“draft assessment order”

Assessment ProceduresSection 144CSection 144C4,773 judgments

The decision most relied on for draft assessment order is ACIT v. Serajuddin & Co. (454 ITR 312), cited in 580 judgments on BharatTax.

Leading authorities on draft assessment order

ACIT v. Serajuddin & Co.

454 ITR 312 · 2023 · High Court

580

citing judgments

Approval under Section 153D of the Income Tax Act is mandatory for assessment orders in search cases. While elaborate reasons for approval are not required, the approving authority must provide some indication that it has examined the draft orders and found them to meet the requirements of law.

Principal Commissioner of Income-tax v. Subodh Agarwal

149 Taxmann.com 373 · 2023 · High Court

194

citing judgments

Approval of draft assessment orders under Section 153D must be granted with due application of mind, not mechanically. Approving multiple cases, such as 38 in a single day, without proper scrutiny amounts to mechanical approval, rendering the assessment invalid.

Vijay Television (P.) Ltd. v. DRP

369 ITR 113 · 2014 · High Court

140

citing judgments

Passing a final assessment order under Section 143(3) directly, without first issuing a draft assessment order under Section 144C(1) for an eligible assessee, constitutes a fundamental jurisdictional defect. This defect cannot be cured by a subsequent corrigendum, especially if issued beyond the prescribed period of limitation.

ESPN Star Sports Mauritius S.N.C. ET Compagnie v. Union of India

388 ITR 383 · 2016 · High Court

citing judgments

Failure to issue a draft assessment order under Section 144C(1) makes the final assessment order illegal and beyond jurisdiction. Non-compliance with Dispute Resolution Panel (DRP) directions renders the final assessment order bad in law.

JCB India Ltd. v. DCIT

398 ITR 189 · 2017 · High Court

citing judgments

The requirement to pass a draft assessment order under Section 144C of the Act is mandatory. A final assessment order issued without such a draft order is a nullity, constituting an incurable jurisdictional error that cannot be saved by Section 292B, even in set-aside proceedings following an ITAT remand.

Aggarwal v. NFAC

127 Taxmann.com 637 · High Court

citing judgments

Denying a personal hearing when specifically requested, especially after a search and during a pandemic, violates the principles of natural justice. The assessment and appellate proceedings themselves were conducted during the COVID-19 pandemic.

Hire Purchase (P.) Ltd. v. NFAC

128 Taxmann.com 190 · High Court

citing judgments

Failure to grant a personal hearing to an assessee when income is likely to be varied based on submitted evidence violates the principles of natural justice and renders the assessment order invalid.

Chandrakant Dharia v. ITO

469 ITR 262 · Reported

citing judgments

An adverse assessment order cannot be passed without granting an opportunity of personal hearing to the taxpayer. Where income is to be varied based on evidence, a personal hearing is mandatory.

Judgments citing draft assessment order

Western Outdoor Interactive Pvt Ltd, Mumbai vs. Assessement Unit, Income Tax Department Asstt Comm. of Income Tax, Circle-16(1), Mumbai

ITA 2474/MUM/2022[2018-19]Status: DisposedITAT Mumbai16 Jul 2024AY 2018-19

Bench: Ms Padmavathy S, Am & Shri Rahul Chaudhary, Jm

For Appellant: Shri Dhanesh Bafna, Shri AmolFor Respondent: Shri Himanshu Sharma, CIT-DR

Section 143(3)Section 234ASection 244ASection 270ASection 40

period. The issues contended by the assessee for both the AYs are tabulated as under: Issue AY 2017-18 AY 2018-19 The draft assessment order passed is Ground No.1 (1.1 - barred by limitation and 1.2) Disallowance of export commission for Ground No.2 (2.1 - non-deduction of tax at source ... towards provision of sale and marketing services amounting to Rs. 6,62,392/-. The AO passed a draft assessment order incorporating the T.P. Adjustment. The AO also made a disallowance under section 40(a)(i) for non-deduction of tax at source on the Export Commission paid by the assessee

Western Outdoor Interactive Private Limited, Mumbai vs. Asstt. Comm. of Income Tax, Circle-16(1), Mumbai

ITA 2461/MUM/2022[2017-2018]Status: DisposedITAT Mumbai16 Jul 2024AY 2017-2018

Bench: Ms Padmavathy S, Am & Shri Rahul Chaudhary, Jm

For Appellant: Shri Dhanesh Bafna, Shri AmolFor Respondent: Shri Himanshu Sharma, CIT-DR

