How many judgments cite AGS Tiber v. CIT?

26 judgments on BharatTax cite AGS Tiber v. CIT (233 ITR 207), spanning 2020 to 2022.

AGS Tiber v. CIT

233 ITR 207High Court1998#4478 most cited

What is AGS Tiber v. CIT authority for?

Statutory provisions, especially those that disallow deductions, must be interpreted strictly and literally. Courts cannot read words or concepts into a provision that are not expressly stated, even if the intent seems logical.

judgments rely on this decision, according to BharatTax’s citation analysis of 366,314 Indian tax judgments — from 2020 to 2022.

Also referred to as

AGS Tiber v. CIT · section 40(a)(ii) · deduction of tax · profits and gains of business or profession · interpretation of statutes · legislative intent · cess vs tax · rule of strict construction

Also reported as

92 Taxmann 268

Issues it is cited on

section 40(a)(ii)section 90a section 91 profits and gains of business or profession comparable companies section 30 interest under section 234b section 90 section 40(a)associated enterprise associated enterprises transfer pricing adjustment

Judgments citing AGS Tiber v. CIT

Ramjee Concretes Pvt.Ltd., Mohali vs. ITO-Ward-6(3), Chandigarh

The appeals are disposed of in the aforesaid terms

ITA 205/CHANDI/2021[2019-20]Status: DisposedITAT Chandigarh17 Jan 2022AY 2019-20

Bench: Shri N.K. Saini & Shri Sudhanshu Srivastavaआयकर अपील सं./ Ita No. 205/Chd/2021 "नधा"रण वष" / Assessment Year : 2019-20 Ramjee Concretes Private Limited, The Ito, बनाम #1238.Sector 91, Ward 6(3), Mohali, Punjab Chandigarh "थायी लेखा सं./Pan No: Aafcr9457E अपीलाथ"/Appellant ""यथ"/Respondent

For Appellant: Shri T.N. Singla, CAFor Respondent: Sh. Ashok Khanna, Addl. CIT

Section 143(1)Section 143(2)Section 250

…and in favour of the assessee and it should be so construed as to effectuate the object of the legislature and not to defeat it. Further, the interpretation cannot go to the extent of reading something that is not stated in the provision [See AGS Tiber Vs CIT 233 ITR 207]. ITA No. 205-Chd-2021 Ramjee Concretes Private Limited, Chandigarh 22. Applying the aforesaid principles, we find that the legislature, in Section 40(a)(ii) has provided that “any rate or tax levied” on “profits and gains of business or profession” shall not be deducted in computing the income chargeable under the head “profits and gains of bu…

Shahi Exports Pvt. Ltd., New Delhi vs. ACIT, New Delhi

In the result, appeal of the assessee in ITA No

ITA 843/DEL/2021[2016-17]Status: HeardITAT Delhi17 Jan 2022AY 2016-17

Bench: Shri Saktijit Dey & Shri N.K. Billaiya

For Appellant: Shri M.P. Rastogi, AdvFor Respondent: Shri Mahesh Shah, CIT-DR

Section 143(3)Section 234ASection 37Section 40A(2)Section 80ISection 92BSection 92C

…favour of the assessee and it should be so construed as to effectuate the object of the legislature and not to defeat it. Further, the interpretation cannot go to the extent of reading something that is not stated in the provision [See IGS Tiber v. CIT [998] 233 ITR 207 I Ll997l 92 Taxann 268 (Mad.)l. 22. Applying the aforesaid principles, we find that the legislature, in Section ail@)(ii) has provided that "any rate or tax levied' on "profits and gains of business or profession" shall not be deducted in computing the income chargeable under the head "profits and gains of business or profession". There is no re…

Cenduit (India) Services Private Limited, Bangalore vs. The Deputy Commissioner of Income Tax, Circle-2(1)(1), Bangalore

In the result, the assessee’s appeal is partly allowed for statistical purposes

ITA 227/BANG/2021[2016-17]Status: DisposedITAT Bangalore12 Jan 2022AY 2016-17

Bench: Shri N.V. Vasudevan & Shri Chandra Poojari

For Appellant: Shri Ketan K. Ved, CAFor Respondent: Shri Sunil Kumar Singh, CIT(DR)(ITAT), Bengaluru

Section 143(3)

