ACIT CIRCLE 16(1), DELHI vs. KUL PRAKASH CHANDOK , DELHI

In the result, we do not\nfind any merit in this appeal, the same fails and is hereby\ndismissed

price would also become almost half. Therefore, on the\nsale of original shares held by an assessee, the assessee would undisputedly\nincur a loss. However, such loss is likely to be compensated on sale of bonus\nshares as and when it happens because cost of acquisition of bonus shares is\nnil as per the provisions of section 55(2)(aa

DCIT CIRCLE - 16(1), NEW DELHI vs. ARUNA CHANDHOK, NEW DELHI

In the result, we do not find any merit in this appeal, the same fails and is hereby dismissed

Bench: Shri M. Balaganesh & Shri Anubhav Sharmadcit, Vs. Smt Aruna Chandhok, Circle-16(1), H-30, Sainik Farms, New Delhi Delhi-110062 (Appellant) (Respondent) Pan: Aaepc7861R

price would also become almost half. Therefore, on the sale of original shares held by an assessee, the assessee would undisputedly incur a loss. However, such loss is likely to be compensated on sale of bonus shares as and when it happens because cost of acquisition of bonus shares is nil as per the provisions of section 55(2)(aa

DCIT, NEW DELHI vs. M/S. SONY INDIA PVT. LTD., NEW DELHI

In the result, appeal filed by the assessee is partly allowed as indicated above and appeal filed by the revenue is dismissed

Bench: SHRI S.RIFAUR RAHMAN (Accountant Member), SHRI YOGESH KUMAR U.S. (Judicial Member)

Transfer pricing officer issued 2 Show cause notices - At page 462 of paper book 2A, SCN relating to AMP can be found and at page 338 of paper book 2A, SCN issued in connection with Software services can be seen. Kind attention is invited to page 462 paper book 2A-show cause notice refers to "Benchmarking of REIMBUSEMENT OF MARKETING

SONY INDIA PRIVATE LIMITED,NEW DELHI vs. DEPUTY COMMISSIONER OF INCOME-TAX, NEW DELHI

In the result, appeal filed by the assessee is partly allowed as indicated above and appeal filed by the revenue is dismissed

Bench: SHRI S.RIFAUR RAHMAN (Accountant Member), SHRI YOGESH KUMAR U.S. (Judicial Member)

Transfer pricing officer issued 2 Show cause notices - At page 462 of paper book 2A, SCN relating to AMP can be found and at page 338 of paper book 2A, SCN issued in connection with Software services can be seen. Kind attention is invited to page 462 paper book 2A-show cause notice refers to "Benchmarking of REIMBUSEMENT OF MARKETING

DIRECTOR OF INCOME TAX

2 K.B. 459. that if property passed when the documents are transferred that property is subject to the condition that the goods should re-vest in the seller if on an examination by the buyer he finds them not to be in accordance with the contract. It is not necessary to consider this aspect because in any case the ascertainment

ACIT CIRCLE-15(2), NEW DELHI vs. LIFESTYLE PROBUILD PVT LTD, GHAZIABAD

In the result, this appeal by the Revenue stands dismissed

Bench: AO; that valuation report dated 15.03.2012 prepared by the Chartered Accountant as per rule 11UA

55 PB) 2015-16 1,60,00,000 1,72,54,180 12,54,180 2016-17 10,40,08,526 11,05,75,396 65,66,870 2017-18 11,36,66,099 12,32,45,382 95,79,283 6.20 Further, the AO mentioned that the assessee has taken unrealistic estimates of revenue growth

DIRECTOR OF INCOME TAX vs. INFRASOFT LTD

55. Article 5 of the DTAA defines and lays down the number of conditions both positive and negative when 2013:DHC:6018 ======================================================================= ITA 1034/2009 Page 87 of 174 an establishment would have a permanent establishment in the other contracting State. 56. In the present case, it is an admitted position that the Respondent Assessee has a branch office in India

SRF LTD.,NEW DELHI vs. ACIT, NEW DELHI

In the result, the appeal being ITA No

Bench: Shris.Rifaur Rahman & Shri Sudhir Pareek

2. Interest subsidy under Technology Upgradation Fund (TUF) Scheme: 23. During the year, Assessee had obtained loan of Rs. 6,250 Lacs from SBI and Rs. 3,500 Lacs from State Bank of Mysore under TUF Scheme issued by the ministry of textile, Government of India. Whether the Loan was utilized as per the scheme is not under question. Under

SRF LIMITED,NEW DELHI vs. DCIT, CIRCLE- 1, LTU, NEW DELHI

In the result, the appeal being ITA No

Bench: Shris.Rifaur Rahman & Shri Sudhir Pareek

2. Interest subsidy under Technology Upgradation Fund (TUF) Scheme: 23. During the year, Assessee had obtained loan of Rs. 6,250 Lacs from SBI and Rs. 3,500 Lacs from State Bank of Mysore under TUF Scheme issued by the ministry of textile, Government of India. Whether the Loan was utilized as per the scheme is not under question. Under

