M/S Exide Life Insurance Company Limited, Bangalore vs. Assistant Commissioner of Income Tax Circle-2(1)(2), Bangalore
In the result, appeal by the assessee is partly allowed
ITA 839/BANG/2019[2013-14]Status: DisposedITAT Bangalore27 Jul 2021AY 2013-14
Bench: Shri N.V. Vasudevan & Shri Chandra Poojariassessment Year : 2013-14 M/S. Exide Life Insurance Company Ltd., Vs. The Assistant Commissioner Of No.3/1, Jp Technopark Millers Road, Income Tax, Bengaluru – 560 001. Circle – 2(1)(2), Pan : Aaaci 7940 L Bengaluru. Appellant Respondent Appellant By : Shri. Surya Narayana, Advocate Respondent By : Shri. Muzaffar Hussain, Cit(Dr)(Itat), Bengaluru Date Of Hearing : 26.07.2021 Date Of Pronouncement : 27.07.2021 O R D E R Per N.V. Vasudevanthis Is An Appeal By The Assessee Against The Order Dated 18.02.2019 Of Cit(A), Bengaluru-2, Bengaluru, Relating To Assessment Year 2013-14. 2. The First Issue That Requires Adjudication In This Appeal Is As To Whether The Cit(A) Was Justified In Upholding The Order Of The Ao In Determining The Alp Of The International Transaction Pertaining To Payment For Intra Group Services As Nil Against A Sum Of Rs.4,06,89,430/- Claimed By The Assessee To Have Been Paid To The Ae & Adding The Sum Of Rs.4,06,89,430/- As Income Of The Assessee Under Section 92 Of The Income Tax Act, 1961 (Act). Page 2 Of 13 3. The Facts With Regard To The Aforesaid Issue Are As Follows:
For Appellant: Shri. Surya Narayana, AdvocateFor Respondent: Shri. Muzaffar Hussain, CIT(DR)(ITAT), Bengaluru
Section 92
…IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH : BANGALORE BEFORE SHRI N.V. VASUDEVAN, VICE PRESIDENT AND SHRI CHANDRA POOJARI, ACCOUNTANT MEMBER Assessment year : 2013-14 M/s. Exide Life Insurance Company Ltd., Vs. The Assistant Commissioner of No.3/1, JP Technopark Millers Road, Income Tax, Bengaluru – 560 001. Circle – 2(1)(2), PAN : AAACI 7940 L Bengaluru. APPELLANT RESPONDENT Appellant by : Shri. Surya Narayana, Advocate Respondent by : Shri. Muzaffar Hussain, CIT(DR)(ITAT), Bengaluru Date of hearing : 26.07.2021 Date of Pronouncement : 27.07.2021 O R D E R Per N.V. Vasudevan, Vice President This is an appea…