Pr. CIT Circle-2, Mumbai vs. Bharat Prtroleum Corporation Ltd., Mumbai
In the result, the appeal of the assessee is partly allowed
ITA 1601/MUM/2020[2016-17]Status: DisposedITAT Mumbai05 Sept 2022AY 2016-17
Bench: Shri Pramod Kumar, Vp & Shri Aby T. Varkey, Jm आयकर अपील सं/ I.T.A. No.1601/Mum/2020 (निर्धारण वर्ा / Assessment Year: 2016-17) Bharat Petroleum बिधम/ Pcit, Circle-2 Corporation Ltd. Room No.344, Aayakar Vs. Taxation Section, Bhavan, M. K. Road, 4Th Floor, Bharat Bhavan 1, Mumbai-400020. 4 & 6 Currimbhoy Road, Ballard Estate, Mumbai- 400001. स्थधयी लेखध सं./जीआइआर सं./Pan/Gir No. : Aaacb2902M (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) Assessee By: Shri Jehangir D. Mistry Revenue By: Dr. Mahesh Akhade (Dr) सुनवाई की तारीख / Date Of Hearing: 28/06/2022 घोषणा की तारीख /Date Of Pronouncement: 05/09/2022 आदेश / O R D E R Per Aby T. Varkey, Jm: This Appeal Has Been Preferred By The Assessee Against The Order Of The Ld. Principal Commissioner Of Income Tax-02 [Hereinafter Referred To As The “Pcit”], Mumbai Dated 21.02.2020 For Assessment Year [Hereinafter Referred To As “Ay”] 2016-17 Passed Under Section 263 Of The Income Tax Act, 1961 [Hereinafter Referred To As “The Act”].
For Appellant: Shri Jehangir D. MistryFor Respondent: Dr. Mahesh Akhade (DR)
Section 10(34)Section 142(1)Section 143(3)Section 2Section 263Section 32A
…considered by various High Courts and decided in the affirmative but those decisions were not challenged by the Department. The cases specifically referred were M/s. Puttur Petro Products Pvt. Ltd. v. The Assistant Commissioner of Income Tax, Mangalore (2014) 361 ITR 290 )and Central U.P. Gas Ltd. v. Deputy Commissioner of Income Tax, Kanpur (Income Tax Appeal No. 224 of 2014 decided by High Court of Allahabad. 19) From the submissions made by learned counsel for the Revenue, who banked on the reasoning given by the AO, it can be gathered that the entire thrust of the AO was that the process involved in filling u…
