PR. COMMISSIONER OF INCOME TAX vs. SMT. G. LAKSHMI ARUNA

Bench: K.SOMASHEKAR,UMESH M ADIGA

TDS 28,20,543 Balance Tax 14,76,04,186 Less: Advance Tax 7,50,00,000 Balance Tax 7,26,04,186 Add: Interest u/s234A – 1,30,68,753 235B – 1,59,97,806 2,90,66,559 13 Total Tax 10,16,70,745 Less: 140A paid 2,00,00,000 Net Amount Payable

PR. COMMISSIONER OF INCOME TAX vs. SHRI. GALI JANARDHANA REDDY

Bench: K.SOMASHEKAR,UMESH M ADIGA

TDS 28,20,543 Balance Tax 14,76,04,186 Less: Advance Tax 7,50,00,000 Balance Tax 7,26,04,186 Add: Interest u/s234A – 1,30,68,753 12 235B – 1,59,97,806 2,90,66,559 Total Tax 10,16,70,745 Less: 140A paid 2,00,00,000 Net Amount Payable

THE PRINCIPAL COMMISSIONER vs. M/S OBULAPURAM MINING

Bench: K.SOMASHEKAR,UMESH M ADIGA

TDS, stated that they have not rendered any services to the assessee. It was found that some of them never owned any transportation vehicles and some of them did not have any means. Further, some of the vehicles were not transport vehicles but were autos, scooters, ambulances and school buses etc. However, on an examination of the bank accounts

THE PR. COMMISSIONER OF INCOME-TAX vs. M/S. TE CONNECTIVITY INDIA PVT. LTD.,

Accordingly dispose of the appeal as allowed

Bench: ACTING CHIEF JUSTICE,S RACHAIAH

1), 2ND FLOOR, BMTC BUILDING, 80 FEET ROAD, KORMANGALA, BENGALURU - 560 095. ...APPELLANTS (BY SRI. SUSHAL TIWARI N, ADVOCATE) AND: M/S. TE CONNECTIVITY INDIA PVT. LTD., TE PARK, 22B, DODDENAKUNDI CORPORATION, 2ND PHASE, INDUSTRIAL AREA, WHITEFIELD ROAD, BENGALURU - 560 048. PAN: AABCT7474C …RESPONDENT (BY SRI. K. SURYANARAYANA, SENIOR ADVOCATE FOR SMT. TANMAYEE RAJKUMAR, ADVOCATE) THIS ITA IS FILED UNDER SECTION

THE PR. COMMISIONER OF INCOME TAX vs. M/S. GMR INFRASTRUCTURE LTD

Appeals stand disposed of accordingly

Bench: S.SUJATHA,RAVI V HOSMANI

TDS on payments made to Director’s towards sitting fees by holding that - 16 - the amendment will apply for A.Y.2014-15 onwards?” In ITA No.381/2018: “1. Whether on the facts and in the circumstances of the case and in law the Tribunal was correct in law in holding that incriminating material is necessary condition for proceedings under Section 153A

PR COMMISSIONER OF vs. M/S GMR HYDERABAD

Appeals stand disposed of accordingly

Bench: S.SUJATHA,RAVI V HOSMANI

TDS on payments made to Director’s towards sitting fees by holding that - 16 - the amendment will apply for A.Y.2014-15 onwards?” In ITA No.381/2018: “1. Whether on the facts and in the circumstances of the case and in law the Tribunal was correct in law in holding that incriminating material is necessary condition for proceedings under Section 153A

PR COMMISSIONER OF vs. M/S GMR HYDERABAD

Appeals stand disposed of accordingly

Bench: S.SUJATHA,RAVI V HOSMANI

TDS on payments made to Director’s towards sitting fees by holding that - 16 - the amendment will apply for A.Y.2014-15 onwards?” In ITA No.381/2018: “1. Whether on the facts and in the circumstances of the case and in law the Tribunal was correct in law in holding that incriminating material is necessary condition for proceedings under Section 153A

PR COMMISSIONER OF vs. M/S GMR HYDERABAD

Appeals stand disposed of accordingly

Bench: S.SUJATHA,RAVI V HOSMANI

TDS on payments made to Director’s towards sitting fees by holding that - 16 - the amendment will apply for A.Y.2014-15 onwards?” In ITA No.381/2018: “1. Whether on the facts and in the circumstances of the case and in law the Tribunal was correct in law in holding that incriminating material is necessary condition for proceedings under Section 153A

PR COMMISSIONER OF vs. M/S GMR HYDERABAD

Appeals stand disposed of accordingly

Bench: S.SUJATHA,RAVI V HOSMANI

TDS on payments made to Director’s towards sitting fees by holding that - 16 - the amendment will apply for A.Y.2014-15 onwards?” In ITA No.381/2018: “1. Whether on the facts and in the circumstances of the case and in law the Tribunal was correct in law in holding that incriminating material is necessary condition for proceedings under Section 153A

