How many judgments cite Goetze (India) Ltd. v. CIT?

1,842 judgments on BharatTax cite Goetze (India) Ltd. v. CIT (284 ITR 323), spanning 2008 to 2026.

Which sections of the Income Tax Act does Goetze (India) Ltd. v. CIT come up under?

It is most often cited in judgments turning on Section 143(3), Section 14A, Section 115JB, Section 37(1), Section 147, Section 153A.

Goetze (India) Ltd. v. CIT

284 ITR 323Supreme Court of India2006#13 most cited

What is Goetze (India) Ltd. v. CIT authority for?

An assessee cannot raise a new claim or a claim not made in the original or revised return of income for the first time directly before the Assessing Officer during assessment proceedings.

1,842

judgments rely on this decision, according to BharatTax’s citation analysis of 367,514 Indian tax judgments — from 2008 to 2026.

Also referred to as

Goetze (India) Ltd v CIT · new claim by assessee · additional ground · revised return of income · section 139(5) · Assessing Officer powers · CIT(A) powers · ITAT powers · assessment proceedings · fresh claim · 284 ITR 323

Also reported as

157 Taxmann 1204 CTR 182157 Taxmann.com 1

Sections most often in play

Section 143(3)Section 14A Section 115JB Section 37(1)Section 147 Section 153A Section 143(1)Section 250

Issues it is cited on

section 139(5)book profits section 115j revenue expenditure section 115jb capital expenditure disallowance under section 14a section 32 section 254 section 37(1)transfer pricing adjustment liable to tax

Judgments citing Goetze (India) Ltd. v. CIT

M/S Bhandari Health Care Pvt. Ltd., Jaipur vs. Assistant Commissioner of Income Tax, Circle-6, Jaipur

ITA 688/JPR/2018[2013-14]Status: DisposedITAT Jaipur24 Aug 2022AY 2013-14

For Appellant: Sh. Sandeep JhanwarFor Respondent: Sh. Prathviraj Meena (CIT)

Section 143(3)Section 40Section 43B

…is in relation to the completing the assessment without considering the revised return of income filed in time by the assessee company. For this ground the ld. CIT(A) has recorded his finding that the apex court in the case of Goetze India Limited Vs. CIT 284 ITR 323 that the ITAT can consider such claim of the assessee made by the assessee in revised return of income. He further noted that the apex court did not consider this liberty to the CIT(A) and thus he has confirmed the view of the assessee. Since, there is no other adverse observation about the valid revised return M/s Bhandari Health Care Pvt. Lt…

Thermo Fisher Scientific India P.Ltd, Mumbai vs. DCIT 10(3), Mumbai

In the result, all the three additional grounds mentioned above are treated as allowed for statistical purposes

ITA 2701/MUM/2014[2009-10]Status: DisposedITAT Mumbai24 Aug 2022AY 2009-10

Section 43(6)(c)

…of Good will. The AO, however, did not allow the claim, as he took the view that the assessee should have made the new claim by filing revised return of income as per the decision rendered by Hon’ble Supreme Court in the case of Goetze India Limited vs. CIT (284 ITR 323)(SC). The Tribunal, vide its order dated 28-06- 2019, admitted the additional claim by observing that the Hon’ble Apex Court itself has held that the said decision would not impinge the power of the Tribunal to admit additional grounds. However, the Tribunal restored this issue to the file of AO, as it has not been examined at all by the AO. 3.…

M/S Stratergic Capital Corporation Pvt Ltd, Mumbai vs. ACIT Circle 2(3)(2), Mumbai

In the result, the appeal of the assessee is partly allowed for statistical purposes

ITA 4013/MUM/2019[2012-13]Status: DisposedITAT Mumbai23 Aug 2022AY 2012-13

Section 143(3)Section 37

…259/- earned by the assessee from securities, the assessee had claimed during the course of assessment proceedings that the same is not chargeable to tax. But the ld. AO applied the decision of Hon’ble Supreme Court in the case of Goetze India Ltd reported in 284 ITR 323 (SC) and denied the plea of the assessee. The ld. CIT(A) appreciated the contentions of the assessee and directed the ld. AO to verify the fact as to whether the said interest income earned from securities in the sum of Rs 54,32,259/- is exempt from tax or not and decide the issue in accordance with law. The ld. AR submitted that the ld. AO is no…

