Koch Business Solutions India Private Limited, Bangalore vs. Deputy Commissioner of Income Tax Circle-4(3)(1), Bangalore
In the result, the appeal filed by the assessee is allowed
ITA 1844/BANG/2024[2020-21]Status: DisposedITAT Bangalore01 Apr 2026AY 2020-21
Bench: Shri Waseem Ahmed & Shri Keshav Dubey
For Appellant: Shri Chavali Narayan, A.RFor Respondent: Dr. Divya K.J., D.R
Section 143(3)
…llowing due process and in accordance with law.” 9.4 Further, in support of our contention we highly rely on the order of Hon’ble Telangana High Court in the case of RAPISCAN SYSTEMS PVT. LIMITED V. ADIT (INT. TAX) -2, HYDERABAD AND OTHERS reported in (2025) 473 ITR 485 wherein while considering the similar issue has placed reliance on the decision of Bombay High Court in the case of Vodafone Idea Ltd. (supra). The relevant findings of the Hon’ble High Court are extracted below: has held as under :- “FINDINGS: 13. Before dealing with rival contentions, it is apposite to consider Sections 144C(13) and 282(1)(c)…