M/S Xchanging Solutions Limited, Bangalore vs. The Deputy Commissioner of Income Tax Circle-7(1)(2), Bangalore
In the result, the appeal filed by the assessee is partly allowed for statistical purposes
ITA 3358/BANG/2018[2014-15]Status: DisposedITAT Bangalore01 Nov 2021AY 2014-15
Bench: Shri George George K, Jm & Shri B.R.Baskaran, Am It(Tp)A No.3358/Bang/2018 : Asst.Year 2014-2015 M/S.Xchanging Solutions Limited The Dy.Commissioner Of Plot No.13, 14, 15 Sjr I-Park Income-Tax, Circle 7(1)(2) V. Bangalore. Epip Industrial Area, Phase I Whitefield, Bangalore – 560066. Pan : Aafcs9303L. (Appellant) (Respondent) Appellant By : Sri.Chavali Narayanan, Ca Respondent By : Sri.Sumer Singh Meena, Cit(Osd)-Dr Date Of Pronouncement : 01.11.2021 Date Of Hearing : 28.10.2021 O R D E R Per George George K, Jm This Appeal At The Instance Of The Assessee Is Directed Against Final Assessment Order Dated 22.10.2018 Passed U/S 143(3) R.W.S. 144C Of The I.T.Act. The Relevant Assessment Year Is 2014-2015. 2. The Assessee Has Raised Various Grounds & Sub- Grounds. However, During The Course Of Hearing, The Learned Ar Limited His Submission To Grounds No.4.6(D), 4.11 To 4.14, 5.1 & 5.2. The Surviving Grounds Read As Follows:-
For Appellant: Sri.Chavali Narayanan, CAFor Respondent: Sri.Sumer Singh Meena, CIT(OSD)-DR
Section 143(3)Section 28Section 37(1)Section 92C
…oc disallowance of 10% of the per diem allowance granted to the employees computed at INR 7,97,471 due to non-collation of bills, without having regard to the jurisdictional High Court decision in the case of CIT v. Symphony Marketing Solutions India (P) Ltd (388 ITR 457) and the fact of actual incurrence of expenditure by the Appellant through reimbursement to employees.” 3. The brief facts of the case are as follows: The assessee is a private limited company having its registered office in Bangalore. The assessee has operating 3 IT(TP)A No.3358/Bang/2018. M/s Xchanging Solutions Limited. subsidiaries in USA,…