…and in favour of the assessee and it should be so construed as to effectuate the object of the legislature and not to defeat it. Further, the interpretation cannot go to the extent of reading something that is not stated in the provision [See AGS Tiber v. CIT 233 ITR 207]. 22. Applying the aforesaid principles, we find that the legislature, in Section 40(a)(ii) has provided that "any rate or tax levied" on "profits and gains of business or profession" shall not be deducted in computing the income chargeable under the head "profits and gains of business or profession". There is no reference to any "cess". Obviousl…

Kalyani Steels Ltd, Pune vs. Deputy Commissioner of Income-Tax, Circle - 14, Pune

The appeal of the assesse is allowed in terms of our aforesaid observations

ITA 1403/PUN/2018[2015-16]Status: DisposedITAT Pune05 Jan 2022AY 2015-16

Bench: Shri Inturi Rama Rao() & Shri Ravish Sood () Assessment Year: 2015-16 Kalyani Steels Ltd. Dy. Commissioner Of Income-Tax, Mundhwa, Vs. Income-Tax Circle-14, Pune – 411 036 Aaykarsadan, Bodhi Tower, 548/2B, Salisbury Park, Gultekdi, Pune – 411 037. Pan No. Aaack7315D (Appellant) (Respondent)

For Appellant: Shri. Nikhil Pathak, A.RFor Respondent: Shri. M.G Jasnani, D.R

Section 115JSection 143(3)Section 14A

…and in favour of the assessee and it should be so construed as to effectuate the object of the legislature and not to defeat it. Further, the interpretation cannot go to the extent of reading something that is not stated in the provision [See AGS Tiber Vs CIT 233 ITR 207]. 22. Applying the aforesaid principles, we find that the legislature, in Section 40(a)(ii) has provided that “any rate or tax levied” on “profits and gains of business or profession” shall not be deducted in computing the income chargeable under the head “profits and gains of business or profession”. There is no reference to any “cess”. Obvious…

Expeditors International of Washinton, Usa, Washington vs. ACIT, Circle-1(2)(2) Int.Tax., New Delhi

In the result, the appeal of the assessee is partly allowed

ITA 180/DEL/2021[2017-18]Status: DisposedITAT Delhi05 Jan 2022AY 2017-18

Bench: Shri Anil Chaturvedi & Shri Kul Bharat

Section 144C(13)Section 234BSection 234CSection 271Section 9Section 9(1)(vii)

…and in favour of the assessee and it should be so construed as to effectuate the object of the legislature and not to defeat it. Further, the interpretation cannot go to the extent of reading something that is not stated in the provision [See AGS Tiber Vs CIT 233 ITR 207]. 22. Applying the aforesaid principles, we find that the legislature, in Section 40(a)(ii) has provided that “any rate or tax levied” on “profits and gains of business or profession” shall not be deducted in computing the income chargeable under the head “profits and gains of business or profession”. There is no reference to any “cess”. Obvious…

Expeditors International of Washington Inc., Usa vs. ACIT (International Taxation), New Delhi

In the result, the appeal of the assessee is partly allowed

ITA 1904/DEL/2017[2012-13]Status: DisposedITAT Delhi05 Jan 2022AY 2012-13

Bench: Shri Anil Chaturvedi & Shri Kul Bharat

Section 144C(13)Section 234BSection 234CSection 271Section 9Section 9(1)(vii)

…and in favour of the assessee and it should be so construed as to effectuate the object of the legislature and not to defeat it. Further, the interpretation cannot go to the extent of reading something that is not stated in the provision [See AGS Tiber Vs CIT 233 ITR 207]. 22. Applying the aforesaid principles, we find that the legislature, in Section 40(a)(ii) has provided that “any rate or tax levied” on “profits and gains of business or profession” shall not be deducted in computing the income chargeable under the head “profits and gains of business or profession”. There is no reference to any “cess”. Obvious…

Bachhraj & Company Pvt Ltd., Mumbai vs. Asst CIT Circle- 3 (1)(1), Mumbai

Accordingly, the appeal filed by the assessee is allowed on the same terms

ITA 7349/MUM/2019[2015-16]Status: DisposedITAT Mumbai08 Oct 2021AY 2015-16

Bench: Shri Pramod Kumar () & Shri Ravish Sood () Ita Nos.7348 & 7349/Mum/2019 (Assessment Years: 2014-15 & 2015-16) Bachhraj & Company The Assistant Commissioner Private Limited, 2Nd Floor, Vs. Of Income-Tax, Circle 3(1)(1), Bajaj Bhawan, Room No. 607, Aayakar 226, Nariman Point, Bhavan, M.K. Road, Mumbai – 400 021 Mumbai – 400 020 Pan No. Aaacb5589N (Assessee) (Revenue) Assessee By : Shri Kirit Kamdar, A.R Revenue By : Shri Kprr Murty, D.R Date Of Hearing : 04/10/2021 Date Of Pronouncement : 08/10/2021

