DCIT, KARAIKUDI vs. M.R.M.PLANTATIONS P. LTD., KARAIKUDI
In the results, the appeals of the assessee in ITA Nos
ITA 2947/CHNY/2014[2006-07]Status: DisposedITAT Chennai09 Oct 2015AY 2006-07
Bench: Shri N.R.S. Ganesan & Shri Chandra Poojari] आयकर अपील सं./I.T.A.Nos.2772 & 2773/Mds/2014 "नधा"रण वष" /Assessment Years : 2005-06 & 2006-2007. M/S. M.R.M. Plantations P. Ltd, Vs. The Deputy Commissioner Of No.40, M.R.M Arcade, Income Tax, Amman Sannathi Street, Circle Ii, Karaikudi Madurai [Pan Aaccm 9058R ] (अपीलाथ"/Appellant) (""यथ"/Respondent)
For Appellant: Shri. T.N. Seetharaman, AdvocateFor Respondent: Shri. P. Radhakrishnan, IRS, JCIT
Section 143(1)(a)Section 147Section 148Section 57Section 6(3)
…l Meeting were conducted in India; the income of the Malaysian Branch is included in the accounts of the company and the profits appropriated. 4. The CIT(A) ought to have noted that the Apex Court's decision in the case of CIT vs. P.V.A. Kulandagan Chettiar (267 ITR 657) is not applicable to the present case since the control and management of the affairs of the ITA Nos.2772, 2773, 2946 , :- 3 -: 2947 & 2948/2014 Malaysian Branch of the assessee is situated in India as the Share Holders and Annual General Meeting were conducted in India’’. 3. The facts of the case are that the assessee filed its return of inc…