CIT v. NHK Japan Broadcasting Corporation

305 ITR 137High Court2008#1219 most cited

What is CIT v. NHK Japan Broadcasting Corporation authority for?

When no specific statutory period of limitation exists, proceedings under Section 201(1) and 201(1A) of the Income-tax Act, particularly for payments to non-residents, must be initiated within a reasonable period of four years. This limitation also applies to consequential penalty proceedings under Section 271C.

94

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2010 to 2025.

Also referred to as

CIT v. NHK Japan Broadcasting Corporation · 305 ITR 137 · Section 201 limitation · Section 201(1) reasonable time · Section 201(1A) limitation · assessee in default non-resident · penalty Section 271C limitation · four years limitation · no statutory limitation · TDS proceedings

Sections most often in play

Section 143(3)Section 194ASection 201Section 271CSection 273BSection 120(4)(b)Section 124(3)Section 127

Issues it is cited on

section 201(3)assessee in defaultpenalty proceedings initiatedsection 273section 201(1)section 201section 201(1a)section 273bsection 20section 195section 19non-resident

Judgments citing CIT v. NHK Japan Broadcasting Corporation

THE DISTRICT MINING OFFICER,BAREILLY vs. INCOME TAX OFFICER (TDS), BAREILLY

ITA 246/LKW/2018[2008-09]Status: DisposedITAT Lucknow30 Jun 2025AY 2008-09

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

For Appellant: Revenue byFor Respondent: Date of hearing
Section 133ASection 206CSection 250

…e period for passing the order under section 201(1)/201(1A) of the Act would be four years. Accordingly, taking cue from such decisions of the Delhi High Court on the issue of section 201(1) and 201(1A) in the cases of CIT vs. N.H.K. Japan Broadcasting (2008) 305 ITR 137, Vodafone Essar Mobile Services vs. Union of India and Tata Tele Services vs. Union of India (order dated 9.03.2016) and other cases, the Hon'ble Jaipur Bench had held that four years was a reasonable period within which the ld. AO could pass the order under section 206C(6) / 206C(7) of the Act. Following the said order, the ITAT Lucknow Bench in…

NAGESH BABU VALIVETI,VIJAYAWADA vs. INCOME TAX OFFICER (INTERNAL TAXATION), VIJAYAWADA

In the result, appeal of the assessee is allowed

ITA 9/VIZ/2025[2012-13]Status: DisposedITAT Visakhapatnam30 Apr 2025AY 2012-13

Bench: Shri Vijay Pal Rao, Hon’Bles & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./ I.T.A. No.9/Viz/2025 (िनधा"रण वष" / Assessment Year :2012-13) Nagesh Babu Valiveti, Vs. Income Tax Officer, Vijayawada. Ward-International Taxation, Pan: Accpv7063J Vijayawada. (अपीलाथ"/ Appellant) (""यथ"/ Respondent) अपीलाथ" क" ओर से/ Appellant By : Sri C. Subrahmanyam, Ca ""याथ" क" ओर से / Respondent By : Dr. Aparna Villuri, Sr. Ar सुनवाई क" तारीख / Date Of Hearing : 23/04/2025 घोषणा क" तारीख/Date Of : 30/04/2025 Pronouncement O R D E R

For Appellant: Sri C. Subrahmanyam, CAFor Respondent: Dr. Aparna Villuri, Sr. AR
Section 195Section 201Section 201(1)Section 250

…tion of time for initiating the proceedings u/s 201/201(1A) and held that 4 years is the reasonable time for initiating proceedings u/s 201/201(1A). While holding so, the Hon’ble High Court has relied on the decision of CIT Vs. NHK Japan Broadcasting Limited [305 ITR 137] and the CIT Vs. Hutchison Essar Telecom. Limited [323 ITR 330], Further, Hon’ble Delhi High Court has considered amendment made to Section 201 of the Act vide Finance Bill, 2009 and viewed that the Parliament did not make any amendment to the time limits for the non residents which indicates that the Parliament has accepted the judicial pronounc…