PR. COMMISSIONER OF INCOME TAX (CENTRAL) vs. M/S. DELHI INTERNATIONAL AIRPORT PVT. LTD.,

Appeals stand disposed of accordingly

Bench: S.SUJATHA,RAVI V HOSMANI

TDS on payments made to Director’s towards sitting fees by holding that - 16 - the amendment will apply for A.Y.2014-15 onwards?” In ITA No.381/2018: “1. Whether on the facts and in the circumstances of the case and in law the Tribunal was correct in law in holding that incriminating material is necessary condition for proceedings under Section 153A

PR COMMISSIONER OF vs. M/S GMR HYDERABAD

Appeals stand disposed of accordingly

Bench: S.SUJATHA,RAVI V HOSMANI

TDS on payments made to Director’s towards sitting fees by holding that - 16 - the amendment will apply for A.Y.2014-15 onwards?” In ITA No.381/2018: “1. Whether on the facts and in the circumstances of the case and in law the Tribunal was correct in law in holding that incriminating material is necessary condition for proceedings under Section 153A

THE PR. COMMISIONER OF INCOME TAX vs. M/S. GMR INFRASTRUCTURE LTD

Appeals stand disposed of accordingly

Bench: S.SUJATHA,RAVI V HOSMANI

TDS on payments made to Director’s towards sitting fees by holding that - 16 - the amendment will apply for A.Y.2014-15 onwards?” In ITA No.381/2018: “1. Whether on the facts and in the circumstances of the case and in law the Tribunal was correct in law in holding that incriminating material is necessary condition for proceedings under Section 153A

PR COMMISSIONER OF vs. M/S GMR HYDERABAD

Appeals stand disposed of accordingly

Bench: S.SUJATHA,RAVI V HOSMANI

TDS on payments made to Director’s towards sitting fees by holding that - 16 - the amendment will apply for A.Y.2014-15 onwards?” In ITA No.381/2018: “1. Whether on the facts and in the circumstances of the case and in law the Tribunal was correct in law in holding that incriminating material is necessary condition for proceedings under Section 153A

THE PR. COMMISIONER INCOME TAX vs. M/S. GMR INFRASTRUCTURE LTD

Appeals stand disposed of accordingly

Bench: S.SUJATHA,RAVI V HOSMANI

TDS on payments made to Director’s towards sitting fees by holding that - 16 - the amendment will apply for A.Y.2014-15 onwards?” In ITA No.381/2018: “1. Whether on the facts and in the circumstances of the case and in law the Tribunal was correct in law in holding that incriminating material is necessary condition for proceedings under Section 153A

TATA ADVANCED MATERIALS LIMITED

Appeals are allowed

Bench: P.B.BAJANTHRI

1), Sections 4, 5, 9, 90 and 91 of the Act, the provisions of the DTAA are relevant while applying the provisions of deduction of TDS. Re: Question No. 2 as follows:  that the payments made by assessee to the NTOs18 could not be characterised as royalty, as payment is made to use the process or an equipment

THE PR COMMISSIONER OF INCOME TAX vs. SHRI H NAGARAJA

Bench: S SUNIL DUTT YADAV,B.S PATIL

Section 263(1)(c) of the Act; (2) In so far as expenses on purchase of land and profit from sale of property to Brigade Enterprises, as regards lands situated at Kaggalipura for the assessment years in question, the same did not tally, and therefore, the Revisional Commissioner was justified in exercising revisional jurisdiction; (3) In respect of the expenses

THE COMMISSIONER OF INCOME TAX vs. M/S AD2PRO MEDIA SOLUTIONS PVT LTD

Appeals are dismissed

Bench: P.S.DINESH KUMAR,RAMACHANDRA D. HUDDAR

263 CTR 549 ITA No. 232/2020 C/W ITAs No. 234/2020, 235/2020, 238/2020, 241/2020, 242/2020, 243/2020 14  as per Section 195 of the Act, the person responsible for paying a non-resident is liable to with-hold tax, provided the sums are income accruing or deemed to accrue or arise in India in accordance with Section

M/S EMBASSY BRINDAVAN DEVELOPERS vs. THE COMMISSIONER OF INCOME TAX

Appeal is allowed

Bench: P.S.DINESH KUMAR,UMESH M ADIGA

TDS deducted and remitted Interest Paid to Brindavan Beverages Pvt. Ltd 1,27,85,500/- Not applicable* Professional charges to Sri.Anup Shah 90,000/- 10,197/- Professional charges to M/s.Ahir Consultancy 11,23,600/- 1,27,304/- Brokerage to Daulat Chhabria 33,70,800/- 3,81,912/- Brokerage to Sadhawani International 28,09,000/- 3,18,260/- 15. None