M/S AD2PRO MEDIA SOLUTIONS PRIVATE LIMITED ,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION) CIRCLE-1(1), BANGALORE
In the result, all the 14 appeals filed by the assessee are allowed
ITA 490/BANG/2019[2011-12]Status: DisposedITAT Bangalore20 Mar 2020AY 2011-12
Bench: Shri A.K.Garodia & Shri P.K.Gadale(Ita Nos.490 To 503(Bang)/2019) (Assessment Years: 2011-12 To 2017-18) M/S Ad2Pro Media Solutions Pvt.Ltd., No.10, 2Nd Floor, Bannerghatta Road, J.P.Nagar-Iii Phase, Bangalore-560078 Appellant Vs The Deputy Commissioner Of Income Tax, (International Taxation) Circle-1(1), Bmtc Building, Koramangala, Bangalore-560095 Respondent
For Appellant: Shri V. Chandrashekar, AdvocateFor Respondent: Vandana Sagar, CIT-DR
Section 201Section 201(1)Section 9
…nds of assessee is this that the order passed by the AO u/s 201(1) and 201(1A) of the Act are time barred and in this regard, the assessee has placed reliance on the judgment by the Hon’ble Karnataka High Court rendered in the case of Bharat Hotels Ltd (2016) 384 ITR 77(Kar.) as per ground no. 2.2 raised by the assessee in ITA No.490(B)/2019 and similar ground in all remaining appeals. 2.1 On merit, this is the grievance of the asessee that all these appeals relate to the impugned payment made by the assessee during these 7 years towards marketing services and fees for facilitation services and the same cannot be…