M/S. BHARAT COKING COAL LIMITED,DHANBAD vs. JCIT TDS, DHANBAD

In the result, grounds of appeal raised by the assessee are allowed

ITA 77/RAN/2024[2010-11]Status: DisposedITAT Ranchi29 Apr 2025AY 2010-11

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahay

Section 194ASection 201Section 271CSection 273BSection 40

…the penalty levied in this case deserves to be deleted Hence, we set aside the orders of the authorities below and delete the penalty. 5. That we are also attaching herewith the decision of Hon'ble Delhi High Court in the case of CIT Vs NHK Japan Broadcasting 305 ITR 137, 172 taxman 230 which has been relied upon by the Coordinated Bench of Delhi ITAT in the above case. As such, in view of the above facts and case laws quoted, we submit that the initiation of penalty proceedings U/s 271C is barred by limitation and thus the orders passed thereby imposing the disputed penalties is fit to be set aside." 5. The ld.…

M/S. BHARAT COKING COAL LIMITED,,DHANBAD vs. JCIT, TDS CIRCLE,, DHANBAD

In the result, grounds of appeal raised by the assessee are allowed

ITA 76/RAN/2024[09-10]Status: DisposedITAT Ranchi29 Apr 2025

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahay

Section 194ASection 201Section 271CSection 273BSection 40

…the penalty levied in this case deserves to be deleted Hence, we set aside the orders of the authorities below and delete the penalty. 5. That we are also attaching herewith the decision of Hon'ble Delhi High Court in the case of CIT Vs NHK Japan Broadcasting 305 ITR 137, 172 taxman 230 which has been relied upon by the Coordinated Bench of Delhi ITAT in the above case. As such, in view of the above facts and case laws quoted, we submit that the initiation of penalty proceedings U/s 271C is barred by limitation and thus the orders passed thereby imposing the disputed penalties is fit to be set aside." 5. The ld.…

M/S. BHARAT COKING COAL LIMITED,DHANBAD vs. JT. CIT, TDS,, DHANBAD

In the result, grounds of appeal raised by the assessee are allowed

ITA 75/RAN/2024[08-09]Status: DisposedITAT Ranchi29 Apr 2025

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahay

Section 194ASection 201Section 271CSection 273BSection 40

…the penalty levied in this case deserves to be deleted Hence, we set aside the orders of the authorities below and delete the penalty. 5. That we are also attaching herewith the decision of Hon'ble Delhi High Court in the case of CIT Vs NHK Japan Broadcasting 305 ITR 137, 172 taxman 230 which has been relied upon by the Coordinated Bench of Delhi ITAT in the above case. As such, in view of the above facts and case laws quoted, we submit that the initiation of penalty proceedings U/s 271C is barred by limitation and thus the orders passed thereby imposing the disputed penalties is fit to be set aside." 5. The ld.…

ASSISTANT COMMISSIONER OF INCOME TAX, INTERNATIONAL TAXATION vs. ALLSCRIPTS (INDIA) PRIVATE LIMITED , VADODARA.

In the result, the appeal of the Revenue is dismissed

ITA 1373/AHD/2024[2014-15]Status: DisposedITAT Ahmedabad07 Feb 2025AY 2014-15

Bench: Smt.Annapurna Gupta & Shri T.R. Senthil Kumarassessment Year : 2014-15 Asstt.Cit (International Allscripts (India) Pvt. Ltd. Taxation),Vadodara. Vs 10Th & 11Th Floor, Atlantis Heights Dr. Vikram Sarabhai Road Vadodara. Pan : Aaccm 2641 J (Applicant) (Responent) : Assessee By Shri Rajpat Soni, Ar : Shri Amit Pratap Singh, Sr.Dr. Revenue By सुनवाई क" तारीख/Date Of Hearing : 08/01/2025 घोषणा क" तारीख /Date Of Pronouncement: 07/02/2025 आदेश/O R D E R आदेश आदेश आदेश

Section 195Section 201Section 201(1)Section 201(3)Section 250

…ounds raised by the Revenue are as under: (i) Whether the Hon'ble CIT(A) has erred in law and on facts in upholding the limitation of order u/s. 201 of the Act in light of Hon'ble Delhi High Court 2 decision in the case of NHK Japan Broadcasting Corporation 305 ITR 137 (Del.), which is relevant only for the cases pertaining to the period prior to 01.04.2010, when no limitation was in existence for proceedings w/s. 201 of the I. T. Act? (ii) Whether the Hon'ble CIT(A) has erred in law and on facts by ignoring the legal provision under Sec. 201 of the Act which does not prescribe any limitation In respect of paym…

