ACIT, CIRCLE- 1, LTU, NEW DELHI vs. C&S ELECTRIC LTD., NEW DELHI

In the result, the revenue’s appeal stands dismissed as above

Bench: Shri Yogesh Kumar U.S. & Shri Avdhesh Kumar Mishraita No. 2622/Del/2018, A.Y. 2013-14 Ita No. 2623/Del/2018, A.Y. 2014-15 Ita No. 7981/Del/2018, A.Y. 2015-16 C & S Electric Limited Deputy Commissioner Of 222, Okhla Industrial Estate Income Tax, Phase-Iii, New Delhi Vs. Circle-1, Ltu, New Delhi Pan: Aaacc0909K (Appellant) (Respondent) Ita No. 2532/Del/2018, A.Y.2013-14 Ita No. 2533/Del/2018, A.Y.2014-15 Ita No. 8274/Del/2018, A.Y.2015-16 Deputy Commissioner Of C & S Electric Limited Income Tax, (Formerly Controls & Circle-1, Ltu, Vs. Switchgear Co. Ltd.) New Delhi 222, Okhla Industrial Estate, Phase-Iii, New Delhi Pan: Aaacc0909K (Appellant) (Respondent) Appellant By Sh. Anil Bhalla, Ca Respondent By Sh. Rajesh Kumar Dhanesta, Sr. Dr Date Of Hearing 05/06/2025 Date Of Pronouncement 30/06/2025 Order Per Bench Cross Appeal By The Assessee & Revenue Containing Common Facts Were Heard Together Being Inter-Connected With Each Other & Are Being Disposed Off By This Common Order. Ita No.2532, 2533 & 8274/Del/2018 C & S Electric Ltd. 2. These Appeals Filed By The Assessee & Revenue Are Directed Against Orders Dated 10.01.18 & 25.09.2018 Respectively Of The Commissioner Of Income Tax (Appeals)-22, New Delhi [‘Cit(A)’].

transfer rate from Non 80IC units to 80C unit. 3. On the facts and in the circumstances of the case and in law Ld. CIT(A) has erred in directing the Assessing Officer not to allocate expenses amounting to Rs. 66,57,651/- on depreciation as applied for allocating the expenses of salaries of CMD/MD, interest expenses pertaining

C & S ELECTRIC LTD.,NEW DELHI vs. DCIT, CIRCLE- 1, LTU, NEW DELHI

In the result, the revenue’s appeal stands dismissed as above

Bench: Shri Yogesh Kumar U.S. & Shri Avdhesh Kumar Mishraita No. 2622/Del/2018, A.Y. 2013-14 Ita No. 2623/Del/2018, A.Y. 2014-15 Ita No. 7981/Del/2018, A.Y. 2015-16 C & S Electric Limited Deputy Commissioner Of 222, Okhla Industrial Estate Income Tax, Phase-Iii, New Delhi Vs. Circle-1, Ltu, New Delhi Pan: Aaacc0909K (Appellant) (Respondent) Ita No. 2532/Del/2018, A.Y.2013-14 Ita No. 2533/Del/2018, A.Y.2014-15 Ita No. 8274/Del/2018, A.Y.2015-16 Deputy Commissioner Of C & S Electric Limited Income Tax, (Formerly Controls & Circle-1, Ltu, Vs. Switchgear Co. Ltd.) New Delhi 222, Okhla Industrial Estate, Phase-Iii, New Delhi Pan: Aaacc0909K (Appellant) (Respondent) Appellant By Sh. Anil Bhalla, Ca Respondent By Sh. Rajesh Kumar Dhanesta, Sr. Dr Date Of Hearing 05/06/2025 Date Of Pronouncement 30/06/2025 Order Per Bench Cross Appeal By The Assessee & Revenue Containing Common Facts Were Heard Together Being Inter-Connected With Each Other & Are Being Disposed Off By This Common Order. Ita No.2532, 2533 & 8274/Del/2018 C & S Electric Ltd. 2. These Appeals Filed By The Assessee & Revenue Are Directed Against Orders Dated 10.01.18 & 25.09.2018 Respectively Of The Commissioner Of Income Tax (Appeals)-22, New Delhi [‘Cit(A)’].