ADDL. CIT, SPECIAL RANGE- 7, NEW DELHI vs. ONGC VIDESH LTD., NEW DELHI

In the result, the appeals of the Revenue stand dismissed

2,496.21 *Inadvertently amount of INR 1,453.31 million has been considered as addition in assessment order • The said figures have been adopted by him on the basis of note to accounts wherein the reinstated value of claim made by EPC contractor and claim made to MEM had been reported.” 21. Having heard both the counsels and perusing the record

ADDL. CIT, SPECIAL RANGE-7, NEW DELHI vs. ONGC VIDESH LTD., NEW DELHI

In the result, the appeals of the Revenue stand dismissed

2,496.21 *Inadvertently amount of INR 1,453.31 million has been considered as addition in assessment order • The said figures have been adopted by him on the basis of note to accounts wherein the reinstated value of claim made by EPC contractor and claim made to MEM had been reported.” 21. Having heard both the counsels and perusing the record

ADDL. CIT, SPECIAL RANGE-7, NEW DELHI vs. ONGC VIDESH LTD., NEW DELHI

In the result, the appeals of the Revenue stand dismissed

2,496.21 *Inadvertently amount of INR 1,453.31 million has been considered as addition in assessment order • The said figures have been adopted by him on the basis of note to accounts wherein the reinstated value of claim made by EPC contractor and claim made to MEM had been reported.” 21. Having heard both the counsels and perusing the record

ADDL. CIT,SPL RNAGE-7, NEW DELHI vs. ONGC VIDESH LTD., NEW DELHI

In the result, the appeals of the Revenue stand dismissed

2,496.21 *Inadvertently amount of INR 1,453.31 million has been considered as addition in assessment order • The said figures have been adopted by him on the basis of note to accounts wherein the reinstated value of claim made by EPC contractor and claim made to MEM had been reported.” 21. Having heard both the counsels and perusing the record

DCIT, NEW DELHI vs. M/S. ONGC VIDESH LTD., NEW DELHI

In the result, the appeals of the Revenue stand dismissed

2,496.21 *Inadvertently amount of INR 1,453.31 million has been considered as addition in assessment order • The said figures have been adopted by him on the basis of note to accounts wherein the reinstated value of claim made by EPC contractor and claim made to MEM had been reported.” 21. Having heard both the counsels and perusing the record

DCIT, NEW DELHI vs. M/S. ONGC VIDESH LTD., NEW DELHI

In the result, the appeals of the Revenue stand dismissed

2,496.21 *Inadvertently amount of INR 1,453.31 million has been considered as addition in assessment order • The said figures have been adopted by him on the basis of note to accounts wherein the reinstated value of claim made by EPC contractor and claim made to MEM had been reported.” 21. Having heard both the counsels and perusing the record

DCIT, NEW DELHI vs. M/S. ONGC VIDESH LTD., NEW DELHI

In the result, the appeals of the Revenue stand dismissed

2,496.21 *Inadvertently amount of INR 1,453.31 million has been considered as addition in assessment order • The said figures have been adopted by him on the basis of note to accounts wherein the reinstated value of claim made by EPC contractor and claim made to MEM had been reported.” 21. Having heard both the counsels and perusing the record

ADDL. CIT, NEW DELHI vs. M/S ONGC VIDESH LTD.,, NEW DELHI

In the result, the appeals of the Revenue stand dismissed

2,496.21 *Inadvertently amount of INR 1,453.31 million has been considered as addition in assessment order • The said figures have been adopted by him on the basis of note to accounts wherein the reinstated value of claim made by EPC contractor and claim made to MEM had been reported.” 21. Having heard both the counsels and perusing the record

ACIT, NEW DELHI vs. M/S ADVANTAGE FASHION PVT. LTD.,, NEW DELHI

Accordingly, the order of the CIT(A) on this issue is also affirmed, and the Ground No. 5 raised by the Revenue in AY 2011-12 is also dismissed

Bench: Shri G.S. Pannu, Hon’Ble & Shri Challa Nagendra Prasad, Hon’Ble

55 to 46 A41 Vatika Triangle Landbase Sushant Lok-1, M.G. Kumari Pvt. Ltd., Road, Gurgaon Wonder Developers Pvt. Ltd. Span India Vatika 31.03.2006 35 to 30 A41 Vatika Triangle Pvt. Ltd. Landbase Sushant Lok-1, M.G. Pvt. Ltd., Road, Gurgaon Buzz Estates Pvt. Ltd. v. The lender and Borrower group concern entered into again guarantee agreement to secure right

ACIT, NEW DELHI vs. M/S ADVANTAGE FASHION PVT. LTD.,, NEW DELHI

Accordingly, the order of the CIT(A) on this issue is also affirmed, and the Ground No. 5 raised by the Revenue in AY 2011-12 is also dismissed

Bench: Shri G.S. Pannu, Hon’Ble & Shri Challa Nagendra Prasad, Hon’Ble

55 to 46 A41 Vatika Triangle Landbase Sushant Lok-1, M.G. Kumari Pvt. Ltd., Road, Gurgaon Wonder Developers Pvt. Ltd. Span India Vatika 31.03.2006 35 to 30 A41 Vatika Triangle Pvt. Ltd. Landbase Sushant Lok-1, M.G. Pvt. Ltd., Road, Gurgaon Buzz Estates Pvt. Ltd. v. The lender and Borrower group concern entered into again guarantee agreement to secure right