INDOWORTH INDIA LIMITED,NAGPUR vs. ACIT(TDS), CIRCLE 51(1), NAGPUR

In the result, appeal filed by the assessee for A

ITA 4/NAG/2024[2013-14]Status: DisposedITAT Nagpur23 Sept 2024AY 2013-14

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri R.K. GaneriwalFor Respondent: Shri Abhay Y. Marathe
Section 201Section 201(1)Section 201(3)

…ation of time for initiating the proceedings u/s 201/201(1A) and held that 4 years is the reasonable time forinitiating proceedings u/s 201/201(1A). While holding so, the Hon’ble High Court has relied on the decision of CIT Vs. NHK Japan Broadcasting Limited [305 ITR 137] and the CIT Vs. Hutchison Essar Telecom. Limited [323 ITR 330], Further, Hon’ble Delhi High Court has considered amendment made to Section 201 of the Act vide Finance Bill, 2009 and viewed that the Parliament did not make any amendment to the time limits for the non residents which indicates that the Parliament has accepted the judicial pronounc…

M/S INDOWORTH INDIA LIMITED,NAGPUR vs. ACIT(TDS), CIRCLE 51(1) , NAGPUR

In the result, appeal filed by the assessee for A

ITA 3/NAG/2024[2012-13]Status: DisposedITAT Nagpur23 Sept 2024AY 2012-13

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri R.K. GaneriwalFor Respondent: Shri Abhay Y. Marathe
Section 201Section 201(1)Section 201(3)

…ation of time for initiating the proceedings u/s 201/201(1A) and held that 4 years is the reasonable time forinitiating proceedings u/s 201/201(1A). While holding so, the Hon’ble High Court has relied on the decision of CIT Vs. NHK Japan Broadcasting Limited [305 ITR 137] and the CIT Vs. Hutchison Essar Telecom. Limited [323 ITR 330], Further, Hon’ble Delhi High Court has considered amendment made to Section 201 of the Act vide Finance Bill, 2009 and viewed that the Parliament did not make any amendment to the time limits for the non residents which indicates that the Parliament has accepted the judicial pronounc…

INMOBI TECHNOLOGY SERVICES PRIVATE LIMITED,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE3(1)(1), BANGALORE

ITA 303/BANG/2022[2017-18]Status: DisposedITAT Bangalore11 Jun 2024AY 2017-18
For Appellant: \nShri Chaitanya, Sr. Advocate a/wFor Respondent: \nMs. Neera Malhotra, CIT-DR
Section 143(2)Section 143(3)Section 92C

…rways v. CIT [1992] 193 ITR 439/[1991] 54 Тахтап 470 has held that since no period of limitation for liability has been statutorily given, even the order passed after 6 years is valid, the Hon'ble Delhi High Court in CIT v. NHK Japan Broadcasting Corpn [2008] 305 ITR 137/172 Taxman 230 has held such order in the absence of the express time limit should be passed within a period of four years. Legislature stepped in by way of insertion of sub-section (3) to section 201 w.e.f. A.Y. 2010-11 providing the time limit for passing of the order deeming a person to be an assessee in default for failure to deduct the whole…

ADDL CIT R G 7(1), MUMBAI vs. NOVARTIS INDIA LTD ( FORMERLY KNOWN AS HINDUSTAN CIBA GIEGY LTD. ), MUMBAI

ITA 6772/MUM/2010[2002-03]Status: DisposedITAT Mumbai20 Mar 2024AY 2002-03

Bench: Shri Amit Shukla, Hon'Ble & Shri S. Rifaur Rahman, Hon'Blem/S. Novartis India Limited V. Asst. Commissioner Of Income –Tax - 7(2)(2) {Earlier Addl. Commissioner Of Income –Tax – 7(1)} 6Th& 7Th Floor 1St Floor, Aayakar Bhavan Inspire Bkc M.K. Road, Mumbai - 400020 “G” Block, Bkc Main Road Bandra Kurla Complex, Bandra (E) Mumbai – 400051 Pan: Aaach2914F (Appellant) (Respondent) Addl. Commissioner Of Income –Tax – 7(1) V. M/S. Novartis India Limited Room No. 622, Aayakar Bhavan {Earlier Known As Hindustan Ciba Giegy Ltd.,} Sandoz House, Dr. A.B. Road M.K. Road, Mumbai - 400020 Worli, Mumbai – 400018 Pan: Aaach2914F (Appellant) (Respondent) Co No.190/Mum/2011 [Arising Out Of Ita No.6772/Mum/2010 (A.Y. 2002-03)] M/S. Novartis India Limited V. Addl. Commissioner Of Income –Tax – 7(1)} Room No. 622, Aayakar Bhavan {Earlier Known As Hindustan Ciba Giegy Ltd.,} Sandoz House, Dr. A.B. Road M.K. Road, Mumbai - 400020 Worli, Mumbai – 400018 Pan: Aaach2914F (Appellant) (Respondent)

