IATA BSP, INDIA,MUMBAI vs. ADIT 3(1), MUMBAI

In the result, these appeals are allowed for statistical purposes

Bench: Shri Sanjay Garg & Shri Ashwani Taneja

6. The ADIT passed an order under section 195 of the ITA dated 12 January 2006 holding that BSPL1nk services is in the nature of technical services and therefore the appellant is required to deduct tax at source. The aforesaid order was valid till 31 March 2006. 7. Against the aforesaid order the appellant has filed an appeal before your

IATA BSP, INDIA,MUMBAI vs. ADIT 3(1), MUMBAI

In the result, these appeals are allowed for statistical purposes

Bench: Shri Sanjay Garg & Shri Ashwani Taneja

6. The ADIT passed an order under section 195 of the ITA dated 12 January 2006 holding that BSPL1nk services is in the nature of technical services and therefore the appellant is required to deduct tax at source. The aforesaid order was valid till 31 March 2006. 7. Against the aforesaid order the appellant has filed an appeal before your

IATA BSP INDIA,MUMBAI vs. ADIT 3(1),

In the result, these appeals are allowed for statistical purposes

Bench: Shri Sanjay Garg & Shri Ashwani Taneja

6. The ADIT passed an order under section 195 of the ITA dated 12 January 2006 holding that BSPL1nk services is in the nature of technical services and therefore the appellant is required to deduct tax at source. The aforesaid order was valid till 31 March 2006. 7. Against the aforesaid order the appellant has filed an appeal before your

DCIT, CIR 16(2), MUMBAI vs. M/S KPMG ASSURANCE AND CONSULTING SERVICES LLP, MUMBAI

Section 195 of the Act as the same were\nchargeable to tax in India in terms of Section 9(1)(vii) of the Act\nread with either Article 12 or Article 22/23 of the corresponding\nDTAAs as FTS or Other Income, respectively. Since the Assessee\nhad failed to deduct tax from the same in terms of Section 195

DCIT, CIR 16(2), MUMBAI vs. M/S KPMG ASSURANCE AND CONSULTING SERVICES LLP, MUMBAI

Section 195 of the Act as the same were\nchargeable to tax in India in terms of Section 9(1)(vii) of the Act\nread with either Article 12 or Article 22/23 of the corresponding\nDTAAs as FTS or Other Income, respectively. Since the Assessee\nhad failed to deduct tax from the same in terms of Section 195

KPMG ASSURANCE AND CONSULTING SERVICES LLP,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX-CIRCLE-16(2), MUMBAI

195 of the Act. Since the Assessee had failed to deduct\ntax at source from the professional fee paid to non-residents, the\nAssessing Officer disallowed the deduction for the same by\ninvoking provisions contained in Section 40(a)(i) of the Act.\nFurther, the Assessing Officer also disallowed deduction claimed\nby the Assessee for remittance made by the Assessee

KPMG ASSURANCE AND CONSULTING SERVICES LLP,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX -16(2), MUMBAI

195 of the Act. Since the Assessee had failed to deduct\ntax at source from the professional fee paid to non-residents, the\nAssessing Officer disallowed the deduction for the same by\ninvoking provisions contained in Section 40(a)(i) of the Act.\nFurther, the Assessing Officer also disallowed deduction claimed\nby the Assessee for remittance made by the Assessee

HEMCHAND CHINTAMAN PATIL,THANE vs. ITO, THANE

In the result, the appeal filed by the assessee stands dismissed

Bench: Hon’Ble Shri Sandeep Gosain& Shri Omkareshwar Chidarahemchand Chintaman Patil, Vs. Income Tax Officer 202, Lovely Palace No.2, Qureshi Mansion, Kharigaon, B. P. Road, 2Nd Floor, Gokhale Bhayander (East), Road, Naupada, Teen Thane - 401105. Haath Naka, Thane (W), Thane – 400602. Pan/Gir No. Amapp3180E (Applicant) (Respondent) Assessee By None Revenue By Shri Aditya Rai (Sr. Dr.)

195, 199 (Karn). It is the duty of the appellant to place the relevant facts that there was a sufficient cause for delay in filing an appeal. In the absence of such facts, no presumption can be drawn that there must a sufficient cause for not filing the appeal within the prescribed time [ Union of India v. Brij Lal Prabhu

M/S. TATA SONS LTD.,MUMBAI vs. CIT CIR. 2(3), MUMBAI

In the result, the appeals filed by the assessee are allowed and that of the Revenue is dismissed

Bench: Shri P K Bansal & Shri Ram Lal Negi

Condonation of delay is required in case the appeal is not filed within the permissible time. It is a case where the assessee has raised additional ground. It can be raised by the assessee at any time and even for the first time before the appellate authority. This is a settled law. Even the Hon’ble Supreme Court

M/S. TATA SONS LTD,MUMBAI vs. THE ACIT CIR2(3), MUMBAI

In the result, the appeals filed by the assessee are allowed and that of the Revenue is dismissed

Bench: Shri P K Bansal & Shri Ram Lal Negi

Condonation of delay is required in case the appeal is not filed within the permissible time. It is a case where the assessee has raised additional ground. It can be raised by the assessee at any time and even for the first time before the appellate authority. This is a settled law. Even the Hon’ble Supreme Court

