DCIT(CC)-8(3), MUMBAI vs. 63 MOONS TECHNOLOGIES LIMITED, MUMBAI

In the result, appeal of the Revenue is dismissed

Bench: Shri Sandeep Gosain & Shri Girish Agrawal

purchase of New Computers, Plant & Machinery were submitted. vii. The assessee company has exported the computer software and earned income from rendering Computer Software related services abroad. Copies of sample invoices along with copies of SOFTEX form filed with custom department. viii. The assessee has received consideration in respect of export into India. (Copy of statement and Certificate of Foreign

DCIT(CC)-8(3), MUMBAI vs. 63 MOONS TECHNOLOGIES LIMITED, MUMBAI

In the result, appeal of the Revenue is dismissed

Bench: Shri Sandeep Gosain & Shri Girish Agrawal

purchase of New Computers, Plant & Machinery were submitted. vii. The assessee company has exported the computer software and earned income from rendering Computer Software related services abroad. Copies of sample invoices along with copies of SOFTEX form filed with custom department. viii. The assessee has received consideration in respect of export into India. (Copy of statement and Certificate of Foreign

DCIT(CC)-8(3), MUMBAI vs. 63 MOONS TECHNOLOGIES LIMITED, MUMBAI

In the result, appeal of the Revenue is dismissed

Bench: Shri Sandeep Gosain & Shri Girish Agrawal

purchase of New Computers, Plant & Machinery were submitted. vii. The assessee company has exported the computer software and earned income from rendering Computer Software related services abroad. Copies of sample invoices along with copies of SOFTEX form filed with custom department. viii. The assessee has received consideration in respect of export into India. (Copy of statement and Certificate of Foreign

JT. CIT (ODS) - CC -1(4), MUMBAI vs. ULTRATECH CEMENT LTD., MUMBAI

In the result, appeal filed by the revenue is dismissed

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Sandeep Singh Karhail, Hon’Bledeputy Commissioner Of Income Tax V. M/S. Ultratech Cement Ltd., Central Circle- 1(4) Ahura Centre, B- Wing Room No. 902, 9Th Floor 2Nd Floor, Mahakali Caves Road Pratishtha Bhavan, Old C.G.O. Bldg, (Annexe) Andheri (E), Mumbai- 400093 M.K. Road, Mumbai- 400020 Pan: Aaacl6442L (Appellant) (Respondent) Jt. Commissioner Of Income Tax (Osd) V. M/S. Ultratech Cement Ltd. Central Circle- 1(4) Ahura Centre, B- Wing Room No. 902, 9Th Floor 2Nd Floor, Mahakali Caves Road Pratishtha Bhavan Andheri (E), Mumbai- 400093 Old C.G.O. Bldg, (Annexe) M.K. Road, Mumbai- 400020 Pan: Aaacl6442L (Appellant) (Respondent) & M/S. Ultratech Cement Limited V. Dcit, Central Circle- 1(4) [Acit, Cc] Room. No 902, 9Th Floor Ahura Centre, B-Wing, 2Nd Floor Pratishtha Bhavan Mahakali Caves Road Old C.G.O. Bldg, (Annexe) Andheri (E), Mumbai- 400093 Maharishi Karve Road Mumbai- 400020 Pan: Aaacl6442L (Appellant) (Respondent)

purchase and meet and greet. As regard the expenditure incurred on assets not owned but claimed as revenue expenditure, the Ld.CIT(A) has partly allowed assessee’s appeal by directing to treat few expenditures as purely revenue expenses and few other as deferred revenue expenses to be spread over a period of five (5) years. 13. Aggrieved by the order

