“advance tax”

Chapter XVII - Collection & Recovery (Advance tax)Chapter XVII-CSection 2(1) / Chapter XVII-C / ITR Schedule IT1,785 judgments

The decision most relied on for advance tax is Bajaj Tempo Ltd. v. CIT (196 ITR 188), cited in 289 judgments on BharatTax.

Leading authorities on advance tax

Bajaj Tempo Ltd. v. CIT

196 ITR 188 · 1992 · Supreme Court

289

citing judgments

Provisions in taxing statutes that grant incentives, concessions, or exemptions for promoting economic growth and industrialization must be interpreted liberally and purposively. Any restrictions placed on such provisions should also be construed reasonably to advance their objective, not frustrate it.

DIT v. GE Packaged Power Inc.

373 ITR 65 · 2015 · High Court

199

citing judgments

Interest under section 234B for default in payment of advance tax is not leviable when the entire income is subject to tax deduction at source under section 195, as no advance tax liability arises for the assessee in such circumstances.

Sreenivas Charitable Trust v. Dy. CIT

280 ITR 357 · 2006 · High Court

182

citing judgments

The expression "sufficient cause" for condoning delay in filing appeals must receive a liberal and purposive construction. This approach aims to advance substantial justice, which is of paramount importance.

Pradip Kumar Malhotra v. CIT

338 ITR 538 · 2011 · High Court

152

citing judgments

Section 2(22)(e) of the Income Tax Act, which addresses deemed dividends, does not apply to loans or advances provided by a company to its shareholders if these transactions occur in the normal course of business, are driven by business expediency, or are made in consideration of a benefit conferred upon the company by the shareholder. Conversely, gratuitous loans or advances given to shareholders fall within the purview of this section.

DIT v. NGC Network Asia LLC

313 ITR 187 · 2009 · High Court

144

citing judgments

Where a duty is cast on the payer to deduct and pay tax at source under Section 195, the payee-assessee cannot be levied interest under Section 234B for failure to pay advance tax if the payer defaults on its TDS obligation. This principle may also extend to interest under Section 234C.

Topman Exports v. CIT

342 ITR 49 · 2012 · Supreme Court

121

citing judgments

Export incentives, such as DEPB (Duty Entitlement Pass Book) and advance license benefits, constitute income taxable on an accrual basis under Section 28 of the Income-tax Act. Profit arising on the transfer of DEPB is not eligible for deduction under Section 80HHC.

CIT v. Creative Dyeing & Printing Pvt. Ltd.

318 ITR 476 · 2009 · High Court

119

citing judgments

Genuine trade advances or amounts advanced for bona fide business transactions, driven by commercial expediency, do not fall within the definition of deemed dividend under section 2(22)(e) of the Income-tax Act.

CIT v. Raj Kumar

318 ITR 462 · 2009 · High Court

119

citing judgments

Genuine trade advances made by a company in the ordinary course of business to a shareholder do not fall within the definition of deemed dividend under Section 2(22)(e) of the Income-tax Act.

Judgments citing advance tax

Measeg. Surinder Sat Agro Foods, Jalalabad vs. Deputy Commissioner of Income Tax Circle-II, Bathinda

In the result, the three appeals of the assessee are allowed for

ITA 304/ASR/2019[2013-14]Status: DisposedITAT Amritsar30 Oct 2023AY 2013-14

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

For Appellant: Sh. Ashwani Kalia, CAFor Respondent: Sh. Rajiv Wadhera, Sr. DR

Section 143(3)Section 145(3)Section 147Section 148Section 151Section 271(1)(c)Section 282

impounded books that net profit worked out was Rs. 1,41,85,726/- and if market fees of Rs 57,91,898/-and advanced tax paid of Rs. 72,736/- is reduced for the reason that these were wrongly credited, the profit still remains ... find that a similar argument was taken before the Assessing Officer who has in consideration of the contention allowed benefit of market fee and advance tax. The other contentions of the appellant are fallacious because entries in the nature of expenses appear both on the credit side and also

Measage. Surinder Sat Agro Foods, Jalalabad vs. Deputy Commissioner of Income Tax-Circle-II, Bathinda