Asian Hotels (North) Ltd., New Delhi vs. ACIT, Circle- 3(2), New Delhi

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 6983/DEL/2019[2016-17]Status: DisposedITAT Delhi23 Aug 2022AY 2016-17

Bench: Shri Challa Nagendra Prasada N D Shri Pradip Kumar Kedia

For Appellant: C. AFor Respondent: Ms. Suman Malik

Section 43B

…u/s 43B while preparing the computation of taxable income by the appellant, merely on the ground that it was not claimed by filing of a revised return in view of the judgment of the Hon’ble Supreme Court in the case of Goetze (India) Ltd. vs. CIT reported in 284 ITR 323.” 3. The ld. Counsel for the assessee submits that in the course of assessment proceedings the assessee by way of letter dated 12.11.2018 requested the Assessing Officer to reduce Rs.2,03,44,553/- which was erroneously added back by the assessee under section 43B of the Income Tax Act, 1961 (the Act) in the computation of income pertaining to a…

JCIT (OSD), Circle 14, Pune vs. Kumar Builder Mumbai Realty Private Limited, Pune

In the result, the appeal filed by the Revenue in ITA

ITA 22/PUN/2020[2014-15]Status: DisposedITAT Pune22 Aug 2022AY 2014-15

Bench: Shri Inturi Rama Rao & Shri S. S. Viswanethra Ravisl.

For Appellant: Shri Nikhil S. PathakFor Respondent: Shri Abhinay Kumbhar &

Section 143(3)Section 14ASection 36(1)(iii)Section 43B

…IN THE INCOME TAX APPELLATE TRIBUNAL PUNE BENCH “A”, PUNE BEFORE SHRI INTURI RAMA RAO, ACCOUNTANT MEMBER AND SHRI S. S. VISWANETHRA RAVI, JUDICIAL MEMBER Sl. ITA No. Name of Appellant Name of Respondent Asst. No. Year 1-2 20/PUN/2020 JCIT (OSD), Circle- Kumar Urban 2013-14 21/PUN/2020 14, Pune. Development Private 2014-15 Limited, 10th Floor, Kumar Business Centre, CTS No.29, Opp. Pune Central Bund Garden, Pune-411001. PAN : AAACK7659N 3 22/PUN/2020 JCIT (OSD), Circle- Kumar Builder 2014-15 14, Pune. Mumbai Realty Private Limited, 10th Floor, Kumar Business Centre, CTS No.29, Opp. Pune Central Bund Garden, Pune-4…

JCIT (OSD), Circle 14, Pune vs. Kumar Urban Development Private Limited, Pune

In the result, the appeal filed by the Revenue in ITA

ITA 21/PUN/2020[2014-15]Status: DisposedITAT Pune22 Aug 2022AY 2014-15

Bench: Shri Inturi Rama Rao & Shri S. S. Viswanethra Ravisl.

For Appellant: Shri Nikhil S. PathakFor Respondent: Shri Abhinay Kumbhar &

Section 143(3)Section 14ASection 36(1)(iii)Section 43B

JCIT (OSD), Circle 14, Pune vs. Kumar Urban Development Private Limited, Pune

In the result, the appeal filed by the Revenue in ITA

ITA 20/PUN/2020[2013-14]Status: DisposedITAT Pune22 Aug 2022AY 2013-14

Bench: Shri Inturi Rama Rao & Shri S. S. Viswanethra Ravisl.

For Appellant: Shri Nikhil S. PathakFor Respondent: Shri Abhinay Kumbhar &

Section 143(3)Section 14ASection 36(1)(iii)Section 43B

Greaves Cotton Ltd., Mumbai vs. DCIT Cir 6(3), Mumbai

In the result, appeal by assessee is partly allowed in the terms aforesaid

ITA 7742/MUM/2014[2010-11]Status: DisposedITAT Mumbai22 Aug 2022AY 2010-11

Bench: Shri Vikas Awasthy & Shri Gagan Goyalआअसं.7742/मुं/2014 ("न.व. 2010-11) Greaves Cotton Ltd. 3Rd Floor, Motilal Oswal Tower, Junction Of Gokhale & Sayani Road, Prabhadevi, Mumbai 400 025. Pan: Aaacg-2062-M ...... अपीलाथ" /Appellant बनाम Vs. Dy. Commissioner Of Income Tax, Circle 6(3), Aaykar Bhavan, M.K.Road, ..... ""तवाद"/Respondent Mumbai 400 020. अपीलाथ" "वारा/ Appellant By : Smt. Aarti Vissanji, Advocate ""तवाद" "वारा/Respondent By : Smt. Vranda U. Matkari, Sr.A.R सुनवाई क" "त"थ/ Date Of Hearing : 27/05/2022 घोषणा क" "त"थ/ Date Of Pronouncement : 22/08/2022 आदेश/ Order