For Appellant: Shri Kirit Kamdar, A.RFor Respondent: Shri KPRR Murty, D.R

Section 143(3)Section 14A

…and in favour of the assessee and it should be so construed as to effectuate the object of the legislature and not to defeat it. Further, the interpretation cannot go to the extent of reading something that is not stated in the provision [See AGS Tiber Vs CIT 233 ITR 207]. 22. Applying the aforesaid principles, we find that the legislature, in Section 40(a)(ii) has provided that ―any rate or tax levied‖ on ―profits and gains of business or profession‖ shall not be deducted in computing the income ITA Nos. 7348 & 7349/Mum/2019 A.Ys. 2014-15 & 2015-16 18 Bachhraj & Company Private Limited Vs. The ACIT, Circle-3(1)…

Bachhraj & Company Pvt Ltd., Mumbai vs. Asst CIT Circle- 3 (1)(1), Mumbai

Accordingly, the appeal filed by the assessee is allowed on the same terms

ITA 7348/MUM/2019[2014-15]Status: DisposedITAT Mumbai08 Oct 2021AY 2014-15

For Appellant: Shri Kirit Kamdar, A.RFor Respondent: Shri KPRR Murty, D.R

Section 143(3)Section 14A

…and in favour of the assessee and it should be so construed as to effectuate the object of the legislature and not to defeat it. Further, the interpretation cannot go to the extent of reading something that is not stated in the provision [See AGS Tiber Vs CIT 233 ITR 207]. 22. Applying the aforesaid principles, we find that the legislature, in Section 40(a)(ii) has provided that ―any rate or tax levied‖ on ―profits and gains of business or profession‖ shall not be deducted in computing the income ITA Nos. 7348 & 7349/Mum/2019 A.Ys. 2014-15 & 2015-16 18 Bachhraj & Company Private Limited Vs. The ACIT, Circle-3(1)…

Perfetti Van Melle India Pvt. Ltd., Gurgaon vs. ACIT, Circle-3(1), Gurgaon

In the result, the additional ground raised by the assessee is allowed

ITA 463/DEL/2021[2016-17]Status: DisposedITAT Delhi22 Sept 2021AY 2016-17

Bench: The Income Tax Appellate Tribunal, Delhi Bench “I-2”, New Delhi

For Appellant: Mr. Deepak Chopra, AdvFor Respondent: Ms. Meera Shrivastava, CIT (DR)

Section 142(1)Section 143(2)Section 143(3)Section 271(1)(c)Section 80Section 80ISection 92C

…favour of the assessee and it should be so construed as to effectuate the object of the legislature and not to defeat it. Further, the interpretation cannot go to the extent of reading something that is not stated in the provision [See AGS Tiber v. CIT [1998] 233 ITR 207/[1997] 92 Taxman 268 (Mad.)]. 22. Applying the aforesaid principles, we find that the legislature, in Section 40(a)(z7) has provided that "any rate or tax levied'' on ''profits and gains of business or profession" shall not be deducted in computing the income chargeable under the head "profits and gains of business or profession". There is no ref…

Ashok Kirtanlal Shah, Mumbai vs. Add. CIT CC-22 (1), Mumbai

The appeal of the assessee is allowed in terms of our aforesaid observations

ITA 5842/MUM/2019[2010-11]Status: DisposedITAT Mumbai01 Sept 2021AY 2010-11

Bench: Shri M.Balalganesh () & Shri Ravish Sood () Ashok Kirtanlal Shah Addl. Cit-Range 19(1) (Presently, Addl, Circle 22(1) 401, 4Th Floor, Anand House, Vs. Piramal Chambers, Lal Baug, 13Th Road, Off. Linking Road, Mumbai 400 012 Khar West, Mumbai – 400 052

For Appellant: Shri Dharmesh Shah, A.RFor Respondent: Shri Brajendra Kumar, D.R

Section 143(1)Section 143(2)Section 143(3)Section 14A

…and in favour of the assessee and it should be so construed as to effectuate the object of the legislature and not to defeat it. Further, the interpretation cannot go to the extent of reading something that is not stated in the provision [See AGS Tiber Vs CIT 233 ITR 207]. 22. Applying the aforesaid principles, we find that the legislature, in Section 40(a)(ii) has provided that ―any rate or tax levied‖ on ―profits and gains of business or profession‖ shall not be deducted in computing the income chargeable under the head ―profits and gains of business or profession‖. There is no reference to any ―cess‖. Obviousl…