In the result, the three appeals of the assessee are allowed for

ITA 303/ASR/2019[2010-11]Status: DisposedITAT Amritsar30 Oct 2023AY 2010-11

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

For Appellant: Sh. Ashwani Kalia, CAFor Respondent: Sh. Rajiv Wadhera, Sr. DR

Section 143(3)Section 145(3)Section 147Section 148Section 151Section 271(1)(c)Section 282

M/S Surinder Sat Agro Foods, Jalalabad vs. The Asstt. Commissioner of Income Tax, Bathinda

In the result, the three appeals of the assessee are allowed for

ITA 214/ASR/2017[2013-14]Status: DisposedITAT Amritsar30 Oct 2023AY 2013-14

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

For Appellant: Sh. Ashwani Kalia, CAFor Respondent: Sh. Rajiv Wadhera, Sr. DR

Section 143(3)Section 145(3)Section 147Section 148Section 151Section 271(1)(c)Section 282

Rubeena Shahin Khan, Jabalpur vs. Income Tax Officer, Ward 1(3), Jabalpur

ITA 116/JAB/2023[2011-12]Status: DisposedITAT Jabalpur19 Oct 2023AY 2011-12

Bench: Shri Om Prakash Kant & Shri Pavan Kumar Gadalerubeena Shahin Khan Vs. Ito, Ward1(3), 655, Chotu Miyan Ki Annexure Bldg, Talaiya, Khatek Mohlla, Aayakar Bhawan, Lokman Tilak Ward, Napier Town, Jabalpur-482001, Near Russel Chock, Madhyapradesh. Jabalpur-482001, Madhyapradesh. Pan/Gir No. : Awspk5404A Appellant .. Respondent Appellant By : Shri.Poonam Chand Jain.Adv.Ar Respondentby : Shri.Shiv Kumar.Sr.Dr Date Of Hearing 22.09.2023 Date Of Pronouncement 09.10.2023 आदेश / O R D E R Per Pavan Kumar Gadale Jm: The Assessee Has Filed The Appeal Against The Order Of The National Faceless Appeal Centre (Nfac) /Cit (A) Passed U/Sec144 R.W.S 147 & U/Sec 250 Of The Act. The Assessee Has Raised The Following Grounds Of Appeal:

For Appellant: Shri.Poonam Chand Jain.Adv.ARFor Respondent: Shri.Shiv Kumar.Sr.DR

Section 144Section 147Section 148Section 208Section 234ASection 234BSection 69

circumstance of the case the Ld. A.O. was not justified in charging the interest u/s 234B and 234C while the liability payment of advance tax not attracted in the instant case as per the provision of section 208. The amount of interest so charged should be deleted. 16. That

Rajesh Agrawal, Raipur vs. Deputy Commissioner of Income Tax, Raipur-1(1), Raipur

In the result, the appeal of the assessee is allowed in terms of our aforesaid observations

ITA 249/RPR/2022[2010-11]Status: DisposedITAT Raipur19 Oct 2023AY 2010-11

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita No.249/Rpr/2022 "नधा"रण वष" / Assessment Year : 2010-11 Rajesh Agrawal C/O. M/S. Chhattisgarh Steel Traders, 15/343, Main Road, Jawahar Nagar, Raipur (C.G.)-492 001. Pan : Acppa2905F .......अपीलाथ" / Appellant बनाम / V/S. The Deputy Commissioner Of Income Tax, Raipur-1(1), Raipur (C.G.) ……""यथ" / Respondent

For Appellant: Shri Ravi Agrawal, CAFor Respondent: Shri Satya Prakash Sharma, Sr. DR

Section 143(2)Section 143(3)Section 36(1)(iii)

High Court had come to the conclusion that the profits were 14 Rajesh Agrawal Vs. DCIT, Raipur-1(1), Raipur sufficient to meet the advance tax liability and the profits were deposited in the over draft account of the assessee and in such a case it should be presumed that

Ashok Kumar, Raipur vs. Income Tax Officer, Ward-4(1), Raipur

In the result the appeal filed by the assessee is partly allowed, in terms of our observations

