ASSISTANT COMMISSIONER OF INCOME TAX-16(1), MUMBAI vs. VIACOM18 MEDIA PRIVATE LIMITED, MUMBAI
Before: SHRI NARENDER KUMAR CHOUDHRY & Ms. PADMAVATHY SACIT, Circle-16(1), Mumbai. Vs.
Per: Bench
C.O.No. 07/MUM/2025
(Viacom 18 Media Pvt. Ltd.)
2
The present appeal and Cross Objection have been preferred by the Revenue and the Assessee respectively, against the order dated
27/08/2024 impugned herein, passed by the National Faceless Appeal
Centre (NFAC)/Commissioner of Income Tax (Appeals), Delhi (in short,
‘Ld. Commissioner’) u/sec. 250 of the Income Tax Act, 1961 (in short,
‘Act’) for the A.Y. 2014-15. 2. Thus, the instant appeal and CO were heard together and are being disposed by this composite order. For brevity, first we will decide the CO filed by the Assessee, as the same is having involved legal issue.
C.O.No. 07/MUM/2025
In the instant case, M/s. Prism TV Pvt. Ltd. had declared its income at total loss of Rs. 107,54,68,375/- by filing its return of income for the assessment under consideration on dated 29/11/2014, which was initially processed u/sec. 143(1) of the Act. Thereafter, the return was selected for scrutiny and accordingly, notice u/sec. 143(2), dated 28/08/2015, was issued by the erstwhile Assessing Officer (AO), DCIT-14(1),
Hyderabad by fixing the case for hearing on 21/09/2015, on which date certain details were filed by the Assessee.
Thereafter, before the then erstwhile AO i.e. DCIT-14(1), Hyderabad, the Assessee by filing a letter dated 24/10/2016 along with copy of order dated 12/08/2016 passed by the Hon'ble Bombay High Court qua amalgamation M/s. Prism TV Pvt. Ltd. and M/s. Viacom 18 Media Pvt. Ltd. and acknowledgement issued by the