M/S Novozymes South Asia Pvt Ltd, Bangalore vs. Assistant Commissioner of Income Tax Circle-5(1)(1), Bangalore

In the result, both the appeals of the assessee are allowed

ITA 895/BANG/2018[2013-14]Status: DisposedITAT Bangalore29 Jun 2021AY 2013-14

Bench: Shri George George K. & Shri B.R. Baskaranit(Tp)A No.894/Bang/2018 Assessment Year:2012-13

For Appellant: Shri T. Suryanarayan, A.RFor Respondent: Ms. Neera Malhotra, D.R

…favour of the assessee and it should be so construed as to effectuate the object of the legislature and not to defeat it. Further, the interpretation cannot go to the extent of reading something that is not stated in the provision [See AGS Tiber v. CIT [1998] 233 ITR 207/[1997] 92 Taxman 268 (Mad.)]. 22. Applying the aforesaid principles, we find that the legislature, in Section 40(a)(ii) has provided that "any rate or tax levied" on "profits and gains of business or profession" shall not be deducted in computing the income chargeable under the head "profits and gains of business or profession". There is no refer…

M/S Novozymes South Asia Pvt Ltd, Bangalore vs. Joint Commissioner of Income Tax (OSD) Circle-5(1)(1), Bangalore

In the result, both the appeals of the assessee are allowed

ITA 894/BANG/2018[2012-13]Status: DisposedITAT Bangalore29 Jun 2021AY 2012-13

Bench: Shri George George K. & Shri B.R. Baskaranit(Tp)A No.894/Bang/2018 Assessment Year:2012-13

For Appellant: Shri T. Suryanarayan, A.RFor Respondent: Ms. Neera Malhotra, D.R

…favour of the assessee and it should be so construed as to effectuate the object of the legislature and not to defeat it. Further, the interpretation cannot go to the extent of reading something that is not stated in the provision [See AGS Tiber v. CIT [1998] 233 ITR 207/[1997] 92 Taxman 268 (Mad.)]. 22. Applying the aforesaid principles, we find that the legislature, in Section 40(a)(ii) has provided that "any rate or tax levied" on "profits and gains of business or profession" shall not be deducted in computing the income chargeable under the head "profits and gains of business or profession". There is no refer…

The Sarswat Co-Operative Bank Ltd., Mumbai vs. ITO 1 (3)(1), Mumbai

ITA 6609/MUM/2019[2013-14]Status: DisposedITAT Mumbai28 Jun 2021AY 2013-14

Bench: Shri S. Rifaur Rahman & Shri Ravish Sood

For Appellant: Shri Anil Sathe, A.RFor Respondent: Shri Neehar Pandey, CIT D.R

Section 143(3)Section 14ASection 3Section 36(1)(vii)Section 36(1)(viia)

…and in favour of the assessee and it should be so construed as to effectuate the object of the legislature and not to defeat it. Further, the interpretation cannot go to the extent of reading something that is not stated in the provision [See AGS Tiber Vs CIT 233 ITR 207]. 22. Applying the aforesaid principles, we find that the legislature, in Section 40(a)(ii) has provided that “any rate or tax levied” on “profits and gains of business or profession” shall not be deducted in computing the income chargeable under the head “profits and gains of business or profession”. There is no reference to any “cess”. Obvious…

Ajanta Pharma Ltd., Mumbai vs. DCIT, CC-7(2), Mumbai

The appeal of the assessee is allowed in terms of our aforesaid observations

ITA 4785/MUM/2019[2015-16]Status: DisposedITAT Mumbai25 May 2021AY 2015-16

Bench: Shri Rajesh Kumar () & Shri Ravish Sood () Ita No.4784 & 4785/Mum/2019 (Assessment Years: 2015-16 & 2016-17) M/S Ajanta Pharma Ltd. Dy. Commissioner Of 98, Ajanta House, Vs. Income-Tax-Central Circle 6(2),19Th Floor, Air India Govt. Industrial Area, Hindustan Naka, Building, Nariman Point, Charkop,Kandivli (West), Mumbai – 400 021. Mumbai – 400 067. Pan No. Aaaca5579P (Appellant) (Respondent)

For Appellant: Shri J.D. Mistri, Senior AdvocateFor Respondent: Shri Rajeev Harit, CIT D.R

Section 143(2)Section 37(1)