ITA 296/RPR/2023[2017-18]Status: DisposedITAT Raipur18 Oct 2023AY 2017-18

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अपील सं./Ita No: Ita296/Rpr/2023 (Assessment Years: 2017-18) Ashok Kumar, V Income Tax Officer- Ward 4(1), B-11, Pink City, Gayatri Nagar, S Central Revenue Building, Civil Lines, Raipur, 492007 (C.G.) Near Akashwani, Raipur (C.G.) Pan: Bgnpk9988H (अपीलाथ"/Applicant) (""यथ" / Respondent) .. िनधा"रतीक"ओरसे /Assessee By : Shri Prafulla Pendse, Ca राज"वक"ओरसे /Revenue By : Shri Satya Prakash Sharma, Sr. Dr सुनवाईक"तार"ख/ Date Of Hearing : 13-10-2023 घोषणाक"तार"ख/Date Of Pronouncement : 18-10- 2023 आदेश / O R D E R Per Arun Khodpia, Am:

For Appellant: Shri Prafulla Pendse, CAFor Respondent: Shri Satya Prakash Sharma, Sr. DR

Section 115BSection 133(6)Section 147Section 194CSection 249Section 250Section 69

were not paid 2 when the fact remains that appellant did not have any taxable income so as to oblige him to pay either advance tax or file return of income, as such the provisions of section 249(b) were not applicable to the appellant. 4. That the invocation

Chandhok Cold Storage Pvt. Ltd., Raipur vs. Income Tax Officer, Ward-3(1), Raipur

In the result, the appeal of the assessee is partly allowed for statistical purposes in terms of the aforesaid observations

ITA 200/RPR/2023[2013-14]Status: DisposedITAT Raipur18 Oct 2023AY 2013-14

Bench: Shri Ravish Soodआयकर अपील सं. / Ita No. 200/Rpr/2023 "नधा"रण वष" / Assessment Year : 2013-14 Chandhok Cold Storage Private Limited Ph No.100/28, Bilaspur Road, Ravigram S.O, Raipur-492 001 Pan : Aadcc8354P .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer, Ward-3(1), Raipur (C.G.) ……""यथ" / Respondent

For Appellant: Shri Hardik Jain, CAFor Respondent: Shri Satya Prakash Sharma, Sr. DR

Section 143(3)Section 224Section 56Section 56(2)(viib)

value of the assets in the balance-sheet as reduced by any amount of tax paid as deduction or collection at source or as advance tax payment as reduced by the amount of tax claimed as refund under the Income-tax Act and any amount shown in the balance-sheet ... apart towards depreciation; (iv) any amount representing provision for taxation, other than amount of tax paid as deduction or collection at source or as advance tax payment as reduced by the amount of tax claimed as refund under the Income-tax Act, to the extent of the excess over

Mahanadi Coalfields Ltd., Burla, Sambalpur vs. DCIT Circle2(1), Sambalpur

In the result, appeal filed by the revenue being ITA No

ITA 41/CTK/2023[2020-21]Status: DisposedITAT Cuttack17 Oct 2023AY 2020-21

Bench: Shri George Mathan & Shri Girish Agrawalआयकर अऩीऱ सं/Ita Nos.14 To 17/Ctk/2023 & आयकर अऩीऱ सं/Ita No.41/Ctk/2023 (ननधाारण वषा / Assessment Years : 2016-2017 To 2020-2021) Mahanadi Coalfields Limited, Vs Acit/Dcit, Circle-2(1), Sambalpur Jagriti Vihar, Burla, Sambalpur-768020 Pan No. :Aabcm 5188 P & आयकर अऩीऱ सं/Ita Nos.70 To 73/Ctk/2023 & आयकर अऩीऱ सं/Ita No.147/Ctk/2023 (ननधाारण वषा / Assessment Years : 2016-2017 To 2020-2021) Acit/Dcit, Circle-2(1), Sambalpur Vs Mahanadi Coalfields Limited, Jagriti Vihar, Burla, Sambalpur-768020 Pan No. :Aabcm 5188 P & आयकर अऩीऱ सं/Ita No.69/Ctk/2023 (ननधाारण वषा / Assessment Year : 2015-2016) Acit/Dcit, Circle-2(1), Sambalpur Vs Mahanadi Coalfields Limited, Jagriti Vihar, Burla, Sambalpur-768020 Pan No. :Aabcm 5188 P (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) .. ननधााररती की ओर से /Assessee By : Shri S.S.Poddar, Ca राजस्व की ओर से /Revenue By : Dr. Abani Kanta Nayak, Cit-Dr सुनवाई की तारीख / Date Of Hearing : 17/10/2023 घोषणा की तारीख/Date Of Pronouncement : 17/10/2023 आदेश / O R D E R Per Bench :