Section 143(3)Section 234ASection 244ASection 270ASection 40

Goldman Sachs (India) Securities Pvt.Ltd, Mumbai vs. ACIT Cir 7 (1) (1), Mumbai

ITA 1484/MUM/2021[2016-17]Status: DisposedITAT Mumbai16 Jul 2024AY 2016-17

Bench: Shri Narendra Kumar Billaiya, Hon'Ble & Shri Rahul Chaudhary, Hon'Bleι.Τ.Α. No. 1484/Mum/2021

For Appellant: Shri Madhur Agrawal, A/RFor Respondent: Shri Vachaspati Tripathi, CIT, D/R

Section 143(3)Section 144C(1)Section 144C(13)Section 153Section 253(1)Section 92C

Validity of final assessment order 1. In directly passing the final assessment order under section 143(3) of the Act, without passing the draft assessment order as applicable in case of Appellant being 'eligible Assessee' as per section 144C(1) of the Act, thereby entire order which not in consonance ... ITAT to decide this appeal according to law." 3. Vide Ground No. 1 (supra), the assessee has challenged the validity of the draft assessment order dt. 28/12/2019 and also legality and validity of subsequent DRP and final assessment order. 4. Representatives of both the sides were heard at length. Case

Brijeshkumar Jayantibhai Patel, Anand vs. The Income Tax Office, Ward-1(3)(1), Petlad

In the result, the appeal of the assessee in ITA No

ITA 18/AHD/2024[2011-12]Status: DisposedITAT Ahmedabad15 Jul 2024AY 2011-12

Bench: Income Tax Appellate Tribunal, Ahmedabad Bench , Ahmedabad For Assessment Year 2011-12 Is Directed Against The Appellate Order Dated 7Th November, 2023 Passed By Ld. Commissioner Of Income

For Appellant: Shri Vinit Mundra, A.RFor Respondent: Smt. Trupti Patel, Sr. D.R

Section 139Section 144Section 147Section 148Section 69A

paper book , wherein show cause notice dated 19.11.2018 issued by the Assessing Officer is placed. It was submitted that no draft assessment order was provided to the assessee. The Ld. Departmental Representative on the other hand submitted that assessee has now filed additional evidences before the Tribunal which requires verification

Income Tax Officer, Ward-1, Ahmednagar vs. Atul Ashok Parakh, Ahmednagar

In the result, the appeal of the Revenue and Cross Objection of the assessee both are dismissed

ITA 305/PUN/2024[2014-15]Status: DisposedITAT Pune15 Jul 2024AY 2014-15

Bench: Shri R.K. Panda & Ms. Astha Chandra

For Appellant: Shri Prasad S. BhandariFor Respondent: Shri Pawan Bharati

Section 132Section 143(2)Section 147Section 148Section 69

total income of the assessee u/s 69 of the Act. 6. A show cause notice dated 23.03.2022 with a copy of draft assessment order was sent to the assessee requiring him to furnish reply or raise objection, if any, in respect of addition proposed

Income-Tax Officer Ward-2, Ahmednagar vs. Samta Gramin Bigarsheti Sahakari Patsanstha Maryadit, Ahmednagar

In the result, the appeal filed by the Revenue stands dismissed

ITA 180/PUN/2024[2020-21]Status: DisposedITAT Pune15 Jul 2024AY 2020-21

Bench: Shri R. K. Panda & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.180/Pun/2024 िनधा"रण वष" / Assessment Year: 2020-21 Ito, Ward-2, Ahmednagar. Vs. Samta Gramin Bigarsheti Sahakari Patsanstha Maryadit, Newasa Shevgaon Road, Kukana, Tal. Newasa, Dist.-Ahmednagar- 414604. Pan : Aacas1915K Appellant Respondent Assessee By : Smt. Payal Rathi Revenue By : Shri Sourabh Nayak Date Of Hearing : 26.06.2024 Date Of Pronouncement 15.07.2024 : आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Revenue Is Directed Against The Order Dated 14.12.2023 Passed By Ld Cit(A)/Nfac For The Assessment Year 2020-21. 2. The Appellant Has Raised The Following Grounds Of Appeal :- “1. On The Facts & In The Circumstances Of The Case & In Law, The Ld. Cit(Appeals) Erred In Allowing The Deduction Of Rs.1,54,02,646/- U/S 80P(2)(D) Of The Act, As The Assessee Claimed Deduction U/S 80P(2)(D) In Respect Of The Interest Income From Investment, Which Is Not The Operational Income.

