TALENTPRO INDIA HR PRIVATE LIMITED,CHENNAI vs. DCIT, CORPORATE CIRCLE 3(1), CHENNAI
In the result, both the appeals filed by the assessee are partly allowed for statistical purposes
ITA 2722/CHNY/2024[2019-20]Status: DisposedITAT Chennai25 Mar 2025AY 2019-20
Bench: Shri Aby T. Varkey & Shri S.R. Raghunathaआयकर अपील सं./I.T.A. Nos.2721 & 2722/Chny/2024 िनधा"रण वष"/Assessment Years: 2018-19 & 2019-20 Talentpro India Hr Private Limited, Vs. The Deputy Commissioner Of No. 30, Ethiraj Salai, Egmore, Income Tax, Chennai 600 008. Corporate Circle 3(1), Chennai. [Pan:Aabcp9823A] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से/ Appellant By : Shri Sanjeev Aditya, C.A. (Virtual) ""थ" की ओर से /Respondent By : Shri R. Clement Ramesh Kumar, Cit & Ms. R. Anita, Addl. Cit सुनवाईकीतारीख/Date Of Hearing : 13.02.2025 घोषणाकीतारीख /Date Of Pronouncement : 25.03.2025 आदेश / O R D E R Per S.R. Raghunathaboth The Appeals Filed By The Assessee Are Directed Against Different But Identical Orders Of The Addl/Jcit(A), Thiruvanantpuram Both Dated 28.08.2024 For The Assessment Years 2018-19 & 2019-20. 2. Since Issues Raised In Both The Appeals Are Similar Based On The Same Identical Facts, With The Consent Of Both The Parties, We Proceed To Hear The Appeals Together & Pass Consolidated Order For The Sake Of Convenience.
For Appellant: Shri Sanjeev Aditya, C.A. (Virtual)For Respondent: Shri R. Clement Ramesh Kumar, CIT &
Section 143(1)Section 2(24)(x)Section 36(1)(va)
…on of the assessee is that unless specifically directed by the Hon’ble Supreme Court to apply the judgement retrospectively, the judgement applies prospectively only, is not acceptable for the reason that in the case of M A Murthy v State of Karnataka, (2003) 7 SCC 517, the Hon’ble Supreme Court has held as under: “It is for this Court to indicate as to whether the decision in question will operate prospectively. In other words, there shall be no prospective over- ruling, unless it is so indicated in the particular decision. It is not open to be held that the decision in a particular case will be prospective in i…