For Appellant: Shri S.S.Poddar, CAFor Respondent: Dr. Abani Kanta Nayak, CIT-DR

Section 271(1)(c)

assessment year 2017-2018 is dismissed as not pressed. 22. The next issue in regard to the short credit of advance tax of Rs.1255 crores and TDS, which is raised in Ground No.4 in the appeal of the assessee for A.Y.2016-2017. 23. It was the submission that ... wish to press this ground as the assessee has already got the benefit of the full credit in the advance tax. Thus, this issue is dismissed as not pressed. 24. The next issue is in regard to the penalty proceedings, which is raised by the assessee in Ground No.5

Mahanadi Coalfields Ltd., Burla, Sambalpur vs. DCIT Circle2(1), Sambalpur

In the result, appeal filed by the revenue being ITA No

ITA 14/CTK/2023[2016-17]Status: DisposedITAT Cuttack17 Oct 2023AY 2016-17

For Appellant: Shri S.S.Poddar, CAFor Respondent: Dr. Abani Kanta Nayak, CIT-DR

Section 271(1)(c)

Flemingo Dutyfree Shop Pvt Ltd, Mumbai vs. DCIT, Cen-Cir-8(4), Mumbai

In the result, the appeal of the assessee is dismissed

ITA 2218/MUM/2023[2016-2017]Status: DisposedITAT Mumbai16 Oct 2023AY 2016-2017

Bench: Shri Aby T Varkey & Shri Amarjit Singhflemingo Dutyfree Shop Vs. Dcit, Central Circle-8(4) Private Limited, 6Th Floor, Aayakar D-73/1 Ttc D-73/1 Ttc Bhavan, M.K. Road, Industrial Area, New Marine Lines, Midc Turbhe, Churchgate, Navi Mumbai – 400705 Mumbai – 400 020 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No:Aaacf7909E Appellant .. Respondent [ Appellant By : J.P. Baragra Respondent By : Ujjawal Kumar Chavan Date Of Hearing 26.09.2023 Date Of Pronouncement 16.10.2023

For Appellant: J.P. BaragraFor Respondent: Ujjawal Kumar Chavan

Section 143(2)Section 201Section 37(1)

assessee's business. The court held that (headnote) : "When interest is paid for committing a default in respect of the statutory liability to pay advance tax, the amount paid and the expenditure incurred in that connection is not in any way connected with preserving or promoting the business ... Shop Pvt. Ltd. Vs. DCIT, CC-8(4) the case of payment of income-tax and interest for delayed payment of income-tax or advance tax arises on the computation of the profits and gains of business". The court further held that (headnote) : "Under the Income-tax Act, the payment

DCIT, Cir-3(3)(1), Mumbai vs. Sicom Limited, Mumbai City

In the result, the appeal filed by the revenue is dismissed

ITA 2034/MUM/2023[1999-2000]Status: DisposedITAT Mumbai16 Oct 2023AY 1999-2000

Bench: Shri Pavan Kumar Gadale & Shri Gagan Goyalita Nos. 2034 & 2035/Mum/2023 (A.Y:1999-2000 &1998-99) Dcit, Circle-3(3)(1), Vs. M/S Sicom Limited, Room No.609, Solitaire Corporate Aayakar Bhavan, Park, Building No.4, M.K. Road, Guru Nanak Marg, Mumbai-400020. Chakala, Midc S.O, Mumbai-400093. Pan/Gir No. : Aaacs5524J Appellant .. Respondent

Section 143(3)Section 21Section 244ASection 244A(1)

where the refund is out of any tax paid under section 115WJ or collected at source under section 206C or paid by way of advance tax or treated as paid under section 199, during the financial year immediately preceding the (a) assessment year, such interest shall be calculated