For Appellant: Smt. Payal RathiFor Respondent: Shri Sourabh Nayak

Section 143(1)Section 143(2)Section 143(3)Section 80PSection 80P(2)Section 80P(2)(a)Section 80P(2)(d)

were issued. After considering the reply of the assessee, the AO issued show cause notice along with draft assessment order requesting the assessee as to why the interest income earned from co-operative banks should not be disallowed. In response thereto, the assessee filed reply to the AO stating that

Asst. Commissioner of Income Tax, Vijayawada vs. Fysolate Technologies, Vijayawada

In the result, appeal of the Revenue is dismissed

ITA 182/VIZ/2023[2017-18]Status: DisposedITAT Visakhapatnam15 Jul 2024AY 2017-18

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./ I.T.A. No.182/Viz/2023 (िनधा"रण वष" / Assessment Year : 2017-18) Assistant Commissioner Of Vs. Fysolate Technologies, Income Tax, Vijayawada. Vijawayada. Pan: Aacff5633L (अपीलाथ"/ Appellant) (""यथ"/ Respondent) अपीलाथ" क" ओर से/ Assessee By : Sri Mithilesh Sannareddy ""याथ" क" ओर से / Revenue By : Dr. Satyasai Rath, Cit-Dr सुनवाई क" तारीख / Date Of Hearing : 16/04/2024 घोषणा क" तारीख/Date Of : 15/07/2024 Pronouncement O R D E R

For Appellant: Sri Mithilesh SannareddyFor Respondent: Dr. Satyasai Rath, CIT-DR

Section 10ASection 143(2)Section 143(3)Section 92C

based on the fact that the assessee is availing tax exemption U/s. 10AA of the Act. The Ld. AO thereafter passed a Draft Assessment Order U/s. 144C of the Act dated 05/05/2021 asking the assessee to file objection / appeal against the order either before Dispute Resolution Panel [“DRP”] or before

Nisha Thomas, Mumbai vs. Commissioner of Income Tax (A)-Drp-2, Mumbai

In the result, the appeal is allowed

ITA 2764/MUM/2024[2015-16]Status: DisposedITAT Mumbai15 Jul 2024AY 2015-16

Bench: Ms Padmavathy S, Am & Shri Raj Kumar Chauhan, Jm

For Appellant: Shri Gunjan Kakkad, CAFor Respondent: Shri Himanshu Sharma, CIT-DR

Section 142(1)Section 147Section 148Section 148A

unexplained investment and made addition accordingly. 3. The assessee filed its objections before the DRP against the draft assessment order passed by the AO. Before the DRP, the assessee admitted that she has sent certain amounts to her father who in turn has withdrawn the sums in cash

Krutika Ashwin Sarvaiya, Ahmedabad vs. The ITO, Ward-5(3)(4), Ahmedabad

In the result, the appeal of the assessee in ITA

ITA 43/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad12 Jul 2024AY 2017-18

Bench: Shri Ramit Kochar (Accountant Member)

For Appellant: Shri S.N. Divatia, AdvocateFor Respondent: Smt. Trupti Patel, Sr. D.R

Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 250Section 69A

Parveen M Makwana, and not to Shri Mohanbhai Jivabhai Makwana , and hence inspector report is not reliable. It was also submitted that draft assessment order was not provided to the assessee by the AO. It was submitted that return of income was filed after demonetization. It was submitted that

Pralay Pradyotkanti Ghosh, Ahmedabad vs. Income -Tax Officer, Ward-1, International Taxation, Ahmedabad