Section 120(4)(b)Section 127Section 143(2)Section 143(3)Section 2

…lk Producers Union Ltd. (2007) 11 SCC 363 (ii) State of Gujarat vs. Patel Raghav Natha and others AIR 1960 SCC 1297 (iii) Santosh Kumar Shivgonda Patil & Ors vs. Balasaheb Tukarams hevale (2009) 9 SCC 352 (iv) CIT vs. NHK Japan Broadcasting Corporation (2008) 305 ITR 137 (Del) (v) CIT vs. Hutchison Telecom Ltd. (2010) 323 ITR 320 (Del). 5.3 Although no time limit is prescribed for filing additional ground, it does not mean that it can be filed after any lapse of time in a reckless manner. Even when no time limit is provided for filing additional grounds, they need be filed within a reasonable time. In my respectf…

ASHWINI SAHAKARI RUNGNALAYA & RESEARCH CENTER,,SOLAPUR vs. COMMISSIONER OF INCOME-TAX, (EXEMPTIONS),, PUNE

ITA 714/PUN/2018[N.A]Status: DisposedITAT Pune07 Mar 2024

Bench: Hon’Ble Shri S. S. Viswanethra Ravi & Shri G. D. Padmahshaliआयकर अपील सं. / Ita No. 714/Pun/2018 Ashwini Sahakari Rugnalaya & Research Centre 7107/1, Plot No. 180, North Sadar Bazar, Solapur-413003. Pan: Aaaja0041K . . . . . . . अपीलार्थी / Appellant

For Appellant: Mr Pramod Shingte [‘Ld. AR’]For Respondent: Mr Keyur Patel [‘Ld. DR’]
Section 10Section 10(23)Section 11Section 12ASection 22Section 253(1)(c)

…at, the cancellation/revocation process traversed over a decade since it was first initiated, hence such far-fetched proceedings are untenable in law in the light of binding judicial precedents laid in ‘CIT Vs. NHK Japan Broadcasting Corporation’, reported in 305 ITR 137 (Del.); ‘DIT Vs. Mahindra & Mahindra Ltd.’, finds placed in 365 ITR 560 (Bom). ITAT-Pune Page 10 of 66 Ashwini Sahakari Rugnalaya & Research Centre 7.6 Lastly on the point of retrospective cancellation, the Ld. AR remonstrated that the power to cancel registration granted u/c (b) of s/s (1) of section 12AA was brought to statute first time by…

SH. ASHOK KUMAR PORWAL,JHALAWAR vs. JCIT, RANGE-1, KOTA, KOTA

In the result, appeal of the assessee is partly allowed

ITA 572/JPR/2023[2010-11]Status: DisposedITAT Jaipur19 Dec 2023AY 2010-11

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Sh. P. C. Parwal (CA)For Respondent: Smt Monisha Chaudhary (Addl. CIT)
Section 133(6)Section 147Section 269SSection 271D

…t be found out from the statutory scheme. As indicated hereinbefore, maximum period of limitation provided for in sub-section (6) of Section 11 of the Act is five years. The Hon’ble Delhi High Court in case of CIT Vs. NHK Japan Broadcasting Corporation (2008) 305 ITR 137 after considering the said decision of Hon’ble Supreme Court with reference to the proceedings initiated u/s 201 where no time limit for initiation of proceedings is prescribed at para 19 to 22 of its order held as under:- 19. Even though the period of three years would be a reasonable period as prescribed by s. 153 of the Act for completion of…

SARDA DEVI CHECHANI,UDAIPUR vs. ITO TDS, UDAIPUR

In the result, the appeals of the assessee are allowed for statistical purposes

ITA 127/JODH/2021[2013-14]Status: DisposedITAT Jodhpur23 Aug 2023AY 2013-14
Section 206CSection 5

