RHODIANYL.SAS,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX, INTERNATIONAL TAX CIRCLE-4(1)(1), MUMBAI

ITA 4002/MUM/2023Status: DisposedITAT Mumbai20 February 2025AY 2020-21Bench: SMT. BEENA PILLAI (Judicial Member), SMT. RENU JAUHRI (Accountant Member)1 pages
AI SummaryWithdrawn

What did the Tribunal hold?

The Assessing Officer (AO) and Dispute Resolution Panel (DRP) made an adjustment of INR 5,26,54,886 to the total income of the assessee. The assessee contested various aspects of the assessment, including the validity of the notice and the calculation of capital gains. The assessee's appeal was ultimately dismissed as withdrawn due to opting for the Vivad-Se-Vishwas Scheme.

What were the facts?

The assessee filed an appeal against the order of the Deputy Commissioner of Income-tax. The assessee raised multiple grounds of appeal, including issues with the notice issued under Section 143(2), recomputation of long-term capital loss, rejection of revised computation of total income, and incorrect computation of additions. The assessee had opted for the Vivad-Se-Vishwas Scheme.

What were the issues?

The primary issues revolved around the validity of the notice issued under Section 143(2) for a non-resident assessee, the correctness of recomputing long-term capital loss, and the rejection of a revised computation of total income.

Which sections of the Income-tax Act were involved?

Section 143(3),Section 144C(13),Section 143(2),Section 120,Section 144B,Section 48,Section 112(1)(c),Section 234A,Section 234B,Section 234C,Section 270A

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Before: SMT. BEENA PILLAI & SMT. RENU JAUHRI

For Appellant: Ms. Riddhi Maru
For Respondent: Shri Krishna Kumar
Hearing: 17.02.2025Pronounced: 20.02.2025

PER RENU JAUHRI [A.M.] :- This appeal is filed by the assessee against the order of the Learned Deputy Commissioner of Income-tax, International Tax Circle-4(1)(1), Mumbai dated 28.07.2023 passed u/s 143(3) r.w.s. 144c(13) of the Income-tax Act, 1961 [hereinafter referred to as “Act”] for Assessment Year [A.Y.] 202-21. 2. The assessee has raised the following grounds of appeal: Ground no. 1- General ground On the facts and in the circumstances of the case and in law, the Ld. AO based on the directions of the Hon'ble Dispute Resolution Panel (DRP), erred in making adjustment of INR 5,26,54,886 to the total income of the Appellant.

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