transfer rate from Non 80IC units to 80C unit. 3. On the facts and in the circumstances of the case and in law Ld. CIT(A) has erred in directing the Assessing Officer not to allocate expenses amounting to Rs. 66,57,651/- on depreciation as applied for allocating the expenses of salaries of CMD/MD, interest expenses pertaining

ITO WARD - 10(4), NEW DELHI vs. GHP BUILDCON PVT LTD, NEW DELHI

In the result, the revenue’s appeal stands dismissed as above

Bench: Shri Yogesh Kumar U.S. & Shri Avdhesh Kumar Mishraita No. 2622/Del/2018, A.Y. 2013-14 Ita No. 2623/Del/2018, A.Y. 2014-15 Ita No. 7981/Del/2018, A.Y. 2015-16 C & S Electric Limited Deputy Commissioner Of 222, Okhla Industrial Estate Income Tax, Phase-Iii, New Delhi Vs. Circle-1, Ltu, New Delhi Pan: Aaacc0909K (Appellant) (Respondent) Ita No. 2532/Del/2018, A.Y.2013-14 Ita No. 2533/Del/2018, A.Y.2014-15 Ita No. 8274/Del/2018, A.Y.2015-16 Deputy Commissioner Of C & S Electric Limited Income Tax, (Formerly Controls & Circle-1, Ltu, Vs. Switchgear Co. Ltd.) New Delhi 222, Okhla Industrial Estate, Phase-Iii, New Delhi Pan: Aaacc0909K (Appellant) (Respondent) Appellant By Sh. Anil Bhalla, Ca Respondent By Sh. Rajesh Kumar Dhanesta, Sr. Dr Date Of Hearing 05/06/2025 Date Of Pronouncement 30/06/2025 Order Per Bench Cross Appeal By The Assessee & Revenue Containing Common Facts Were Heard Together Being Inter-Connected With Each Other & Are Being Disposed Off By This Common Order. Ita No.2532, 2533 & 8274/Del/2018 C & S Electric Ltd. 2. These Appeals Filed By The Assessee & Revenue Are Directed Against Orders Dated 10.01.18 & 25.09.2018 Respectively Of The Commissioner Of Income Tax (Appeals)-22, New Delhi [‘Cit(A)’].

transfer rate from Non 80IC units to 80C unit. 3. On the facts and in the circumstances of the case and in law Ld. CIT(A) has erred in directing the Assessing Officer not to allocate expenses amounting to Rs. 66,57,651/- on depreciation as applied for allocating the expenses of salaries of CMD/MD, interest expenses pertaining

DCIT, CIRCLE- 1, LTU, NEW DELHI vs. C & S ELECTRIC LTD., NEW DELHI

In the result, the revenue's appeal stands dismissed as above

transfer rate from\nNon 80IC units to 80C unit.\n3. On the facts and in the circumstances of the case and in law Ld. CIT(A)\nhas erred in directing the Assessing Officer not to allocate expenses\namounting to Rs.66,57,651/- on depreciation as applied for allocating\nthe expenses of salaries of CMD/MD, interest expenses pertaining to car\nloan

C & S ELECTRIC LTD.,NEW DELHI vs. DCIT, CIRCLE- 1, LTU, NEW DELHI

In the result, the revenue's appeal stands dismissed as above

transfer rate from\nNon 80IC units to 80C unit.\n3. On the facts and in the circumstances of the case and in law Ld. CIT(A)\nhas erred in directing the Assessing Officer not to allocate expenses\namounting to Rs.66,57,651/- on depreciation as applied for allocating\nthe expenses of salaries of CMD/MD, interest expenses pertaining to car\nloan

C & S ELECTRIC LTD.,NEW DELHI vs. DCIT, CIRCLE- 1, LTU, NEW DELHI

In the result, the revenue's appeal stands dismissed as above

transfer rate from\nNon 80IC units to 80C unit.\n3. On the facts and in the circumstances of the case and in law Ld. CIT(A)\nhas erred in directing the Assessing Officer not to allocate expenses\namounting to Rs.66,57,651/- on depreciation as applied for allocating\nthe expenses of salaries of CMD/MD, interest expenses pertaining to car\nloan