…Act in respect of ‘tax deduction at source’. The reference is made to the decision of the Honble Bench in Raymond Woollen Mills Ltd. Vs. ITO 57 ITD 536 (Mum); CIT vs. Hutchison Essar Telecom Ltd. (2010) 323 ITR 230 (Del ); NHK Japan Broadcast ing Corporation 305 ITR 137 (Del ); State Bank of India vs. ACIT 106 ITD 589 (Mum) for the proposition that a period of four years was perceived as reasonable time limit by such judicial precedents. Thus such order under s. 206C of the Act cannot be passed after the expiry of four years from the end of the relevant financial year where default has been allegedly commit ted.…

SARDA DEVI CHECHANI,UDAIPUR vs. ITO TDS , UDAIPU

In the result, the appeals of the assessee are allowed for statistical purposes

ITA 126/JODH/2021[2012-13]Status: DisposedITAT Jodhpur23 Aug 2023AY 2012-13
Section 206CSection 5

…Act in respect of ‘tax deduction at source’. The reference is made to the decision of the Honble Bench in Raymond Woollen Mills Ltd. Vs. ITO 57 ITD 536 (Mum); CIT vs. Hutchison Essar Telecom Ltd. (2010) 323 ITR 230 (Del ); NHK Japan Broadcast ing Corporation 305 ITR 137 (Del ); State Bank of India vs. ACIT 106 ITD 589 (Mum) for the proposition that a period of four years was perceived as reasonable time limit by such judicial precedents. Thus such order under s. 206C of the Act cannot be passed after the expiry of four years from the end of the relevant financial year where default has been allegedly commit ted.…

SARDA DEVI CHECHANI,UDAIPUR vs. ITO TDS, UDAIPUR

In the result, the appeals of the assessee are allowed for statistical purposes

ITA 125/JODH/2021[2011-12]Status: DisposedITAT Jodhpur23 Aug 2023AY 2011-12
Section 206CSection 5

…Act in respect of ‘tax deduction at source’. The reference is made to the decision of the Honble Bench in Raymond Woollen Mills Ltd. Vs. ITO 57 ITD 536 (Mum); CIT vs. Hutchison Essar Telecom Ltd. (2010) 323 ITR 230 (Del ); NHK Japan Broadcast ing Corporation 305 ITR 137 (Del ); State Bank of India vs. ACIT 106 ITD 589 (Mum) for the proposition that a period of four years was perceived as reasonable time limit by such judicial precedents. Thus such order under s. 206C of the Act cannot be passed after the expiry of four years from the end of the relevant financial year where default has been allegedly commit ted.…

SH. SWAPNIL AGARWAL,1, AGARWAL DHARAM KANTA, ADARSH NAGAR, AJMER vs. ITO(TDS), AJMER, AJMER

ITA 160/JPR/2023[2014-15]Status: DisposedITAT Jaipur10 May 2023AY 2014-15

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Sh. P. C. Parwal (CA)For Respondent: Smt Monisha Chaudhary (Addl. CIT)
Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 194ISection 201(1)Section 271CSection 274

…must be found out from the statutory scheme. As indicated hereinbefore, maximum period of limitation provided for in sub-section (6) of Section 11 of the Act is five years. Hon’ble Delhi High Court in case of CIT Vs. NHK Japan Broadcasting Corporation (2008) 305 ITR 137 after considering the said decision of Hon’ble Supreme Court with reference to the proceedings initiated u/s 201 where no time limit for initiation of proceedings is prescribed at para 19 to 22 of its order held as under:- 19. Even though the period of three years would be a reasonable period as prescribed by s. 153 of the Act for completion of…

AMBATTUR DEVELOPER (P) LTD.,CHENNAI vs. DCIT INTERNATIONAL TAXATION 1(1), CHENNAI

The appeal stands allowed in terms of our above order

ITA 2348/CHNY/2017[2009-10]Status: DisposedITAT Chennai04 Jan 2023AY 2009-10

Bench: Hon’Ble Shri Mahavir Singh & Hon’Ble Shri Manoj Kumar Aggarwal, Am

For Appellant: Shri D. Anand (Advocate)-Ld. ARFor Respondent: Shri P. Sajit Kumar (JCIT) –Ld. DR
Section 201Section 201(1)Section 201(3)

