E H BUILDING CONSULTANCY PVT. LTD.,CHENNAI vs. ITO, CORPORATE WARD 2(1),CHENNAI, CHENNAI
In the result, the appeal filed by the assessee is partly allowed for statistical purposes
ITA 459/CHNY/2023[2012-13]Status: DisposedITAT Chennai19 Jul 2023AY 2012-13
Bench: Shri V. Durga Raoआयकर अपील सं./I.T.A. No.459/Chny/2023 िनधा"रण वष"/Assessment Year: 2012-13 Eh Building Consultancy Pvt. Ltd., Vs. The Income Tax Officer, Flat No. 1C, First Floor, Gowri Chitra Corporate Ward 2(1), Garden Complex, 88/4, Arcot Road, Chennai. Vadapalani, Chennai 600 026. [Pan:Aabce8062E] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri G. Tarun, Advocate ""थ" की ओर से/Respondent By : Shri P. Sajit Kumar, Jcit सुनवाई की तारीख/ Date Of Hearing : 13.07.2023 घोषणा की तारीख /Date Of Pronouncement : 19.07.2023 आदेश /O R D E R This Appeal Filed By The Assessee Is Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi Dated 15.02.2023 Relevant To The Assessment Year 2012-13. 2. Brief Facts Of The Case Are That The Assessee Has Filed The Return Of Income For The Assessment Year 2012-13 On 30.09.2012 With Returned Income Of ₹.Nil. The Return Of Income Was Processed Under Section 143(1) Of The Income Tax Act, 1961 [“Act” In Short] Dated 15.03.2013. Thereafter, The Case Was Selected For Scrutiny Through Nd Notice Under 2
For Appellant: Shri G. Tarun, AdvocateFor Respondent: Shri P. Sajit Kumar, JCIT
Section 143(1)Section 143(2)Section 143(3)Section 14A
…w as it earlier stood. The relevant extract of the said judgment is reproduced herein below: ………………. ……………….. 7. The aforesaid proposition of law has been reiterated by the Supreme Court in M.M Aqua Technologies Ltd. V. Commissioner of Income Tax, Delhi-III, 2021 SCC OnLine SC 575. The relevant portion of the said judgment is reproduced herein below:- ………………. ……………… 8. Consequently, this Court is of the view that the amendment of Section 14A, which is “for removal of doubts” cannot be presumed to be retrospective even where such language is used, if it alters or changes the law as it earlier stood. 9. Though the…