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

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

3. Persistent System Limited (a) Functionally not comparable – Persistent systems is engaged in provision of outsourced product development services for independent software vendors and enterprises, which is different in nature from IT services. The company derives income from both software services & products. (b) Segmental information not available – P&L shows income from “sale of software services & Products. However, no break

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

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

3. Persistent System Limited (a) Functionally not comparable – Persistent systems is engaged in provision of outsourced product development services for independent software vendors and enterprises, which is different in nature from IT services. The company derives income from both software services & products. (b) Segmental information not available – P&L shows income from “sale of software services & Products. However, no break

GRAPHITE INDIA LTD.,KOLKATA vs. ADDI. COMMISSIONER OF INCIME TAX, RANGE - 11, KOLKATA

In the result, the appeal of the assessee is partly allowed as indicated above

Bench: Shri P.M. Jagtap & Shri S.S. Viswanethra Ravi

3 different amounts for the same tour. The discrepancy in claim of expenses is very much apparent and abnormal. Considering the amount of expenditure claimed on different expenses the sum of Rs.5,612/- is only considered to have been incurred for the purpose of the business. The other 2 entries for Rs.2,965/- is therefore considered not to have been

NATWEST MARKETS PLC,KOLKATA vs. ASSISTANT COMMISSIONER OF INCOME TAX, INTERNATIONAL TAXATION - 1(2), KOLKATA

In the result the appeal of the assessee is allowed

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm Asst. Commissioner Of Natwest Markets Plc Income Tax 907, Regus, 9Th Floor, Ps Arcadia, 4A, Abanindra Nath Aaykar Bhavan, 2 Nd Floor, Vs. Thakur Sarani, Kolkata, West 110, Shanti Pally, Kolkata, Bengal-700016 West Bengal 700017 (Appellant) (Respondent) Pan No. Aacct8020E Assessee By : Shri Parcy Pardiwalla, Ar Revenue By : Shri Praveen Kishore, Dr Date Of Hearing: 26.09.2024 Date Of Pronouncement : 27.11.2024 O R D E R

3) read with section 144C(13) of the Act dated 27.01.2023, wherein the ld. AO reiterated the finding given by him in the draft assessment order, save and except that he held that interest of ₹6,18,50,000/- could not be added to the assessee’s income u/s 68 of the Act but it should be added

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

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

In the result, appeal of the assessee is allowed partly

68,623/- 17.1. The issue is covered in favour The issue is covered in favour of the assessee by the order of the Hon’ble by the order of the Hon’ble Tribunal in appellant’s own case for Tribunal in appellant’s own case for AY 2003-04 in [ITA No. 1521/Kol/2013] [ITA No. 1521/Kol/2013], wherein the coordinate Bench

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

3. The Ld. CIT(A) held that sub-section (2A) of Section 115JAA only speaks about tax credit and does not mention cess and therefore upheld the order I.T.A. No.: 223/KOL/2025 Assessment Year: 2012-13 Universal Trading Company Limited. of the CPC. Aggrieved by the order of the Ld. CIT(A), the assessee is in appeal before your

PRICEWATERHOUSE COOPERS PVT. LTD.,KOLKATA vs. D.C.I.T., CIRCLE - 1(1),, KOLKATA

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

Bench: Shri George Mathan & Shri Rakesh Mishra

3. That on the facts and in the circumstances of the case and in law, the Ld. CIT (Appeals), erred in not considering the claim (made during the course of assessment proceedings) of business expenses of Rs. 2,68,57,702 pertaining to AY 2020-21, but debited and already disallowed in subsequent AY 2021-22, by merely stating that

NATWEST MARKETS PLC - INDIA BRANCH,KOLKATA vs. CIT (IT & TP), CIR- 1(2), KOLKATA, KOLKATA

In the result the appeal of the assessee is allowed

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm Commissioner Of Income Tax Natwest Markets Plc-India (International Taxation & Branch Transfer Pricing) 907, Regus, 9Th Floor, Ps Aaykar Bhavan Poorva, Vs. Arcadia, 4A, Abanindra Nath 2Nd Floor, 110, Shanti Pally, Thakur Sarani, Kolkata-700016 Kolkata-700107, West Bengal (Appellant) (Respondent) Pan No. Aacct8020E Assessee By : Shri Percy Pardiwala, Ar Revenue By : Shri Sandeep Lakra, Dr Date Of Hearing: 31.07.2025 Date Of Pronouncement: 26.08.2025

3) read with section 144C(13) of the Act dated 27.01.2023, wherein the ld. AO reiterated the finding given by him in the draft assessment order, save and except that he held that interest of ₹6,18,50,000/- could not be added to the assessee’s income u/s 68 of the Act but it should be added

NAT WEST MARKETS PLC- INDIA BRANCH ,KOLKATA vs. ACIT(I.T)-1(2), KOLKATA. , KOLKATA

In the result, the appeal of the assessee is allowed

Bench: Shri Rajesh Kumar, Am & Shri Sonjoy Sarma, Jm Nat West Markets Plc-India Acit (I.T)-1(2), Kolkata Branch Aaykar Bhavan Poorva, 2 Nd 907, Regus, 9Thfloor, Floor, Psarcadia,4A, Abandindra Nath Vs. 110, Shanti Pally, Thakur Sarani, Kolkata-700016, Kolkata-700107, West Bengal West Bengal (Appellant) (Respondent) Pan No. Aacct8020E Assessee By : Shri Percy Pardiwala, Ar Revenue By : Shri Gaurav Kanujia, Dr Date Of Hearing: 15.01.2025 Date Of Pronouncement : 31.01.2025

3) read with section 144C(13) of the Act dated 27.01.2023, wherein the ld. AO reiterated the finding given by him in the draft assessment order, save and except that he held that interest of ₹6,18,50,000/- could not be added to the assessee’s income u/s 68 of the Act but it should be added

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