…hat the Commissioner has to pass an order within a reasonable time and what is a reasonable time limit depends on the facts of that particular case. 10.7 The Hon’ble Delhi High Court in the case of CIT v. NHK Japan Broadcasting Corporation reported in [(2008) 305 ITR 137 (Delhi)] had held that the order passed u/s 201 of the I.T.Act beyond four years was not reasonable and had quashed the same as barred by limitation. Similar view was taken by the Hon’ble Himachal Pradesh High Court in the case of CIT v. Satluj Jal Vidyut Nigam Ltd. reported in [(2012) 345 ITR 552 (HP)]. As mentioned earlier, the learned DR submi…

SRINIVAS RUDRAPPA,BANGALORE vs. INCOME TAX OFFICER, TDS, WARD-3(1), BANGALORE

In the result, both the appeals filed by the assessee stands allowed

ITA 703/BANG/2022[2014-15]Status: DisposedITAT Bangalore02 Dec 2022AY 2014-15

Bench: Smt. Beena Pillai & Shri. Laxmi Prasad Sahu

For Appellant: Shri Rajiv C Nulvi, C.A : Smt. Priyadarshini
Section 133ASection 194HSection 201Section 201(1)

…hat the Commissioner has to pass an order within a reasonable time and what is a reasonable time limit depends on the facts of that particular case. 10.7 The Hon’ble Delhi High Court in the case of CIT v. NHK Japan Broadcasting Corporation reported in [(2008) 305 ITR 137 (Delhi)] had held that the order passed u/s 201 of the I.T.Act beyond four years was not reasonable and had quashed the same as barred by limitation. Similar view was taken by the Hon’ble Himachal Pradesh High Court in the case of CIT v. Satluj Jal Vidyut Nigam Ltd. reported in [(2012) 345 ITR 552 (HP)]. As mentioned earlier, the learned DR submi…

SRINIVAS RUDRAPPA,BANGALORE vs. INCOME TAX OFFICER, TDS, WARD-3(1), BANGALORE

In the result, both the appeals filed by the assessee stands allowed

ITA 702/BANG/2022[2013-14]Status: DisposedITAT Bangalore02 Dec 2022AY 2013-14

Bench: Smt. Beena Pillai & Shri. Laxmi Prasad Sahu

For Appellant: Shri Rajiv C Nulvi, C.A : Smt. Priyadarshini
Section 133ASection 194HSection 201Section 201(1)

…hat the Commissioner has to pass an order within a reasonable time and what is a reasonable time limit depends on the facts of that particular case. 10.7 The Hon’ble Delhi High Court in the case of CIT v. NHK Japan Broadcasting Corporation reported in [(2008) 305 ITR 137 (Delhi)] had held that the order passed u/s 201 of the I.T.Act beyond four years was not reasonable and had quashed the same as barred by limitation. Similar view was taken by the Hon’ble Himachal Pradesh High Court in the case of CIT v. Satluj Jal Vidyut Nigam Ltd. reported in [(2012) 345 ITR 552 (HP)]. As mentioned earlier, the learned DR submi…

THE ACIT (INT. TAXA), VADODARA vs. M/S. ALLSCRIPTS (INDIA) PVT.LTD., BARODA

In the result, the appeal of the Revenue is dismissed

ITA 41/AHD/2021[2013-14]Status: DisposedITAT Ahmedabad12 Oct 2022AY 2013-14

Bench: Ms. Suchitra Kamble & Shri Waseem Ahmed

For Appellant: Shri Atul Pandey, Sr. D.RFor Respondent: Shri Nikhil Mutha, A.R
Section 194ISection 195Section 201Section 201(1)Section 201(3)

…IN THE INCOME TAX APPELLATE TRIBUNAL “D” BENCH, AHMEDABAD BEFORE MS. SUCHITRA KAMBLE, JUDICIAL MEMBER & SHRI WASEEM AHMED, ACCOUNTANT MEMBER I.T.A. No. 41/Ahd/2021 (Assessment Year: 2013-14) The ACIT (Intl. Taxn), Vadodara Vs. M/s. Allscripts (India) Pvt. Room No. 202, 2nd Floor, GEB Ltd., 10th – 11th Floor, Building, Race Course Circle, Atlantis Heights, Vadodara-390007 Dr. Vikram Sarabhai Road, Vadodara-390023 [PAN No.AACCM2641J] (Appellant) .. (Respondent) Appellant by : Shri Atul Pandey, Sr. D.R. Respondent by : Shri Nikhil Mutha, A.R. Date of Hearing 06.09.2022 Date of Pronouncement 12.10.2022 O R D E R P…

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