In the result, the appeal of Assessee is partly allowed

ITA 298/AHD/2022[2018-19]Status: DisposedITAT Ahmedabad12 Jul 2024AY 2018-19

Bench: Shri T.R. Senthil Kumar & Shri Makarand V. Mahadeokar, Accountnat Member आयकर अपील सं /Ita No.298/Ahd/2022 "नधा"रण वष" /Assessment Year : 2018-19 Pralay Pradyotkanti Ghosh The Ito बनाम/ 22, Konark Society Ward-1 Nr. Railway Colony International Taxation V/S. Jawahar Chowk, Sabarmati Ahmedabad Ahmedabad – 380 019 "थायी लेखा सं./Pan: Abypg 6172 C (अपीलाथ"/ Appellant) ("" यथ"/ Respondent) Assessee By : Shri Bandish Soparkar, Ar Revenue By : Shri Atul Pandey, Sr.Dr सुनवाई क" तार"ख/Date Of Hearing : 27/06/2024 घोषणा क" तार"ख /Date Of Pronouncement: 12/07/2024 आदेश/O R D E R Per Shri Makarand V. Mahadeokar, Am: This Appeal Is Filed By The Assessee As Against The Order Passed By The Ld.Commissioner Of Income-Tax(Appeals)-13, Ahmedabad [Hereinafter Referred To As “The Ld.Cit(A)”], Dated 01/06/2022, Arising Out Of The Assessment Order Passed By The Assessing Officer (Ao) Under Section 143(3) R.W.S.144C(3) Of The Income Tax Act, 1961 (Hereinafter Referred To As "The Act") Dated 22/10/2021 Relevant To The Assessment Year (Ay) 2018-19. Pralay Pradyotkanti Ghosh Vs. Ito (Intl.Taxation) Asst. Year : 2018-19

For Appellant: Shri Bandish Soparkar, ARFor Respondent: Shri Atul Pandey, Sr.DR

Section 139(1)Section 143(3)Section 192Section 2Section 5(2)(b)

grounds of assessee that the order was passed beyond the time limit u/s.153 of the Act, stating that AO had passed the draft assessment order on 03.09.2021. While doing so, the Ld. CIT(A) relied on the judgment of Hon’ble Gujarat High Court in the case ... assessee, shall be applicable from the date such amendment was introduced. From the records. it is seen that the AO passed the draft assessment order u/s. 144C(1) on 03.09.2021 giving the appellant an opportunity to file his objection if any, before the Hon'ble DRP within 30 days

ITO, Corporate Ward-2(1), Chennai vs. M/S Encore It Solutions Private Limited, Chennai

In the result, both the appeal filed by the Revenue and the cross objection filed by the assessee are dismissed

ITA 630/CHNY/2023[2016-17]Status: DisposedITAT Chennai11 Jul 2024AY 2016-17

Bench: Shri Mahavir Singhand Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 630/Chny/2023 िनधा"रण वष"/Assessment Year:2016-17 & C.O No.28/Chny/2023 [In I.T.A. No.630/Chny/2023] The Income Tax Officer, Encore It Solutions Pvt. Corporate Ward 2(1), Vs. Ltd., Chennai – 600 034. Htc Towers, No.41 Gst Road, Guindy, Chennai – 600 032. Pan: Aaace 8044K (अपीलाथ"/Appellant) (""यथ"/Respondent/Cross Objector) राज"व क" ओर से /Revenue By : Shrig. Suresh, Jcit िनधा"रती क" ओर से/Assessee By : Shri Vikram Vijayaraghavan, Advocate सुनवाई क" तारीख/Date Of Hearing : 11.07.2024 घोषणा क" तारीख/Date Of Pronouncement : 11.07.2024

For Appellant: Shri Vikram Vijayaraghavan, AdvocateFor Respondent: ShriG. Suresh, JCIT

Section 143(2)Section 143(3)Section 92C

margin, an adjustment of Rs.2,50,08,077/- is made to the value of the international transaction.” 4.1 Consequently, the AO passed the draft assessment order u/s.144C of the Act dated 06.11.2019 and made TP adjustment as - 5 - ITA No.630/CHNY/2023 & CO No.28/CHNY/2023 proposed by the TPO of Rs.2 ... Consequent to draft assessment order, as no objection was filed by the assessee before DRP, final assessment order was passed by the AO u/s.143(3) r.w.s. 92CA(3) of the Act dated 18.12.2019 and TP adjustment was retained at Rs.2,50,08,077/-. Aggrieved, assessee came in appeal before

Assistant Commissioner of Income Tax, Circle-3(4), Mumbai vs. Union Bank of India, Mumbai

ITA 1959/MUM/2024[2016-17]Status: DisposedITAT Mumbai11 Jul 2024AY 2016-17

Bench: Shri Om Prakash Kant () & Shri Sunil Kumar Singh ()