DLF CYBER CITY DEVELOPERS LTD.,GURUGRAM vs. DCIT, CIRCLE-1, GURUGRAM

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

Bench: Shri C. N. Prasad & Shri M. Balaganeshacit, Vs. Dlf Cyber City Developers Ltd, 3Rd Floor, B-Wing, Shopping Mall Circle-1(1), Gurugram Complex, Arjun Marg, Dkf City, Phase-I, Gurgaon, Haryana (Appellant) (Respondent) Pan: Aaccd3572H Dlf Cyber City Developers Ltd, Vs. Addl. Cit, 3Rd Floor, B-Wing, Shopping Mall Range-I, Complex, Arjun Marg, Dkf City, Gurgaon Phase-I, Gurgaon, Haryana (Appellant) (Respondent) Pan: Aaccd3572H

transferring & handing over specified bare shell buildings located within the project. This MOU of Co-Developer Agreement was approved by the SEZ authorities vide their approval letter bearing Ref. No. F.2/126/2005-EPZ dated 01.05.2007. The clauses of the Addendum to the MOU for appointment of Co- Developer Agreement, inter alia, included that the assessee, being a Developer shall hand over

ACIT, CIRCLE-1(1), GURUGRAM vs. DLF CYBER CITY DEVELOPERS LTD., GURUGRAM

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

Bench: Shri C. N. Prasad & Shri M. Balaganeshacit, Vs. Dlf Cyber City Developers Ltd, 3Rd Floor, B-Wing, Shopping Mall Circle-1(1), Gurugram Complex, Arjun Marg, Dkf City, Phase-I, Gurgaon, Haryana (Appellant) (Respondent) Pan: Aaccd3572H Dlf Cyber City Developers Ltd, Vs. Addl. Cit, 3Rd Floor, B-Wing, Shopping Mall Range-I, Complex, Arjun Marg, Dkf City, Gurgaon Phase-I, Gurgaon, Haryana (Appellant) (Respondent) Pan: Aaccd3572H

transferring & handing over specified bare shell buildings located within the project. This MOU of Co-Developer Agreement was approved by the SEZ authorities vide their approval letter bearing Ref. No. F.2/126/2005-EPZ dated 01.05.2007. The clauses of the Addendum to the MOU for appointment of Co- Developer Agreement, inter alia, included that the assessee, being a Developer shall hand over

DLF CYBER CITY DEVELOPERS LTD.,GURUGRAM vs. DCIT, CIRCLE-1(1), GURUGRAM

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

Bench: Shri C. N. Prasad & Shri M. Balaganeshacit, Vs. Dlf Cyber City Developers Ltd, 3Rd Floor, B-Wing, Shopping Mall Circle-1(1), Gurugram Complex, Arjun Marg, Dkf City, Phase-I, Gurgaon, Haryana (Appellant) (Respondent) Pan: Aaccd3572H Dlf Cyber City Developers Ltd, Vs. Addl. Cit, 3Rd Floor, B-Wing, Shopping Mall Range-I, Complex, Arjun Marg, Dkf City, Gurgaon Phase-I, Gurgaon, Haryana (Appellant) (Respondent) Pan: Aaccd3572H

transferring & handing over specified bare shell buildings located within the project. This MOU of Co-Developer Agreement was approved by the SEZ authorities vide their approval letter bearing Ref. No. F.2/126/2005-EPZ dated 01.05.2007. The clauses of the Addendum to the MOU for appointment of Co- Developer Agreement, inter alia, included that the assessee, being a Developer shall hand over