For Appellant: Smt. Aarti Vissanji, AdvocateFor Respondent: Smt. Vranda U. Matkari, Sr.A.R

Section 10(54)Section 115OSection 143(3)Section 14A

…dings the assessee raised alternate plea that sale of TDR does not give rise to capital gains as TDR has no cost. The fresh plea raised during assessment was rejected by the Assessing Officer in the light of judgment in the case of Goetz (India) Ltd. vs. CIT, 284 ITR 323(SC). We find that similar was the case in Assessment Year 2008-09. The Tribunal after admitting the additional ground/claim made in respect of income received on transfer of TDR, restored the issue back to the file of Assessing Officer to decide the issue 7 afresh in accordance with law. Without commenting on the merits of the issue, we deem it…

Sarika Amit Sanap, Aurangabad vs. Assistant Commissioner of Income-Tax, Circle - 3, Aurangabad

In the result, assessee‟s appeal is dismissed

ITA 77/PUN/2019[2015-16]Status: DisposedITAT Pune16 Aug 2022AY 2015-16

For Appellant: NoneFor Respondent: Shri M.G. Jasnani

Section 10Section 10(38)Section 131

…Aurangabad and the long term capital gains had been offered to tax @10% in the return of income, therefore she could not claim the income to be exempt V/s 10(38) of the Act in light of decision of Hon'ble Apex Court in the case of Goetze (India) Ltd. Vs. CIT (284 ITR 323). In this background, the AO was of the opinion that it was not understood as to why the appellant had invested in the shares of Mahavir Advanced Remedies Ltd., a company which was neither a large cap nor a mid cap scrip. The AO also found out that purchase and sale of shares of Mahavir Advanced Remedies Ltd., was a predetermined action leading t…

Coronet Hotel Services & Suppliers Pvt. Ltd., Delhi vs. ITO, Ward- 6(3), New Delhi

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 7418/DEL/2018[2013-14]Status: DisposedITAT Delhi11 Aug 2022AY 2013-14

For Appellant: Shri R.S. Singhvi, CAFor Respondent: Md. Gayasuddin Ansari, Senior DR

Section 143(1)Section 194Section 24

…at the issue of fixed rent or rent linked to the receipts is not decisive factor in this case because the important issue is the activity from the income is earned. He further referred to Hon’ble Supreme Court decision in the case of Goetze India Ltd. vs. CIT 284 ITR 323 wherein it was held that assessee cannot make a fresh claim before the AO without filing a revised return. He held that for cases referred by assessee, facts of the case are distinguishable from the facts of the assessee’s case. Hence he confirmed the AO’s action to assessee the rental income under the head ‘income from house property. 8 ITA No…

M/S. Patel Brass Works Pvt. Ltd., Rajkot vs. The ACIT-Circle-5, Rajkot

In the result, appeal of the assessee is dismissed

ITA 60/RJT/2020[2011-12]Status: HeardITAT Rajkot10 Aug 2022AY 2011-12

For Appellant: Shri R.D. Lalchandani, A.RFor Respondent: Shri B.D. Gupta, Sr. D.R

Section 139(1)Section 139(5)Section 143(3)Section 801ASection 80I

…IN THE INCOME TAX APPELLATE TRIBUNAL RAJKOT BENCH, RAJKOT Before: Shri Waseem Ahmed, Accountant Member And Shri Siddhartha Nautiyal, Judicial Member Assessment Year 2011-12 M/s. Patel Brass Works P. ACIT, Ltd. Rajkot Circle-5, PAN: AAFCP6759F Vs Rajkot (Appellant) (Respondent) Assessee by: Shri R.D. Lalchandani, A.R. Revenue by: Shri B.D. Gupta, Sr. D.R. Date of hearing : 30-06-2022 Date of pronouncement : 10-08-2022 आदेश/ORDER PER BENCH:- This assessee’s appeal for A.Y. 2011-12, arises from order of the CIT(A)-1, Rajkot dated 12-02-2020, in proceedings under section 143(3) of the Income Tax Act, 196…

