus, it has been confirmed by the Samiti that the Form 6R filled in by the appellant is not the only evidence to prove that the sellers were farmers but there are various other records required to be maintained by the samiti mandatorily which prove that the sales were made by the farmers