DLF CYBER CITY DEVELOPERS LTD.,GURUGRAM vs. DCIT, CIRCLE-1(1), GURUGRAM

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

Bench: Shri C. N. Prasad & Shri M. Balaganeshacit, Vs. Dlf Cyber City Developers Ltd, 3Rd Floor, B-Wing, Shopping Mall Circle-1(1), Gurugram Complex, Arjun Marg, Dkf City, Phase-I, Gurgaon, Haryana (Appellant) (Respondent) Pan: Aaccd3572H Dlf Cyber City Developers Ltd, Vs. Addl. Cit, 3Rd Floor, B-Wing, Shopping Mall Range-I, Complex, Arjun Marg, Dkf City, Gurgaon Phase-I, Gurgaon, Haryana (Appellant) (Respondent) Pan: Aaccd3572H

transferring & handing over specified bare shell buildings located within the project. This MOU of Co-Developer Agreement was approved by the SEZ authorities vide their approval letter bearing Ref. No. F.2/126/2005-EPZ dated 01.05.2007. The clauses of the Addendum to the MOU for appointment of Co- Developer Agreement, inter alia, included that the assessee, being a Developer shall hand over

DLF CYBER CITY DEVELOPERS LTD.,GURUGRAM vs. DCIT, CIRCLE-1(1), GURUGRAM

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

Bench: Shri C. N. Prasad & Shri M. Balaganeshacit, Vs. Dlf Cyber City Developers Ltd, 3Rd Floor, B-Wing, Shopping Mall Circle-1(1), Gurugram Complex, Arjun Marg, Dkf City, Phase-I, Gurgaon, Haryana (Appellant) (Respondent) Pan: Aaccd3572H Dlf Cyber City Developers Ltd, Vs. Addl. Cit, 3Rd Floor, B-Wing, Shopping Mall Range-I, Complex, Arjun Marg, Dkf City, Gurgaon Phase-I, Gurgaon, Haryana (Appellant) (Respondent) Pan: Aaccd3572H

transferring & handing over specified bare shell buildings located within the project. This MOU of Co-Developer Agreement was approved by the SEZ authorities vide their approval letter bearing Ref. No. F.2/126/2005-EPZ dated 01.05.2007. The clauses of the Addendum to the MOU for appointment of Co- Developer Agreement, inter alia, included that the assessee, being a Developer shall hand over

DLF CYBER CITY DEVELOPERS LTD.,GURGAON vs. ADDL. CIT, GURGAON

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

Bench: Shri C. N. Prasad & Shri M. Balaganeshacit, Vs. Dlf Cyber City Developers Ltd, 3Rd Floor, B-Wing, Shopping Mall Circle-1(1), Gurugram Complex, Arjun Marg, Dkf City, Phase-I, Gurgaon, Haryana (Appellant) (Respondent) Pan: Aaccd3572H Dlf Cyber City Developers Ltd, Vs. Addl. Cit, 3Rd Floor, B-Wing, Shopping Mall Range-I, Complex, Arjun Marg, Dkf City, Gurgaon Phase-I, Gurgaon, Haryana (Appellant) (Respondent) Pan: Aaccd3572H

transferring & handing over specified bare shell buildings located within the project. This MOU of Co-Developer Agreement was approved by the SEZ authorities vide their approval letter bearing Ref. No. F.2/126/2005-EPZ dated 01.05.2007. The clauses of the Addendum to the MOU for appointment of Co- Developer Agreement, inter alia, included that the assessee, being a Developer shall hand over

INCOME TAX OFFICER, DELHI vs. MOHD RIZWAN, DELHI

In the result, addition of Rs

80C, 80D and 80TTA of the Act.\nThe AO has made addition on account of doubtful purchases on the grounds of non-filing of ITRs, non-availability of suppliers at the given addresses, non-submission of bank statements and invoices by suppliers, cancellation of registration on GST portal, mention of different business on GST Portal and use of small-sized

BHIM SINGH,GURGAON vs. ITO WARD 1(3) , GURGAON

In the result, the appeal of the assessee in ITA No

Bench: Shri Challa Nagendra Prasad & Shri Naveen Chandra

80C &Rs 18,172/- claimed U/s 80Dof the Act. The action of the ld.AO is totally unlawful, unjustified and unreasonable. The deduction claimed deserves to be allowed. 2. On the basis of Facts &circumstances of the case there is no legal warrant or valid justification on the part of learned AO to make addition