THE ACIT 2(3), MUMBAI vs. M/S. TATA SONS LTD, MUMBAI

In the result, the appeals filed by the assessee are allowed and that of the Revenue is dismissed

Bench: Shri P K Bansal & Shri Ram Lal Negi

Condonation of delay is required in case the appeal is not filed within the permissible time. It is a case where the assessee has raised additional ground. It can be raised by the assessee at any time and even for the first time before the appellate authority. This is a settled law. Even the Hon’ble Supreme Court

ACIT-2(1)(1), MUMBAI vs. GEECEE VENTURES LIMITED, MUMBAI

The appeal is allowed for statistical purposes

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

195 NCPA Marg, Nariman Point, …………. Respondent S.O. Mumbai - 400021, Maharashtra. [PAN: AAACG3914A] Appearance For the Appellant/Assessee : Shri Rahul Sarda For the Respondent/Department : Shri Bhangepatil Pushkaraj Ramesh Date 24.03.2025 Conclusion of hearing : Pronouncement of order 30.05.2025 : O R D E R [ Per Rahul Chaudhary, Judicial Member: 1. This is a batch of three matters consisting of Cross-Appeals and Cross Objection

GEECEE VENTURES LIMITED ,MUMBAI vs. DCIT, CIRCLE 2(1)(1), MUMBAI

The appeal is allowed for statistical purposes

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

195 NCPA Marg, Nariman Point, …………. Respondent S.O. Mumbai - 400021, Maharashtra. [PAN: AAACG3914A] Appearance For the Appellant/Assessee : Shri Rahul Sarda For the Respondent/Department : Shri Bhangepatil Pushkaraj Ramesh Date 24.03.2025 Conclusion of hearing : Pronouncement of order 30.05.2025 : O R D E R [ Per Rahul Chaudhary, Judicial Member: 1. This is a batch of three matters consisting of Cross-Appeals and Cross Objection

YOGESH RAGHAVJI MEHTA,MUMBAI vs. INCOME TAX OFFICER WARD 41(4)(4), MUMBAI, MUMBAI

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

Bench: Shri Om Prakash Kant & Shri. Raj Kumar Chauhanyogesh Raghavji Mehta Vs. Ito Ward 41(4)(4) Opp. Devi Mandir, Devi Gully, Kautilya Bhavan, Carnac Bunder, Mumbai-400 009 Mumbai-400 051 Pan: Aabpm4679A (Appellant) (Respondent)

section 250 of the Income Tax Act, 1961 [hereinafter referred to as “the Act”] for the A.Y. 2012-13, wherein the appeal of the assessee was dismissedby the Ld. CIT(A) on the ground that assessee neither sought Yogesh Raghavji Mehta any condonation nor filed any satisfactory explanation regarding the delay, therefore the addition of Rs. 17,65,841/- made

DCIT, CIR 16(2), MUMBAI vs. M/S KPMG ASSURANCE AND CONSULTING SERVICES LLP, MUMBAI

195 of the Act. Since the Assessee had failed to deduct\n\nITA No.2272-2276/Mum/2023 & CO No.123-128/Mum/2023\nITA No.2410-2415/Mum/2023 AYs 2012-2013 to 2017-2018\n\ntax at source from the professional fee paid to non-residents, the\nAssessing Officer disallowed the deduction for the same by\ninvoking provisions contained in Section 40(a)(i) of the Act.\nFurther, the Assessing

UNITED HOME ENTERTAINMENT P.LTD,MUMBAI vs. ADIT (IT) 2(2), MUMBAI

The appeals are allowed in terms of our directions as given above

Bench: Shri Amit Shukla () & Shri Ashwani Taneja ()

6. We have gone through the facts and circumstances of the case. As far as, prayer for condonation of delay in filing the appeal before Ld.CIT(A) is concerned, it is noted that the assessee submitted before us application dated 15-11-2016 wherein all the facts and circumstances of the case, which led to delay in filing the appeals

UNITED HOME ENTERTAINMENT P.LTD,MUMBAI vs. ADIT (IT) 2(2), MUMBAI

The appeals are allowed in terms of our directions as given above

Bench: Shri Amit Shukla () & Shri Ashwani Taneja ()

6. We have gone through the facts and circumstances of the case. As far as, prayer for condonation of delay in filing the appeal before Ld.CIT(A) is concerned, it is noted that the assessee submitted before us application dated 15-11-2016 wherein all the facts and circumstances of the case, which led to delay in filing the appeals

UNITED HOME ENTERTAINMENT P.LTD,MUMBAI vs. ADIT (IT) 2(2), MUMBAI

The appeals are allowed in terms of our directions as given above

Bench: Shri Amit Shukla () & Shri Ashwani Taneja ()

6. We have gone through the facts and circumstances of the case. As far as, prayer for condonation of delay in filing the appeal before Ld.CIT(A) is concerned, it is noted that the assessee submitted before us application dated 15-11-2016 wherein all the facts and circumstances of the case, which led to delay in filing the appeals