M/S TEGA INDUSTRIES LTD.,KOLKATA vs. DCIT, CIRCLE-11(1), KOLKATA

In the result, the appeal filed by the assessee is partly allowed

Bench: Shri George Mathan & Shri Rakesh Mishra

244A of the Act to the appellant.” I.T.A. No.: 2597/KOL/2024 Assessment Year: 2021-22 M/s. Tega Industries Ltd. 3. Brief facts of the case are that the assessee filed its return of income for AY 2021-22 on 15.03.2022 declaring total income of ₹ 118,64,50,672/-. The assessee company is engaged in the business of providing customized solutions

M/S. PRICEWATERHOUSE COOPERS PRIVATE LIMITED,KOLKATA vs. ACIT, CIRCLE - 2(2), KOLKATA, KOLKATA

In the result, appeal of the assessee is allowed partly

gains of business or profession”, - ….. 13 Assessment Year: 2009-10 M/s. Pricewaterhouse Coopers Private Limited M/s. Pricewaterhouse Coopers Private Limited (iv) the value of any benefit or perquisite, whether convertible into money or not, (iv) the value of any benefit or perquisite, whether convertible into money or not, (iv) the value of any benefit or perquisite, whether convertible into money

M/S THE RIGHT ADDRESS LTD.,KOLKATA vs. THE INCOME TAX OFFICER,(TDS) WARD-59(4) (TDS),KOLKATA KOLKATA, KOLKATA

In the result, Revenue’s appeal stands dismissed and assessee’s appeals are allowed

Bench: Shri Waseem Ahmed & Shri K.Narasimha Chary

section 201 (lA) for the said years and the assessee had accepted the said finding. " In the case of Thomas Muthoot vs. DCIT (2012) 34 CCH 0170 (copy enclosed at Page 1-12 of the Paper Book), the Cochin Tribunal discussed the case of the assessee in detail. In this case, the assessee failed to deduct the TDS on payments

DCIT, CIR-12(2), KOLKATA, KOLKATA vs. M/S PHILIPS INDIA LTD., KOLKATA

Bench: Shri N.V.Vasudevan & Shri Waseem Ahmed

244A of the Act. 13. Penalty u/s 271(1)(c) 13.1. The Learned AO erred in initiating penalty proceedings under section 271 (1)(c) of the Act. 14. Dividend Distribution Tax 14.1 The learned AO erred in wrongly computing additional tax and interest payable on distributed profit of Rs. 4,44,320 without assigning any reason thereto. The appellant submits

M/S PHILIPS INDIA LTD.,KOLKATA vs. DCIT, CIR-12(2), KOLKATA, KOLKATA

Bench: Shri N.V.Vasudevan & Shri Waseem Ahmed

244A of the Act. 13. Penalty u/s 271(1)(c) 13.1. The Learned AO erred in initiating penalty proceedings under section 271 (1)(c) of the Act. 14. Dividend Distribution Tax 14.1 The learned AO erred in wrongly computing additional tax and interest payable on distributed profit of Rs. 4,44,320 without assigning any reason thereto. The appellant submits

PRICE WATERHOUSE & CO., [NOW KNOWN AS PRICE WATERHOUSE & CO. CHARTERED ACCOUNTANTS LLP],KOLKATA vs. DCIT, CIRCLE - 22, , KOLKATA

In the result, appeal filed by the assessee is allowed

Bench: Shri A. T. Varkey, Jm & Dr. A.L. Saini, Am Vs. Dcit, Circle-22, Kolkata Price Waterhouse & Co, Kolkata (Now Versus Known As Price Waterhouse & Co Chartered Accountants Llp)

244A of the Income-tax Act, 1961 as per the relevant provisions of the Act. The Assessee submits that the above grounds are independent and without prejudice to one another. The Assessee desires leave to add to or alter, by deletion, substitution or otherwise, any or all of the above grounds of objections, at any time before or during

ITO, WD-36(4), KOLKATA, KOLKATA vs. THE NEW INDIA ASSURANCE CO LTD., KOLKATA

In the result, the appeal of the revenue is allowed for statistical purposes

244A of the Act and interest earned on FDs from bank should be assessed under the ‘profit & gains of business’. 3 6. The CIT-A after considering the above submissions and the case laws as relied on by the assessee of Mumbai Tribunal, allowed the claim of the assessee by observing as under:- DECISION: I have carefully considered the assessment

AVR STORAGE TANK TERMINALS PVT. LTD.,KOLKATA vs. D.C.I.T., CIRCLE - 11(1), KOLKATA, KOLKATA

In the result, the appeal is allowed for statistical purposes

Bench: Shri Sanjay Garg & Shri Rakesh Mishraassessment Year: 2020-21

capital gains chargeable to income-tax as per the revised computation furnished by the appellant during the course of assessment proceedings. 4. a) That on the facts and in the circumstances of the case, the NFAC erred in not directing the Assessing Officer to allow depreciation as per the revised computation of depreciation furnished by the appellant during the course

