DCIT, 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

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

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

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

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

NTT DATA GLOBAL DELIVERY SERVICES LTD.,BANGALORE vs. DCIT, NEW DELHI

The appeal of the assessee is partly allowed

Bench: Shri Bhavnesh Saini & Shri Prashant Maharishintt Data Global Delivery Vs. Dcit, Services Ltd, Circle-13(1), No. 17, South End Road, New Delhi Bangalore Pan: Aabck7777J (Appellant) (Respondent)

transfer pricing adjustment also during the course of assessment proceedings. Consequently, the returned income of the assessee of INR 30 170 320720/– was assessed at INR 70 21138145/– wide order under section 143 (3) of the income tax act wide order dated 28/3/2013. 4. The order of the learned AO was challenged before the learned CIT – A. He passed

DCIT, CIRCLE- 2, MEERUT vs. SARVA UP GRAMIN BANK, MEERUT

In the result, the appeal of the revenue is dismissed

Bench: Shri Kul Bharat & Shri Anadee Nath Misshra

Transfer Pricing Officer vide his order dated 29.09.2017 u/s 92CA(3) has not found any thing adverse in the case of the assessee. The appellant has admitted in its submissions as well as before A.O regarding the entitlement of deduction U/s 36(l)(viia) of Rs 171.72 crores. There is no dispute as to the correctness of the calculation

SMT. NEELAM HANDA,DELHI vs. ITO, NEW DELHI

In the result, appeal of the assessee is allowed

Bench: Smt Diva Singh & Shri Prashant Maharishineelam Handa, Ito, C-7/7, Ground Floor, Ward-20(4), Vs. Model Town-Iii, Delhi New Delhi Pan: Abgph5388D (Appellant) (Respondent)

price was not utilised for construction of the building and it was deposited in an approved bank. The assessee took a plea before the appellate authorities that he had completed the construction of a house in Calicut on December 31, 1983 at a cost of Rs. 2,98,300, the cost of the building which he had sold was valued

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

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, 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

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

GREAT EASTERN EXPORTS vs. ASSISTANT COMMISSIONER OF INCOME TAX

Bench: CASES PERTAINING TO SPL.DIVISION BENCHES

80C to 80U. (2) The aggregate amount of the deductions under this Chapter shall not, in any case, exceed the gross total income of the assessee. (3) Where, in computing the total income of an association of persons or a body of individuals, any deduction is admissible under section 80G or [section 80GGA or section 80GGC] or section 80HH

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

DCIT, DEHRADUN vs. SH. RAMESH BATTA, DEHRADUN

In the result, the Cross

Bench: Shri S.V. Mehrotra & Ms. Suchitra Kambleassessment Year : 2007-08 Dcit, Central Circle, Ramesh Batta, Dehradun. Vs. 81/210, Kaulagarh Road, Dehradun.

80C 1,00,000/- 1,85,95,313/- Rounded off as per section 288A 1,85,95,310/- 4. Ld. CIT(A), while partly allowing the assessee’s appeal, confirmed the addition in principle on account of sale of Plot No.91 to Aggarwal Associates Ltd. and deleted the addition in regard to profit of business in regard to Sailok land