For Respondent: Mr. Ankush Kapoor, CIT-DR

Section 115JSection 143(3)Section 144BSection 148

erred in upholding the order passed u/s 144B, even when no time was given to appellant to furnish replies to the draft assessment order. Reopening of Assessment 2.1 On the facts and in the circumstances of the case and in law, the la. CIT(A) erred in upholding the reopening

M/S Union Bank of India, Mumbai vs. Deputy Commissioner of Income Tax, Circle- Ltu 2, Mumbai

ITA 1677/MUM/2024[2016-17]Status: DisposedITAT Mumbai11 Jul 2024AY 2016-17

Bench: Shri Om Prakash Kant () & Shri Sunil Kumar Singh ()

Section 115JSection 143(3)Section 144BSection 148

M/S Union Bank of India, Mumbai vs. Deputy Commissioner of India, Circle-(Ltu)-2, Mumbai

In the result, the appeal of the a In the result, the appeal of the assessee for assessment year ssessee for assessment year

ITA 1676/MUM/2024[2017-18]Status: DisposedITAT Mumbai11 Jul 2024AY 2017-18

Bench: Shri Om Prakash Kant () & Shri Sunil Kumar Singh ()

For Respondent: Mr. C Naresh

Section 144B

erred in upholding the order passed u/s 144B, even when no time was given to appellant to furnish replies to the draft assessment order. was given to appellant to furnish replies to the draft assessment order. was given to appellant to furnish replies to the draft assessment order. Reopening

Capgemini Technology Services India Limited (Successor to Capgemini India Private Limited, Airoli, Navi Mumbai vs. Commissioner of Income Tax (Appeals)- 55, Mumbai

Appeal is allowed

ITA 2657/MUM/2023[AY 2012-13]Status: DisposedITAT Mumbai11 Jul 2024

Bench: SHRI PRASHANT MAHARISHI, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri M P LohiaFor Respondent: Shri Vachashpati Tripathi

Section 143(3)Section 144CSection 144C(3)Section 92C

under section 92CA(3A) of the Income-tax Act, 1961 (‘the Act’) Invalidity of assessment proceedings Ground No. 17 Erred in issuing the draft assessment order without appreciating the fact that since the transfer pricing order is 2 bad in law, no transfer pricing adjustments can be said ... Officer (TPO) who passed order under Section 92CA(3) of the Act on 31/01/2016, proposing transfer pricing adjustment. The Assessing Officer passed the Draft Assessment Order on 31/03/2016, proposing additions/disallowances including the aforesaid transfer pricing adjustment. Sequent thereto, Assessing Officer passed the Final Assessment Order on 19/05/2016 under Section

Nachimuthugownder Balasamy Karthikeyan, Erode vs. ITO, International Taxation Ward, Coimbatore

In the result, the appeal stand partly allowed

ITA 428/CHNY/2024[2018-19]Status: DisposedITAT Chennai10 Jul 2024AY 2018-19

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm आयकरअपील सं./ Ita No.428/Chny/2024 (िनधा9रणवष9 / Assessment Year: 2018-19) Shri Nachimuthugownder Balasamy Ito बनाम/ Karthikeyan International Taxation Ward, 66, Kovalan 2Nd Street, Coimbatore. Vs. Teachers Colony, Erode-638 011. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aotpk-3606-H (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ" कीओरसे/ Appellant By : Shri S.Sridhar (Advocate) Erode - Ld.Ar " थ"कीओरसे/Respondent By : Shri Nilay Baran Som (Cit) - Ld. Dr सुनवाई की तारीख/Date Of Hearing : 20-06-2024 घोषणा की तारीख /Date Of Pronouncement : 10-07-2024 आदेश / O R D E R Manoj Kumar Aggarwal ()

For Appellant: Shri S.Sridhar (Advocate) Erode - Ld.ARFor Respondent: Shri Nilay Baran Som (CIT) - Ld. DR

Section 144CSection 144C(5)Section 147Section 148Section 148ASection 151ASection 69

pleaded for confirmation of impugned additions. Having heard rival submissions and upon perusal of case records, the appeal is disposed-off as under. Draft Assessment Order and Proceedings before Ld. DRP 3.1 The assessee being non-resident did not file its return of income. Pursuant to receipt of information that ... same date. The assessee filed return and admitted income of Rs.2.40 Lacs. The same was proposed to be determined at Rs.41.67 Lacs in draft assessment order dated 29.03.2023. In this order, Ld. AO proposed addition of cash deposit for Rs.16.63 Lacs, made addition of unexplained investment u/s 69 for Rs.2.42