…and in favour of the assessee and it should be so construed as to effectuate the object of the legislature and not to defeat it. Further, the interpretation cannot go to the extent of reading something that is not stated in the provision [See AGS Tiber Vs CIT 233 ITR 207]. 22. Applying the aforesaid principles, we find that the legislature, in Section 40(a)(ii) has provided that “any rate or tax levied” on “profits and gains of business or profession” shall not be deducted in computing the income chargeable under the head “profits and gains of business or profession”. There is no reference to any “cess”. Obvious…

Ajanta Pharma Ltd., Mumbai vs. DCIT, CC-7(2), Mumbai

The appeal of the assessee is allowed in terms of our aforesaid observations

ITA 4784/MUM/2019[2016-17]Status: DisposedITAT Mumbai25 May 2021AY 2016-17

For Appellant: Shri J.D. Mistri, Senior AdvocateFor Respondent: Shri Rajeev Harit, CIT D.R

Section 143(2)Section 37(1)

…and in favour of the assessee and it should be so construed as to effectuate the object of the legislature and not to defeat it. Further, the interpretation cannot go to the extent of reading something that is not stated in the provision [See AGS Tiber Vs CIT 233 ITR 207]. 22. Applying the aforesaid principles, we find that the legislature, in Section 40(a)(ii) has provided that “any rate or tax levied” on “profits and gains of business or profession” shall not be deducted in computing the income chargeable under the head “profits and gains of business or profession”. There is no reference to any “cess”. Obvious…

Bachhraj Factories Pvt Ltd., Mumbai vs. ACIT Circle-3(1)(1), Mumbai

In the result, the appeal of the assessee is hereby partly allowed

ITA 3986/MUM/2019[2014-15]Status: DisposedITAT Mumbai07 Apr 2021AY 2014-15

For Appellant: Shri Kirit KamdarFor Respondent: Shri Tharian Oommen (DR)

Section 143(2)Section 14A

…favour of the assessee and it should be so construed as to effectuate the object of the legislature and not to defeat it. Further, the interpretation cannot go to the extent of reading something that is not stated in the provision [See AGS Tiber v. CIT [1998] 233 ITR 207/[1997] 92 Taxman 268 (Mad.)]. 22. Applying the aforesaid principles, we find that the legislature, in Section 40(a)(ii) has provided that "any rate or tax levied" on "profits and gains of business or profession" shall not be deducted in computing the income chargeable under the head "profits and gains of business or profession". There is no refer…

Il & Fs Transportation Networks Limited, Mumbai vs. Assistant Commissioner of Income Tax - Range - 14(2)(1), Mumbai

ITA 4177/MUM/2018[2012-13]Status: DisposedITAT Mumbai15 Feb 2021AY 2012-13

Bench: Shri S. Rifaur Rahman & Shri Ravish Soodil & Fs Transportation Networks Asstt. Commissioner Of Limited, The Il & Fs Financial Income-Tax, Range -14(2)(1), Center, Plot No.C-22, Room No. Aaykar Bhavan, Maharshi Karve Vs. 460, 4Th Floor, G Block, Bandra- Road, Marine Lines, Kurla Complex, Bandra (E), Mumbai – 400 020 Mumbai – 400 051 Pan – Aabcc5460A (Appellant) (Respondent) Dcit -14(2)(1), M/S Il & Fs Transportation Network 432, 4Th Floor, Aayakar Bhavan, Ltd., Il & Fs Financial Centre, 8Th Vs. Mumbai – 400 020 Floor, C-22, G Block, B.K.C. Bandra (E), Mumbai – 400051

For Appellant: Shri Sandeep Bhalla, A.RFor Respondent: Shri Sushil Kumar Mishra, D.R

Section 143(3)Section 14A

…and in favour of the assessee and it should be so construed as to effectuate the object of the legislature and not to defeat it. Further, the interpretation cannot go to the extent of reading something that is not stated in the provision [See AGS Tiber Vs CIT 233 ITR 207]. 22. Applying the aforesaid principles, we find that the legislature, in Section 40(a)(ii) has provided that “any rate or tax levied” on “profits and gains of business or profession” shall ITA Nos. 4177/Mum/2018 And 3638/Mum/2018 A.Y: 2012-13 21 IL &FS Transportation Networks Limited VS. Asstt. CIT, Range 14(2)(1) not be deducted in computing…

M/S Honeywell Technology Solutions Lab Private Limited, Bangalore vs. Deputy Commissioner of Income Tax Circle-3(1)(2), Bangalore