ULTRA TECH CEMENT LIMITED,MUMBAI vs. ACIT- CC 1(4), MUMBAI

In the result, appeal filed by the revenue is dismissed

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Sandeep Singh Karhail, Hon’Bledeputy Commissioner Of Income Tax V. M/S. Ultratech Cement Ltd., Central Circle- 1(4) Ahura Centre, B- Wing Room No. 902, 9Th Floor 2Nd Floor, Mahakali Caves Road Pratishtha Bhavan, Old C.G.O. Bldg, (Annexe) Andheri (E), Mumbai- 400093 M.K. Road, Mumbai- 400020 Pan: Aaacl6442L (Appellant) (Respondent) Jt. Commissioner Of Income Tax (Osd) V. M/S. Ultratech Cement Ltd. Central Circle- 1(4) Ahura Centre, B- Wing Room No. 902, 9Th Floor 2Nd Floor, Mahakali Caves Road Pratishtha Bhavan Andheri (E), Mumbai- 400093 Old C.G.O. Bldg, (Annexe) M.K. Road, Mumbai- 400020 Pan: Aaacl6442L (Appellant) (Respondent) & M/S. Ultratech Cement Limited V. Dcit, Central Circle- 1(4) [Acit, Cc] Room. No 902, 9Th Floor Ahura Centre, B-Wing, 2Nd Floor Pratishtha Bhavan Mahakali Caves Road Old C.G.O. Bldg, (Annexe) Andheri (E), Mumbai- 400093 Maharishi Karve Road Mumbai- 400020 Pan: Aaacl6442L (Appellant) (Respondent)

purchase and meet and greet. As regard the expenditure incurred on assets not owned but claimed as revenue expenditure, the Ld.CIT(A) has partly allowed assessee’s appeal by directing to treat few expenditures as purely revenue expenses and few other as deferred revenue expenses to be spread over a period of five (5) years. 13. Aggrieved by the order

M/S. ULTRATECH CEMENT LTD,MUMBAI vs. DCIT CENT CIR-1(4) , MUMBAI

In the result, appeal filed by the revenue is dismissed

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Sandeep Singh Karhail, Hon’Bledeputy Commissioner Of Income Tax V. M/S. Ultratech Cement Ltd., Central Circle- 1(4) Ahura Centre, B- Wing Room No. 902, 9Th Floor 2Nd Floor, Mahakali Caves Road Pratishtha Bhavan, Old C.G.O. Bldg, (Annexe) Andheri (E), Mumbai- 400093 M.K. Road, Mumbai- 400020 Pan: Aaacl6442L (Appellant) (Respondent) Jt. Commissioner Of Income Tax (Osd) V. M/S. Ultratech Cement Ltd. Central Circle- 1(4) Ahura Centre, B- Wing Room No. 902, 9Th Floor 2Nd Floor, Mahakali Caves Road Pratishtha Bhavan Andheri (E), Mumbai- 400093 Old C.G.O. Bldg, (Annexe) M.K. Road, Mumbai- 400020 Pan: Aaacl6442L (Appellant) (Respondent) & M/S. Ultratech Cement Limited V. Dcit, Central Circle- 1(4) [Acit, Cc] Room. No 902, 9Th Floor Ahura Centre, B-Wing, 2Nd Floor Pratishtha Bhavan Mahakali Caves Road Old C.G.O. Bldg, (Annexe) Andheri (E), Mumbai- 400093 Maharishi Karve Road Mumbai- 400020 Pan: Aaacl6442L (Appellant) (Respondent)

purchase and meet and greet. As regard the expenditure incurred on assets not owned but claimed as revenue expenditure, the Ld.CIT(A) has partly allowed assessee’s appeal by directing to treat few expenditures as purely revenue expenses and few other as deferred revenue expenses to be spread over a period of five (5) years. 13. Aggrieved by the order

