CUMMINS TECHNOLOGIES INDIA (P) LTD.,DEWAS vs. ACIT CIRCLE 1(1), UJJAIN

ITA 982/IND/2019Status: DisposedITAT Indore30 November 2023AY 2015-16Bench: SHRI VIJAY PAL RAO (Judicial Member), SHRI B.M. BIYANI (Accountant Member)22 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal quashed the assessment order passed by the Assessing Officer for not incorporating the Document Identification Number (DIN). The Tribunal held that the assessment order was invalid for want of DIN, making it deemed to have never been issued.

What were the facts?

The assessee appealed an assessment order passed under Section 143(3) read with Section 144C of the Income-tax Act, 1961. The primary issue revolved around transfer pricing adjustments and other grounds related to disallowances and deductions.

What were the issues?

The key legal issue was the validity of an assessment order passed without a Document Identification Number (DIN), rendering it invalid. The Tribunal also considered transfer pricing adjustments and other grounds raised by the assessee.

Which sections of the Income-tax Act were involved?

Section 143(3),Section 144C,Section 154,Section 10AA,Section 92C

AI-generated summary — verify with the full judgment below

Cases cited in this judgment(19)Show list

Detected automatically from the text. Citations are also linked where they appear in the judgment. The count shows how many other judgments on BharatTax rely on the same authority.

Income Tax Appellate Tribunal, INDORE BENCH, INDORE

For Appellant: Shri Ketan
For Respondent: Ms. Simran Bhullar, CIT-DR
Hearing: 29.11.2023Pronounced: 30.11.2023

Per Vijay Pal Rao, JM:

This appeal by the Assessee is directed against assessment order dated 15.10.2019 passed u/s 144C r.w. section 143(3) in pursuant to the Directions of DRP dated 26.08.2019 passed u/s 144C(5) for A.Y.2015-16. The assessee has raised following grounds of appeal:

“Based on the facts and circumstances of the case, Cummins Technologies India Private Limited (hereinafter referred to as "CTIPL" or "the Appellant") prefers an appeal for the assessment year 2015- 16 against the order dated October 15, 2019 (received on October 15, 2019 ) passed by the learned Assistant Commissioner of Income Tax, Circle - 1(1), Ujjain ("hereinafter referred to as "Assessing Officer" / "AO"]

The order continues below.

Read the full judgment

A free account opens 10 full judgments a month. Re-reading one you have already opened does not count again.

Create a free accountSign in

See plans and prices

The summary, the parties, the sections and the citations above are open to everyone and always will be. Only the text of the order and the PDF are metered.

More judgments on Section 144C

All 3,699 judgments and leading authorities on Section 144C →

Recent GST High Court judgments

Search GST case law →