M/S SURRENDRA PAUL(HUF),KOLKATA vs. D.C.I.T CC - III,KOLKATA, KOLKATA

In the result, the appeal of the assessee is allowed

Bench: Shri M. Balaganesh, Am & Shri K. Narasimha Chary, Jm]

Capital Gains. This return was revised subsequently declaring total income of Rs.3,92,94,781/- which included LTCG of Rs.3,92,66,534/-. The tax payable on this revised return is as under: Tax on LTCG @ 20% 78,38,956 Surcharge 7,83,896 Education Cess 1,72,457 Total tax payable 87,95,309 Less: Advance Tax (Paid

M/S. SALARPURIA PROPERTIES PVT. LTD., ,KOLKATA vs. DCIT, CIRCLE - 1, KOLKATA, KOLKATA

In the result, assessee’s appeal in ITA No

Bench: Shri Sanjay Garg & Shri Rajesh Kumar]

244A of the Act as the assessee is entitled to on the amount of Refund claimed in the Return. 7. For that your petitioner craves the right to put additional grounds and / or to alter / amend / modify the present grounds before or at the time of hearing. 3. The issue raised in ground no. 1 & 2 is against the order

UNIVERSAL TRADING COMPANY LIMITED,KOLKATA vs. DCIT, CIRCLE 5(1), KOLKATA

In the result, the appeal filed by the assessee is partly allowed for statistical purposes

Bench: Shri Pradip Kumar Choubey & Shri Rakesh Mishra

capital of the company.] 8. On perusal of the above, it shall be noted that, u/s 115O(1) of the Act, an assessee company is required to pay additional income tax on the dividends distributed or paid by the company. Sub-section (1A) further provides that, the amount on which such additional income tax is payable shall be reduced

THE ROYAL BANK OF SCOTLAND N.V.,KOLKATA vs. DCIT, ( INTERNATIONAL TAXATION) CIR-2(1), KOLKATA, KOLKATA

In the result, the appeals of the assessee are partly allowed for statistical purposes

Bench: Hon’Ble Shri S.S.Godara, Jm & Shri M.Balaganesh, Am ] I.T.A Nos. 36 & 1885/Kol/2017 Assessment Year : 2012-13 & 2013-14 M/S Royal Bank Of Scotland N.V. -Vs- Dcit (It), Circle-2(1), Kolkata [Pan: Aacca 6818 K] (Appellant) (Respondent)

gains of business or profession". In this regard, the asseessee relied on the following decisions: • CIT v. High Land Produce Co. Ltd. [1986] 158ITR 419 (SC) • Liberty Cinema V. Commissioner of Income-tax [1964] 52 ITR 153, 161 / (Cal.), • Decom Marketing (P.) Ltd. v. CIT (164 CTR 230). • RDB Industries Ltd vs DCIT 120 ITJ 107 (Kol). • CIT v. Punjab

THE ROYAL BANK OF SCOTLAND N.V.,KOLKATA vs. DCIT, ( INTERNATIONAL TAXATION) CIR-2(1), KOLKATA, KOLKATA

In the result, the appeals of the assessee are partly allowed for statistical purposes

Bench: Hon’Ble Shri S.S.Godara, Jm & Shri M.Balaganesh, Am ] I.T.A Nos. 36 & 1885/Kol/2017 Assessment Year : 2012-13 & 2013-14 M/S Royal Bank Of Scotland N.V. -Vs- Dcit (It), Circle-2(1), Kolkata [Pan: Aacca 6818 K] (Appellant) (Respondent)

gains of business or profession". In this regard, the asseessee relied on the following decisions: • CIT v. High Land Produce Co. Ltd. [1986] 158ITR 419 (SC) • Liberty Cinema V. Commissioner of Income-tax [1964] 52 ITR 153, 161 / (Cal.), • Decom Marketing (P.) Ltd. v. CIT (164 CTR 230). • RDB Industries Ltd vs DCIT 120 ITJ 107 (Kol). • CIT v. Punjab

M/S PHILLIPS INDIA LIMITED,KOLKATA vs. ACIT, CIR-12(2), KOLKATA, KOLKATA

In the result, the appeal of the assessee is allowed for statistical purposes

Bench: Hon’Ble Shri N.V.Vasudevan, Jm & Hon’Ble Shri M.Balaganesh, Am ] I.T.A No. 612/Kol/2017 Assessment Year : 2012-13 M/S Philips India Ltd. -Vs- Acit, Circle-12(2), Kolkata (Formerly Philips Electronics India Ltd.) [Pan: Aabcp 9487 A] (Appellant) (Respondent)

gain economies of scale through the concentration of activities. These services may vary from being very simple administrative functions to more complex industry specific functions. The decision to provide certain services centrally may also be determined by the need to have the best practices implemented across geographies. Thus it can be said that the needs and benefits of Intra-group