DCIT CIR 1(4) , MUMBAI vs. M/S. ULTRATECH CEMENT LTD, MUMBAI

In the result, appeal filed by the revenue is dismissed

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Sandeep Singh Karhail, Hon’Bledeputy Commissioner Of Income Tax V. M/S. Ultratech Cement Ltd., Central Circle- 1(4) Ahura Centre, B- Wing Room No. 902, 9Th Floor 2Nd Floor, Mahakali Caves Road Pratishtha Bhavan, Old C.G.O. Bldg, (Annexe) Andheri (E), Mumbai- 400093 M.K. Road, Mumbai- 400020 Pan: Aaacl6442L (Appellant) (Respondent) Jt. Commissioner Of Income Tax (Osd) V. M/S. Ultratech Cement Ltd. Central Circle- 1(4) Ahura Centre, B- Wing Room No. 902, 9Th Floor 2Nd Floor, Mahakali Caves Road Pratishtha Bhavan Andheri (E), Mumbai- 400093 Old C.G.O. Bldg, (Annexe) M.K. Road, Mumbai- 400020 Pan: Aaacl6442L (Appellant) (Respondent) & M/S. Ultratech Cement Limited V. Dcit, Central Circle- 1(4) [Acit, Cc] Room. No 902, 9Th Floor Ahura Centre, B-Wing, 2Nd Floor Pratishtha Bhavan Mahakali Caves Road Old C.G.O. Bldg, (Annexe) Andheri (E), Mumbai- 400093 Maharishi Karve Road Mumbai- 400020 Pan: Aaacl6442L (Appellant) (Respondent)

purchase and meet and greet. As regard the expenditure incurred on assets not owned but claimed as revenue expenditure, the Ld.CIT(A) has partly allowed assessee’s appeal by directing to treat few expenditures as purely revenue expenses and few other as deferred revenue expenses to be spread over a period of five (5) years. 13. Aggrieved by the order

SANMAN TRADE IMPEX LIMITED,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAXCENTRAL CIRCLE-4(4), MUMBAI, MUMBAI

bogus claim u/s\n10AA. Besides, the AO has formed a view that the appellant has used an\ninstrument of amalgamation for evasion of tax by creation of goodwill and\nclaim of amortization expenses. A perusal of the reasons recorded shows\nthat the AO has coherently recorded the reasons and formed his\nindependent view. Hence, the contention of the appellant that

SANMAN TRADE IMPEX LIMITED,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-4(4), MUMBAI, MUMBAI

In the result, appeals of the Revenue are dismissed whereas\nappeals of the assessee are partly allowed

bogus claim u/s\n10AA. Besides, the AO has formed a view that the appellant has used an\ninstrument of amalgamation for evasion of tax by creation of goodwill and\nclaim of amortization expenses. A perusal of the reasons recorded shows\nthat the AO has coherently recorded the reasons and formed his\nindependent view. Hence, the contention of the appellant that

DCIT CC -4(4), MUMBAI, MUMBAI vs. SANMAN TRADE IMPEX LIMITED, MUMBAI

Appeals of the Revenue are dismissed, whereas appeals of the assessee are partly allowed

bogus claim u/s 10AA. Besides, the AO has formed a view that the appellant has used an\ninstrument of amalgamation for evasion of tax by creation of goodwill and claim of amortization expenses. A perusal of the reasons recorded shows that the AO has coherently recorded the reasons and formed his independent view. Hence, the contention of the appellant that

SANMAN TRADE IMPEX LIMITED,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-4(4), MUMBAI, MUMBAI

Appeals of the Revenue are dismissed whereas appeals of the assessee are partly allowed

bogus claim u/s\n10AA. Besides, the AO has formed a view that the appellant has used an\ninstrument of amalgamation for evasion of tax by creation of goodwill and\nclaim of amortization expenses. A perusal of the reasons recorded shows\nthat the AO has coherently recorded the reasons and formed his\nindependent view. Hence, the contention of the appellant that

DCIT CC -4(4), MUMBAI, MUMBAI vs. SANMAN TRADE IMPEX LIMITED, MUMBAI

bogus claim u/s\n10AA. Besides, the AO has formed a view that the appellant has used an\ninstrument of amalgamation for evasion of tax by creation of goodwill and\nclaim of amortization expenses. A perusal of the reasons recorded shows\nthat the AO has coherently recorded the reasons and formed his\nindependent view. Hence, the contention of the appellant that

