ITO 11(3)(4), MUMBAI vs. ZENTA P.LTD, MUMBAI
In the result, appeal of the revenue in ITA No
ITA 1802/MUM/2015[2010-11]Status: DisposedITAT Mumbai04 Sept 2019AY 2010-11
Bench: Shri M.Balaganesh, Am & Shri Ravish Sood, Jm Ito 11(3)(4) Vs. M/S. Zenta Pvt. Ltd., Room No.429, 4Th Floor 6Th Floor, Unit No.601, Aayakar Bhavan Nomura Mumbai – 20 Hiranandani Business Park Powai, Mumbai – 400 076 Pan/Gir No.Aaach3235M (Appellant) .. (Respondent) Co No.164/Mum/2015 (Arising Out Of Ita No.1802/Mum/2015) (Assessment Year :2010-11) M/S. Zenta Pvt. Ltd., Vs. Ito 11(3)(4) 4Th Floor, Tower Ii Room No.429, 4Th Floor Phase Ii, Logitech Park Aayakar Bhavan Andheri Kurla Road Mumbai – 400020 Andheri (E) Mumbai – 400 072 Pan/Gir No.Aaach3235M (Appellant) .. (Respondent) Ito 11(3)(4) Vs. M/S. Zenta Pvt. Ltd., Room No.429, 4Th Floor 6Th Floor, Unit No.601, Aayakar Bhavan Nomura, Hiranandani Mumbai – 400020 Business Park, Powai, Mumbai – 400 076 Pan/Gir No.Aaach3235M (Appellant) .. (Respondent) Co No.85/Mum/2016 (Arising Out Of Ita No.795/Mum/2016) (Assessment Year :2011-12) M/S. Accenture Solutions Vs. Ito 11(3)(4) Pvt. Ltd., (Formerly Known Aayakar Bhavan As Zenta Pvt. Ltd.,) Mumbai – 400020 M/S. Zenta Pvt. Ltd., 4Th Floor, Tower Ii Phase Ii, Logitech Park Andheri Kurla Road Andheri (E) Mumbai – 400 072 Pan/Gir No.Aaach3235M (Appellant) .. (Respondent) Income Tax Officer 3(3)(4) Vs. M/S. Accenture Solutions Mumbai Pvt. Ltd., 4Th Floor, Tower Ii (Now Assessed Under Asst. Commissioner Of Income Tax Phase Ii, Logitech Park 11(3)(2), Room No.427 Andheri Kurla Road Aayakar Bhavan Andheri (E) Mumbai - 400020 Mumbai – 400 072 Pan/Gir No.Aaach3235M (Appellant) .. (Respondent) Co No.222/Mum/2014 (Arising Out Of Ita No.1623/Mum/2014) (Assessment Year :2009-10) M/S. Zenta Pvt. Ltd., Vs. Ito 3(3)(4) 4Th Floor, Tower Ii Room No.672, Phase Ii, Logitech Park Aayakar Bhavan Andheri Kurla Road Mumbai – 400020 Andheri (E) Mumbai – 400 072 Pan/Gir No.Aaach3235M (Appellant) .. (Respondent)
Section 143(3)Section 92C
…ccording to the ld. AR, said interest is only compensatory in nature and accordingly allowable as deduction. In support of this, the ld. AR placed reliance on the third member decision of Chennai Tribunal in the case of Mascon Global Ltd. vs. ACIT reported in 37 SOT 202 (Chennai)(TM) dated 26/08/2009 wherein it was held as under:- “11. So far as the main issue is concerned, that is regarding the allowability of the interest, I am unable to agree with the ld. Judicial Member that the assessee's claim should be dismissed. As already noted by me, the correct break up of the interest requires to be considered in pro…