Datalink Informatics P.Ltd, Mumbai vs. DCIT Cen Cir 09, Mumbai

In the result, appeal by the assessee is partly allowed for statistical purpose

ITA 571/MUM/2016[2010-11]Status: DisposedITAT Mumbai01 Aug 2022AY 2010-11

Bench: Shri Amarjit Singh & Shri Sandeep Singh Karhail

For Appellant: Ms. Shruti AgarwalFor Respondent: Shri C.T. Mathews

Section 132(1)Section 139Section 143(2)Section 143(3)Section 153CSection 250

…has been held by various Hon’ble Courts that disallowance under section 14A has to be restricted to the dividend income earned. Accordingly, the assessee has made a fresh claim before us. We find that Hon'ble Supreme Court in Goetz India Ltd. v/s CIT, [2006] 284 ITR 323 and Hon'ble Jurisdictional High Court in CIT v/s Pruthvi Brokers and Shareholders Pvt. Ltd., [2012] 349 ITR 336 (Bom.) has held that the appellate authority can entertain a fresh claim made by the assessee, even if such a claim was not made in return of income or by way of revised return of income. Further, as the issue raised by the assessee by…

The Dy. Commissioner of Income Tax, Circle-4(1)(2), Ahmedabad vs. Troikaa Pharmaceuticlas Limited, Ahmedabad

In the result, the CO filed by the assessee is dismissed as infructuous

ITA 939/AHD/2019[2011-12]Status: DisposedITAT Ahmedabad29 Jul 2022AY 2011-12

Bench: Shri Waseem Ahmed & Ms Madhumita Royआयकर अपील सं./Ita Nos. 939 & 1129/Ahd/2019 With C.O.Nos.169 & 181/Ahd/2019 िनधा"रण वष"/Asstt. Years: 2011-2012 & 2012-2013 D.C.I.T., Troikaa Pharmaceuticals Ltd., Circle-4(1)(2), Vs. Commerce House-I, Ahmedabad. Opp. Rajvansh Apartment, Judges Bunglow Road, Ahmedabad-380054. Pan: Aabct0228K

For Appellant: Shri Dhiren Shah, with Shri Karan Shah, A.RsFor Respondent: Shri Alokkumar, CIT.D.R

Section 37Section 37(1)Section 80I

…itional claim made by the assessee by holding that judgment in case of Cadila healthcare has been challenged before the higher forum. The AO further held that, as per the judgment of Hon’ble Supreme Court in the case M/s Goetze (India) Ltd vs. CIT reported in 284 ITR 323, the income shown in the return filed by the assessee cannot be revised merely by filing a letter to that ITA nos.939 & 1129/AHD/2019 With C.O.Nos. 167 & 181/Ahd/2019 Asstt. Years 2011-12 & 2012-13 18 effect. The AO on merit also rejected the claim of the assessee by holding that weighted deduction of R&D expenditure under section 35(2AB) is all…

The DCIT, Circle-4(1)(2), Ahmedabad vs. Troikaa Pharmaceuticals Ltd, Ahmedabad

In the result, the CO filed by the assessee is dismissed as infructuous

ITA 1129/AHD/2019[2012-13]Status: DisposedITAT Ahmedabad29 Jul 2022AY 2012-13

For Appellant: Shri Dhiren Shah, with Shri Karan Shah, A.RsFor Respondent: Shri Alokkumar, CIT.D.R

Section 37Section 37(1)Section 80I

Sambhavnath Infrabuild and Farms Pvt. Ltd, Mumbai vs. DCIT Cent. Cir7(3), Mumbai

The appeal is allowed

ITA 2117/MUM/2021[2017-18]Status: DisposedITAT Mumbai26 Jul 2022AY 2017-18

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm Sambhavnath Infrabuild & Farms Pvt. Ltd. Dcit Circle 7(3) Successor To Bellissimo Realtors Room No. 655, 6 Th Floor, Pvt. Ltd., 412, Floor–4, Aayakar Bhavan, Vs. 17G Vardhman Chamber, Cawasji Mk Road, Patel Road, Mumbai-400 020 Horniman Circle, Fort Mumbai-400 001 (Appellant) (Respondent) Pan No. Aalcs 1394 M

