DCIT 9(3)(1), MUMBAI vs. FEDEX EXPRESS TRANSPORTATION AND SUPPLY CHAIN SERVICES (INDIA) P.LTD, MUMBAI
The appeal of the revenue is dismissed
ITA 6872/MUM/2018[2014-15]Status: DisposedITAT Mumbai24 Feb 2021AY 2014-15
Bench: Shri Rajesh Kumar () & Shri Ravish Sood () & The Assistant Commissioner M/S Fedex Express Of Income Tax-9(3)(1), Vs. Transportation & Supply Chain Room No. 215, 2Nd Floor, Services (India) Private Limited Aayakar Bhavan, M.K. Road, Boomerang, 801, A Wing, Mumbai - 400020 Chandivali Farm Road, Andheri (East), Mumbai – 400072 Pan No. Aabcf6516A (Revenue) (Assessee) Assessee By : Shri Dhanesh Bafna, A.R Revenue By : Ms. Leena Srivastava, D.R Date Of Hearing : 23/02/2021 Date Of Pronouncement : 24/02/2021
For Appellant: Shri Dhanesh Bafna, A.RFor Respondent: Ms. Leena Srivastava, D.R
Section 143(1)Section 143(2)Section 143(3)Section 263Section 32
…s whether the CIT was justified in giving a direction in para 10.5 of his order on apportionment of goodwill between the assessee and its affiliates. The assessee relied upon the decision of the Bombay High Court in the case of Herdillia Chemicals reported in 221 ITR 194 and based on this decision submitted that since there is a specific direction on merits by the CIT to the AU, the Tribunal ought to adjudicate this issue. On perusal of the CITs order and applying the decision of the jurisdictional High Court, the assessee is justified in raising this issue before us. The direction of the CIT on this issue is wit…