In the result, the assessee's appeal is partly allowed

ITA 1210/BANG/2018[2010-11]Status: DisposedITAT Bangalore07 Jan 2021AY 2010-11

Bench: Shri N.V. Vasudevan & Shri Chandra Poojarim/S. Honeywell Technology Solutions Lab Pvt. Ltd., 151/1, Bannerghata Road, Doraisanpalya, Bangalore-560 076 ….Appellant Pan Aaach 4151J Vs. Dy. Commissioner Of Income Tax, Circle 3(1)(2), Bangalore. ……Respondent. Assessee By: Smt. Shreya Loyalka, C.A. Revenue By: Shri B.K. Panda, Cit (D.R)

For Appellant: Smt. Shreya Loyalka, C.AFor Respondent: Shri B.K. Panda, CIT (D.R)

Section 80J

…and in favour of the assessee and it should be so construed as to effectuate the object of the legislature and not to defeat it. Further, the interpretation cannot go to the extent of reading something that is not stated in the provision [See AGS Tiber Vs CIT 233 ITR 207]. 22. Applying the aforesaid principles, we find that the legislature, in Section 40(a)(ii) has provided that “any rate or tax levied” on “profits and gains of business or profession” shall not be deducted in computing the income chargeable under the head “profits and gains of business or profession”. There is no reference to any “cess”. Obviousl…

Mufg Bank Ltd, New Delhi vs. ACIT (International Taxation) Circle-2(2)(1), New Delhi

In the result appeal of the assessee is partly allowed

ITA 7895/DEL/2019[2015-16]Status: DisposedITAT Delhi16 Oct 2020AY 2015-16

Bench: Shri Amit Shukla & Shri Prashant Maharishi(Through Video Conferencing) Mufg Bank Ltd, Vs. Acit (International Taxation), 5Th Floor, Worldmark 2, Asset 8, Circle-2(2)(1), Aerocity, Nh-8, New Delhi New Delhi Pan: Aabct3880D (Appellant) (Respondent)

For Appellant: Shri Nishant Thakkar, AdvFor Respondent: Shr Surender Pal, CIT DR

Section 143(3)Section 14ASection 244ASection 37(1)Section 44C

…and in favour of the assessee and it should be so construed as to effectuate the object of the legislature and not to defeat it. Further, the interpretation cannot go to the extent of reading something that is not stated in the provision [See AGS Tiber v. CIT 233 ITR 207]. 22. Applying the aforesaid principles, we find that the legislature, in Section 40(a)(ii) has provided that "any rate or tax levied" on "profits and gains of business or profession" shall not be deducted in computing the income chargeable under the head "profits and gains of business or profession". There is no reference to any "cess". Obvious…

Msm Discovery P.Ltd, Mumbai vs. Asst CIT 12(3)(2), Mumbai

The appeal of the assessee is partly allowed in terms of our aforesaid observations

ITA 1935/MUM/2017[2012-13]Status: DisposedITAT Mumbai12 Oct 2020AY 2012-13

Bench: Shri Pramod Kumar & Shri Ravish Soodmsm Discovery Private Ltd. The Asst. Commissioner Of Income Interface Building No. 7, Tax-12(3)(2) 4Th Floor, Malad Link Road, Room No. 147B, 1St Floor, Vs. Malad (W), Aayakar Bhavan, M.K. Road Mumbai- 400 064 Churchgate, Mumbai – 400 020 Pan – Aagcs4253E (Appellant) (Respondent)

For Appellant: Shri P.J. Pardiwala, Senior AdvocateFor Respondent: Shri A. Mohan, CIT D.R

Section 143(3)Section 92C

…ITA No.1935/Mum/2017 A.Y. 2012-13 1 MSM Discovery Pvt. Ltd. Vs. The Asst. Commissioner of Income Tax-12(3)(2) IN THE INCOME TAX APPELLATE TRIBUNAL “J” Bench, Mumbai Before Shri Pramod Kumar, Vice President and Shri Ravish Sood, Judicial Member MSM Discovery Private Ltd. The Asst. Commissioner of Income Interface Building No. 7, Tax-12(3)(2) 4th Floor, Malad Link Road, Room No. 147B, 1st Floor, Vs. Malad (W), Aayakar Bhavan, M.K. Road Mumbai- 400 064 Churchgate, Mumbai – 400 020 PAN – AAGCS4253E (Appellant) (Respondent) Appellant by: Shri P.J. Pardiwala, Senior Advocate Respondent by: Shri A. Mohan, CIT D.R D…