For Appellant: Shri Vijay Mehta, ARFor Respondent: Shri S. Anbuselvam, DR

Section 10Section 10(38)Section 115JSection 143

…Sambhavnath Infrabuild and farms Pvt. Ltd.; A.Y. 17–18 IN THE INCOME TAX APPELLATE TRIBUNAL “G” BENCH, MUMBAI BEFORE SHRI PRASHANT MAHARISHI, AM AND SHRI PAVAN KUMAR GADALE, JM Sambhavnath Infrabuild and Farms Pvt. Ltd. DCIT Circle 7(3) Successor to Bellissimo Realtors Room no. 655, 6 th Floor, Pvt. Ltd., 412, Floor–4, Aayakar Bhavan, Vs. 17G Vardhman Chamber, Cawasji MK Road, Patel Road, Mumbai-400 020 Horniman Circle, Fort Mumbai-400 001 (Appellant) (Respondent) PAN No. AALCS 1394 M Assessee by : Shri Vijay Mehta, AR Revenue by : Shri S. Anbuselvam, DR Date of hearing: 11.07.2022 Date of pronouncement : 26.…

Shri Sejalbhai G. Patel, Surat vs. The Income Tax Officer, Surat

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 971/AHD/2016[2012-13]Status: DisposedITAT Surat20 Jul 2022AY 2012-13

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकरअपीलसं./Ita No.971/Ahd/2016 ("नधा"रणवष" / Assessment Years: (2012-13) (Physical Court Hearing) Sejalbhai G. Patel, Vs. The Ito, Ward-1, 225, Khodiyar Nagar Soceity, Gandhi Bardoli. Road, Bardoli, Surat. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Apdpp9316C (Assessee) (Respondent) Assessee By: Shri Sapneth Sheth, Ca Revenue By: Shri J. K. Chandnani, Sr. Dr सुनवाईक"तार"ख/ Date Of Hearing : 12/05/2022 घोषणाक"तार"ख/Date Of Pronouncement : 20/07/2022 आदेश / O R D E R Per Dr. A. L. Saini: The Captioned Appeal Filed By The Assessee, Pertaining To Assessment Year 2012-13, Is Directed Against The Order Passed By The Learned Commissioner Of Income Tax (Appeals)-1, [In Short ‘Ld. Cit(A)’] Surat, In Appeal No. Cas-I/424/2014-15 Dated 18.02.2016, Which In Turn Arises Out Of An Order Passed By Assessing Officer U/S 143(3) Of The Income Tax Act, 1961 (Hereinafter Referred To As The ‘Act’).

For Appellant: Shri Sapneth Sheth, CAFor Respondent: Shri J. K. Chandnani, Sr. DR

Section 143(3)Section 50CSection 54BSection 54F

…o claim the exemption under section 10(35) in the return could not debar the assessee from claiming the same. It was also observed that dividend income was statutorily exempt and the decision of Honourable Supreme Court in case of Goetze (India) Ltd. vs. CIT -204 CTR 182 (SC) was duly considered. Ratio of above decision is directly applicable to the facts of instant case. Exemption u/s 54F on account of construction of new residential house property:- 8. In the course of appellate proceedings, it is submitted that capital gain is not chargeable to tax because assessee has also constructed new residential house pr…

Mr.Rahil Mahesh Kumar Nizamuddin, Bangalore vs. Deputy Commissioner of Income Tax (International Taxation) Circle-1(2), Bangalore

In the result, the appeal of the assessee is partly allowed

ITA 892/BANG/2019[2014-15]Status: DisposedITAT Bangalore18 Jul 2022AY 2014-15

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year: 2014-15

For Appellant: Shri K.Y. Ningoji Rao, A.RFor Respondent: Shri V.S. Chakrapani, D.R

