Medreich Limited, Bangalore vs. Assistant Commissioner of Income Tax, Central Circle-1(2), Bangalore
In the result, the appeal filed by the assessee stands allowed as indicated hereinabove
ITA 451/BANG/2022[2017-18]Status: DisposedITAT Bangalore21 Oct 2022AY 2017-18
Bench: Shri Chandra Poojari & Smt. Beena Pillaiit(Tp)A No. 451/Bang/2022 Assessment Year : 2017-18 M/S. Medreich Ltd., No. 12/8, Medreich The Assistant House, Commissioner Of Saraswati Ammal Income Tax, Street, Central Circle – Maruti Seva Nagar, 1(2), Vs. Bangalore – 560 033. Bangalore. Pan: Aabcm1458Q Appellant Respondent : Shri Padam Chand Assessee By Khincha, Ca : Shri Praveen Karanth, Revenue By Cit-Dr Date Of Hearing : 27-07-2022 Date Of Pronouncement : 21-10-2022 Order Per Beena Pillaipresent Appeal Is Filed By Assessee Against The Final Assessment Order Passed By The Ld.Acit, Central Circle – 1(2), Bangalore Dated 26/04/2022 For A.Y. 2017-18 On Following Grounds Of Appeal: “General Ground 1.1 The Learned Assistant Commissioner Of Income Tax, Central Circle-1(2), Bangalore (`A0') Erred In Passing The Assessment Order Under Section 143(3) R.W.S 144C(13) Of The Income Tax Act, 1961 (`The Act) In The Manner Passed
For Respondent: Shri Padam Chand
Section 143(3)Section 14ASection 92B
…eferring to discussion in said order, it was stated that Hon'ble Delhi Bench in this case referred to the decision of the Hon'ble Bombay High Court in the case of CIT vs. Patni Page 10 of 13 IT(TP)A No. 451/Bang/2022 Computer Systems Ltd., reported in (2013) 215 Taxmann 108, which dealt with question of law: (c) `Whether on the facts and circumstances of the case and in law, the Tribunal did not err in holding that the loss suffered by the assessee by allowing excess period of credit to the associated enterprises without charging an interest during such credit period would not amount to international transaction…