M/S Regen Renewable Energy Generation Global Limited, Chennai vs. ACIT, International Taxation Circle - 2 (1), Chennai

The appeals stand allowed for statistical purposes

ITA 685/CHNY/2022[2015-2016]Status: DisposedITAT Chennai10 Jul 2024AY 2015-2016

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm 1. आयकरअपील सं./ Ita No.684/Chny/2022 (िनधा;रण वष; / Assessment Year: 2014-15) & 2. आयकरअपील सं./ Ita No.685/Chny/2022 (िनधा;रण वष; / Assessment Year: 2015-16) M/S Regen Renewable Energy Acit बनाम Generation Global Limited International Taxation New No.1, Pulla Avenue, / Vs. Circle-2(1), Chennai. Shenoy Nagar, Chennai-600 030. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aafcr-0685-N (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ" कीओरसे/ Appellant By : Shri B. Ramakrishnan (Ca) – Ld.Ar " थ"कीओरसे/Respondent By : Mrs. Jyothi Lakshmi Nayak (Cit)-Ld. Dr सुनवाई की तारीख/Date Of Hearing : 03-06-2024 घोषणा की तारीख /Date Of Pronouncement : 10-07-2024 आदेश / O R D E R Manoj Kumar Aggarwal ()

For Appellant: Shri B. Ramakrishnan (CA) – Ld.ARFor Respondent: Mrs. Jyothi Lakshmi Nayak (CIT)-Ld. DR

Section 115A(1)(b)Section 143(3)Section 144CSection 144C(5)Section 147Section 148Section 153Section 234B

well as issues are stated to be identical in both the years. First, we take up appeal for AY 2014-15 wherein a draft assessment order was passed by Ld. AO on 29-09-2021 which was subjected to assessee’s objections before Ld. DRP. Pursuant to the directions ... name M/s Regen Powertech Private Ltd. (RPPL) which is stated to be engaged in manufacturing of wind turbines. Assessment Proceedings 3.1 While passing draft assessment order, on the basis of scrutiny proceedings for AY 2013-14, it was alleged by Ld. AO that the assessee was mere intermediary

M/S Regen Renewable Energy Generation Global Limited, Chennai vs. ACIT, International Taxation Circle - 2 (1), Chennai

The appeals stand allowed for statistical purposes

ITA 684/CHNY/2022[2014-2015]Status: DisposedITAT Chennai10 Jul 2024AY 2014-2015

For Appellant: Shri B. Ramakrishnan (CA) – Ld.ARFor Respondent: Mrs. Jyothi Lakshmi Nayak (CIT)-Ld. DR

Section 115A(1)(b)Section 143(3)Section 144CSection 144C(5)Section 147Section 148Section 153Section 234B

M/S. Steer America Inc., United States vs. The Deputy Commissioner of Income Tax, International Taxation Circle -1(2), Bengaluru

In the result, both the appeals of the assessee are partly allowed

ITA 833/BANG/2024[2014-15]Status: DisposedITAT Bangalore10 Jul 2024AY 2014-15

Bench: Shri Chandra Poojari & Shri Prakash Chand Yadav

For Appellant: Sri Vasanth Kumar, A.RFor Respondent: Ms. Anjala Sahu, D.R

Section 144CSection 147Section 148

received as “fees for technical services” u/s 9(1)(vii) of the Act and brought to tax by ld. AO in his draft assessment order in the hands of present assessee. Against this assessee sought direction from the ld. DRP. 6.1 The assessee before ld. DRP submitted that the sales

M/S. Steer America Inc., United States vs. The Deputy Commissioner of Income Tax, International Taxation Circle -1(2), Bengaluru

In the result, both the appeals of the assessee are partly allowed

ITA 832/BANG/2024[2013-14]Status: DisposedITAT Bangalore10 Jul 2024AY 2013-14

Bench: Shri Chandra Poojari & Shri Prakash Chand Yadav

For Appellant: Sri Vasanth Kumar, A.RFor Respondent: Ms. Anjala Sahu, D.R

Section 144CSection 147Section 148