Section 48Section 54FSection 55A

…ssee has not incurred this expenditure. The only plea of the Ld. D.R. is that there was no claim by the assessee in the original return of income filed by the assessee. In our opinion, as held by Hon’ble Supreme Court in the case of Goetz (India) Ltd. Vs. CIT 284 ITR 323 (SC), wherein the assessee filed the return of income for the relevant assessment year without claiming a particular deduction, later on, it sought to claim the deduction by way of a letter addressed to the AO the deduction disallowed by the AO on the ground that there was no provision under the Act to make amendment in the return of income by ma…

Shri Chetanbhai Ramjibhai Aviaiya, Surat vs. Income Tax Officer, Ward -3(2)(2), Surat

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 364/SRT/2017[2014-15]Status: DisposedITAT Surat15 Jul 2022AY 2014-15

Bench: Shri Pawan Singh & Dr Arjun Lal Sainiआ.अ.सं./Ita No.364/Srt/2017(Ay 2014-15) (Hearing In Virtual Court) Shri Chetanbhai Ramjibhai Income Tax Officer, Ward- Avaiya, 24, Tapovan Society 3(2)(2), Room No.415, 4Th Vs Ved Road, Katargam, Floor, Aayakar Bhavan, Surat Surat Pan : Afspa 0072 J अपीलाथ"/Appellant ""यथ" /Respondent

Section 143(1)Section 154Section 253Section 254(1)

…s, we treat the rectification application filed under section 154 of assessee as additional claim of the assessee and admit the same for consideration. 12. Our view is also strengthen by the decisions Hon'ble Supreme Court in Goetez (India) Ltd. Vs CIT (2006) 284 ITR 323/158 Taxman 1 (SC) while discussing the scope of power of Tribunal under section 254 clarify though the assessing officer is not empower to entertain new claim without the assessee revising the return of income, however, this restriction is not impinge on the power of Tribunal under section 254. Further Hon'ble jurisdictional High Court in the cas…

Jaya Hind Industries Pvt. Ltd., (Earlier Known As Jaya Hind Investments Pvt.Ltd, Pune vs. Assistant Commissioner of Income-Tax, Circle - 9, Pune

ITA 739/PUN/2018[2012-13]Status: DisposedITAT Pune15 Jul 2022AY 2012-13

For Appellant: Shri Mukesh M. PatelFor Respondent: Shri S.P. Walimbe

Section 12ASection 143(3)Section 80BSection 80GSection 80G(5)

…. 1,99,33,256/- on the ground that the form No. 3CL dt. 21-5- 2015 was received subsequent to the last date for filing of the revised return. The AO rejected the claim relying on the judgment of supreme Court in the case of Goetz Indi Ltd. Vs. CIT reported in 284 ITR 323 (SC) (2006). 5.2 The appellant during the course of appeal proceedings submitted that CT(A) is empowered to entertain the claim of assessee by relying on the lay High Court decision in the case of ClT Vs. Prithvi Brokers and Shareholders reported in 349 ITR 336 (2012) (Bom). The appellant also filed copies of the Form No.3CM dtd.24/5/2013 approvi…

Sitel India Ltd, Mumbai vs. DCIT RG 8(3), Mumbai

In the result, appeal by the Revenue is partly allowed

ITA 1777/MUM/2012[2007-08]Status: DisposedITAT Mumbai15 Jul 2022AY 2007-08

Bench: Shri Pramod Kumar & Shri Sandeep Singh Karhail

For Appellant: Shri Ajit Jain a/wFor Respondent: Shri Tejinder Pal Singh

Section 10ASection 250

…IN THE INCOME TAX APPELLATE TRIBUNAL “J” BENCH, MUMBAI BEFORE SHRI PRAMOD KUMAR, VICE PRESIDENT AND SHRI SANDEEP SINGH KARHAIL, JUDICIAL MEMBER ITA No.1777/Mum./2012 (Assessment Year : 2007–08) Sitel India Ltd. 4A, Parke Davis Complex ……………. Appellant Saklnaka, Andheri Kurla Road Mumbai 400 072 PAN – AAFCS1297M v/s Dy. Commissioner of Income Tax Range–8(3), Mumbai …………….Respondent ITA No.1426/Mum./2012 (Assessment Year : 2007–08) Asstt. Commissioner of Income Tax ……………. Appellant Circle–8(3), Mumbai v/s Sitel India Ltd. 4A, Parke Davis Complex Saklnaka, Andheri Kurla Road ……………. Respondent Mumbai 400 072 PAN…