ACIT Vs M/S Best Auto Ltd
.... entry provider who provides accommodation entry in the form of share capital and share premium. c. The company M / s Skylark Commerce Pvt. Ltd. does not have sufficient funds to give loan. 4. Whether on the facts and in the circumstances of the case and in law, the Ld. CIT(A) has erre ...
Income Tax Appellate Tribunal (Delhi A Bench)
Asstt. Commissioner Of Income-Tax Vs M/S Acme Auto Pvt. Ltd.
.... Heard and perused the record. We first proceed to decide the grounds in ITA no 5647/Del/2013. 4.1. At the time of hearing, primarily learned DR has stressed a lot on the fact that learned CIT(A) has erred in admitting the additional evidences. Learned DR has taken the Bench across the var ...
Income Tax Appellate Tribunal (Delhi A Bench)
Microsoft India (R & D)Private Limited. Vs Deputy Commissioner Of Income Tax
.... arlier years as also in subsequent years in favour of the assessee. Therefore, there is no reason for us to deviate from the same in the absence of any fresh adverse material in the records. Accordingly the modified ground No.1, 2.1 and 2.2 are decided in favour of the assessee with the direction ...
Income Tax Appellate Tribunal (Delhi I Bench)
Adit Infrapower & Multitrading Pvt. Ltd Vs ITO
.... tituting opinion of the Id. AO by that of CIT. 5) That on the facts and circumstances of the case, the order passed by the learned Pr. Commissioner of Income Tax (CIT) under section 263 of the Act is non-application of mind of Hon’ble Pr. CIT as Hon’ble Pr. CIT is on the wrong facts i.e the ...
Income Tax Appellate Tribunal (Delhi A Bench)
Defsys Solutions Pvt Ltd Vs A.C.I.T
.... Court in the case of Kalyan Kumar Ray Vs. CIT 191 ITR 634. The relevant findings of Hon'ble High Court read as under: " 'Assessment’ is one integrated process involving not only the assessment of the total income but also the determination of the tax. The latter is as crucial as the fo ...
Income Tax Appellate Tribunal (Delhi I Bench)
M/S Idemia Syscom India Pvt Ltd Vs C.I.T.
.... otice dated 16.06.2023, the TPO specifically asked the assessee to clarify whether any value addition is done by the AEs to the product sold to the AEs before sale of such products to final customer. 24. The assessee replied that vis a vis AE sales, it is a contract manufacturer and explai ...
Income Tax Appellate Tribunal (Delhi I Bench)
Motherson Sumi Systems Limited Vs DCIT
.... ted experimental economic legislation but on that account alone it cannot be struck down as invalid. 37. On the above legal position discussed by us, we are of the opinion that the Respondent assessee was entitled to 100% exemption or deduction under Section 10-A of the Act in respect of th ...
Income Tax Appellate Tribunal (Delhi I Bench)
Boeing India Pvt. Ltd Vs ACIT
.... framed in the name of non-existing entity, it does not remain a procedural irregularity of the nature which could be cured by invoking the provisions of Section 292-B of the Act. 25. A batch of civil appeals was filed before this Court against the decisions of the Delhi High Court, the lea ...
Income Tax Appellate Tribunal (Delhi I Bench)
Institute Of Company Secretaries Of India Vs DCIT
.... Less Actually applied for purposes of the trust -8,24,28,829 Remaining to be accumulated u/s 11(2) - - 120,00,31,900 (to claim deduction) Therefore, there is merit in the appellant's contention that ...
Income Tax Appellate Tribunal (Delhi H Bench)
Anant Raj Agencies Vs ITO
.... llant without dealing with various grounds of appeal and additional grounds of appeal.” 3. At the outset, ld. Counsel for the assessee submitted that the ld. CIT (A) has dismissed the appeal for non-prosecution. He prayed that an opportunity may be provided to appear before the ld. CIT (A) ...
Income Tax Appellate Tribunal (Delhi SMC Bench)
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