M/S Hcl Technologies Ltd., Noida vs. ACIT (TDS), Noida
In the result appeal of assessee is allowed
ITA 1723/DEL/2017[2009-10]Status: DisposedITAT Delhi20 Jul 2020AY 2009-10
Bench: Shri Amit Shukla & Shri Prashant Maharishihcl Technologies Ltd, Acit(Tds), Plot No. 3A, Tower 6, 14Th Floor, Vs. Noida Sector-126, Noida Pan: Aaach1645P (Appellant) (Respondent)
For Appellant: Shri Neeraj Jain, AdvFor Respondent: Ms. Rakhi Vimal, Sr. DR
Section 194CSection 201Section 201(1)Section 40
…ts, which have become final due to bar of limitation prior to 1-4-1989 and this position is applicable equally to reassessments proposed on the basis of Orders passed under the Act or under any other law." 13.7 In the case of Manan Corpn. v. Asstt. CIT [2013] 356 ITR 44/214 Taxman 373/29 taxmann.com 15 (Guj.), the Division Bench of this court in para 28 and 30 has observed and held as under :— "28. ... In the case of Commissioner of Income-Tax v. Gold Coin Health Food P. Ltd. reported in 304 ITR 308, the Hon'ble Supreme Court of India has held as under : In Zile Singh v. State of Haryana [2004] 8 SCC 1, it was ob…