SANMAN TRADE IMPEX LIMITED,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-4(4), MUMBAI, MUMBAI

In the result, appeals of the Revenue are dismissed whereas\nappeals of the assessee are partly allowed

bogus claim u/s\n10AA. Besides, the AO has formed a view that the appellant has used an\ninstrument of amalgamation for evasion of tax by creation of goodwill and\nclaim of amortization expenses. A perusal of the reasons recorded shows\nthat the AO has coherently recorded the reasons and formed his\nindependent view. Hence, the contention of the appellant that

DCIT CC 4(4), MUMBAI, MUMBAI vs. SANMAN TRADE IMPEX LIMITED, MUMBAI

In the result, appeals of the Revenue are dismissed whereas\nappeals of the assessee are partly allowed

bogus claim u/s\n10AA. Besides, the AO has formed a view that the appellant has used an\ninstrument of amalgamation for evasion of tax by creation of goodwill and\nclaim of amortization expenses. A perusal of the reasons recorded shows\nthat the AO has coherently recorded the reasons and formed his\nindependent view. Hence, the contention of the appellant that

SHRI ANAND M GUPTA,LUCKNOW vs. ITO - 15(1)(4), MUMBAI

Bench: Shri Amit Shukla, Hon'Ble & Shri S. Rifaur Rahman, Hon'Bleestate Of Shri Anand M. Gupta V. Income Tax Officer – 15(1)(4) Aayakar Bhavan, M.K. Road {Through Legal Heir Mumbai - 400020 Mrs. Madhu Anand Gupta} B-723, Sector – C Mahanagar, Lucknow – 226006 Uttar Pradesh Pan: Aabae8078Q (Appellant) (Respondent) Assessee Represented By : Shri Malav Sheth Shri Ashish Kumar Department Represented By :

bogus. 4 Estate of Shri Anand M. Gupta 5. In response assessee by relying on various case laws submitted that assessee had purchased 25000 equity shares of TTL (old name: Omnitech Petroleum Ltd.) for ₹.2,50,000/- through a broker Skunk Tradelink Limited on 24.02.2012. This is off-market transaction and these shares were later dematerialized. Owing to share split

DCIT CC 4 (4), MUMBAI, MUMBAI vs. SANMAN TRADE IMPEX LIMITED, MUMBAI

In the result, appeals of the Revenue are dismissed dismissed whereas appeals of the assessee are partly allowed appeals of the assessee are partly allowed

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail ()

10A or 10B or 10AA has been accepted eligibility of deduction u/s 10A or 10B or 10AA has been accepted eligibility of deduction u/s 10A or 10B or 10AA has been accepted in the initial assessment year, then in the initial assessment year, then, it cannot be withdrawn it cannot be withdrawn in subsequent assessm subsequent assessment years. In this

DCIT CC 4 (4), MUMBAI, MUMBAI vs. SANMAN TRADE IMPEX LIMITED, MUMBAI

In the result, appeals of the Revenue are dismissed dismissed whereas appeals of the assessee are partly allowed appeals of the assessee are partly allowed

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail ()

10A or 10B or 10AA has been accepted eligibility of deduction u/s 10A or 10B or 10AA has been accepted eligibility of deduction u/s 10A or 10B or 10AA has been accepted in the initial assessment year, then in the initial assessment year, then, it cannot be withdrawn it cannot be withdrawn in subsequent assessm subsequent assessment years. In this

DCIT CC 4(4), MUMBAI, MUMBAI vs. SANMAN TRADE IMPEX LIMITED, MUMBAI

In the result, appeals of the Revenue are dismissed dismissed whereas appeals of the assessee are partly allowed appeals of the assessee are partly allowed

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail ()

10A or 10B or 10AA has been accepted eligibility of deduction u/s 10A or 10B or 10AA has been accepted eligibility of deduction u/s 10A or 10B or 10AA has been accepted in the initial assessment year, then in the initial assessment year, then, it cannot be withdrawn it cannot be withdrawn in subsequent assessm subsequent assessment years. In this