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Documents citing Kasper Information Technology Pvt. ... vs Ito Ward-14(2), New Delhi on 18 March, 2021

Tayal Sons Private Limited,Hisar vs Dcit, Hisar on 28 November, 2025

24. Thus, there is no cavil of doubt that Section 144B of the Act and order of CBDT dated 06.09.2021 give exemption from following the mandatory faceless procedure only in relation to passing of assessment orders in cases of central charges and international tax charges. Any other interpretation would amount to doing violence with the language employed in the scheme/notification dated 29.03.2022, Section 144B(2) of the Act and order dated 06.09.2021. Since in our view, the plain and unambiguous language used in the scheme and order dated 06.09.2021 shows that the notice under Section 148 does not fall within the 'exception', the judgments cited by the learned Senior Standing Counsel for Income Tax Department are of no assistance. The Taxpayer is nowhere distinguished between NRIs and Indian Citizens. The notice issued under Section 148 must comply with the requirement of the Scheme whether or not the Taxpayer is NRI/Indian Citizen. Thus, the second limb of 7 ITA No. 3322, 3323, 3446 & 3467/Del/2025 Tayal sons Pvt. Ltd. Vs. DCIT argument of the learned Senior Standing Counsel for Income Tax Department deserves to be rejected.
Income Tax Appellate Tribunal - Delhi Cites 35 - Cited by 0 - Full Document

Dcit, Hisar vs Tayal Sons Pvt. Ltd., Hisar on 28 November, 2025

24. Thus, there is no cavil of doubt that Section 144B of the Act and order of CBDT dated 06.09.2021 give exemption from following the mandatory faceless procedure only in relation to passing of assessment orders in cases of central charges and international tax charges. Any other interpretation would amount to doing violence with the language employed in the scheme/notification dated 29.03.2022, Section 144B(2) of the Act and order dated 06.09.2021. Since in our view, the plain and unambiguous language used in the scheme and order dated 06.09.2021 shows that the notice under Section 148 does not fall within the 'exception', the judgments cited by the learned Senior Standing Counsel for Income Tax Department are of no assistance. The Taxpayer is nowhere distinguished between NRIs and Indian Citizens. The notice issued under Section 148 must comply with the requirement of the Scheme whether or not the Taxpayer is NRI/Indian Citizen. Thus, the second limb of 7 ITA No. 3322, 3323, 3446 & 3467/Del/2025 Tayal sons Pvt. Ltd. Vs. DCIT argument of the learned Senior Standing Counsel for Income Tax Department deserves to be rejected.
Income Tax Appellate Tribunal - Delhi Cites 35 - Cited by 0 - Full Document

Agmotex Fabrics Ltd.,Kanpur vs Dy. Commissioner Of Income Tax, ... on 15 April, 2026

7. The Ld. Departmental Representative could not bring to our notice any contrary binding precedent. We, therefore, respectfully following the judgment of the Hon'ble Delhi High Court in the case of CIT vs. Nalwa Sons Investments Ltd. (supra) and the decision of the Co-ordinate Bench in the case of ITO vs. Software Element India Pvt. Ltd. (supra), hereby direct the AO to delete the impugned penalty. Grounds raised in this appeal are allowed.
Income Tax Appellate Tribunal - Lucknow Cites 12 - Cited by 0 - Full Document

Mr Kedar Jagdish Mankar,Pune vs Assistant Commissioner Of Income Tax, ... on 28 January, 2025

In the case of Kasper Pieter Tideman, Pune Vs. Income Tax Officer, Ward - 7(1), the Hon'ble ITAT Pune wherein it has been held that "We have heard the rival arguments made by both the sides, perused the orders of the AO and NFAC and the paper book filed on behalf of the assessee. We have also considered the various decisions cited before us. We find the AO in the instant case did not allow the Foreign Tax Credit (FTC) on the ground that Form No.67 has been filed beyond the due date of filing of the return. We find the NFAC upheld the action of the AO, the reasons of which have already been reproduced in the preceding paragraph. It is the submission of the ld. Counsel for the assessee that filing of foreign tax credit certificate in Form-67 is 6 ITA No.1624/PUN/2024, AY 2017-18 directory in nature and not mandatory and therefore the NFAC is not justified in denying the Foreign Tax Credit.
Income Tax Appellate Tribunal - Pune Cites 13 - Cited by 0 - Full Document

Goldstar Cement Pvt. Ltd., New Delhi vs Acit, New Delhi on 15 July, 2021

4.4 The additional ground raised by the assessees is with respect to the violation of the Principles of Natural Justice in which the assessees contend that the enquires made by the Department to make the impugned additions in the hands of the assessees were never confronted to the assessees at any stage of the reassessment proceedings. Since the additional ground raised by the assessees is a question of law, we admit this ground in the case of ACIT, Central Circle-13, New Delhi Vs. BBN Transportation Pvt. Ltd., ITA No. 6176/Del/2013 & CO 260/Del/2013 for A.Y. 2008-09 and ACIT, Central Circle-13, New Delhi Vs. Sur Buildcon Pvt. Ltd. (now Globus 28 ITA Nos. 6174, 6176 & 6177/Del/2013 C.O. Nos.258,260 &261/Del/2015 Sur Buildcon Pvt. Ltd. & Ors vs. ITO Real Infra Pvt. Ltd.), ITA No. 6174/Del/2013 & CO 258/Del/2013 for A.Y. 2009-10.
Income Tax Appellate Tribunal - Delhi Cites 42 - Cited by 2 - Full Document
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