Amadeus It Group Sa, Spain vs. ACIT, Circle-1(1)(1) Int.Taxation, New Delhi

In the result, for statistical purposes, the appeal of the assessee is partly allowed

ITA 1742/DEL/2023[2020-21]Status: DisposedITAT Delhi16 Oct 2023AY 2020-21

Bench: Shri G.S. Pannu, Hon’Ble & Ms. Astha Chandraasstt. Year: 2020-21

For Appellant: Sh. Neeraj Jain &For Respondent: Shri Vizay B. Vasanta, CIT-DR

Section 143(3)

relevant finding / observation of the Tribunal in its decision(s) (supra) and submitted that in the absence of any liability for payment of advance tax since tax is deductible at source on the income of the assessee held liable to tax in India, the levy of interest under section 234B ... could not have been made: “33. Ld. AR for the tax payer contended that in the absence of any liability for payment of advance tax since tax is deductible at source of the income of the taxpayer held liable to tax in India, the levy of interest u/s 234B

Sarita, Ghaziabad vs. ITO, Ward- 2(2)(4), Ghaizabad

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 2544/DEL/2022[2012-13]Status: DisposedITAT Delhi16 Oct 2023AY 2012-13

Bench: Shri Kul Bharat & Shri M.Balaganesh[Assessment Year : 2012-13] Sarita, Vs Ito, H.No.25, Strt Mohalla, Asalat Ward-2(2)(4), Naar, Pargana, Jalalabad Police Ghaziabad. Station, Muradnagar, Ghaziabad, Uttar Pradesh-201006. Pan-Dwpps6599A Appellant Respondent Appellant By Shri Dinesh Kumar, Adv. Respondent By Shri Anuj Garg, Sr. Dr Date Of Hearing 16.10.2023 Date Of Pronouncement 16.10.2023

Section 144Section 147Section 148Section 249(4)(b)

dated on 24/08/2022. Hence the present appeal is filed before your goodself against CIT order. That there was no income of assessee hence no advance tax was payable against her hence appeal cannot dismissed on this ground at admission The counsel could not filed reply/compliance because notice of hearing

Sara International Pvt.Ltd, New Delhi vs. Add. CIT, Range-22, New Delhi

In the result, the appeal of the assessee is partly allowed for

ITA 3307/DEL/2019[2014-15]Status: DisposedITAT Delhi13 Oct 2023AY 2014-15

Bench: SHRI M. BALAGANESH (Accountant Member), SHRI ANUBHAV SHARMA (Judicial Member)

Section 143(3)Section 14A

have gone through the decision of the Hon’ble Supreme Court. In that case, the assessee had offered certain income and paid advance tax and TDS in the return of income. The assessment Page 6 of 16 ITA Nos.3307 & 1974/Del/2019 Sara International Pvt. Ltd. vs. Addl. CIT / JCIT was framed ... Assessing Officer. Subsequently, that assessment was declared as void ab initio. Thereafter, the assessee sought refund of the advance tax and TDS paid by him along with return of income. The Hon’ble Supreme Court interfered and said that when an assessment made by the Assessing Officer is nullified

JCIT, Circle-22(1), New Delhi vs. Sara International Pvt.Ltd, New Delhi

In the result, the appeal of the assessee is partly allowed for

ITA 1974/DEL/2019[2014-15]Status: DisposedITAT Delhi13 Oct 2023AY 2014-15

Bench: SHRI M. BALAGANESH (Accountant Member), SHRI ANUBHAV SHARMA (Judicial Member)

Section 143(3)Section 14A

Commissioner, Cuttack Municipal Corporation, Cuttack vs. ITO(TDS), Cuttack

In the result, appeal of the assessee is allowed

ITA 83/CTK/2020[2014-15]Status: DisposedITAT Cuttack12 Oct 2023AY 2014-15

Bench: Shri George Mathan & Shri Rajesh Kumarआयकर अऩीऱ सं/Ita No.83/Ctk/2020 (ननधाारण वषा / Assessment Year : 2014-2015) Commissioner, Vs Ito (Tds), Cuttack Cuttack Municipal Corporation, Choudhury Bazar, Dist: Cuttack Tan No. :Bbnc 00195 G (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) .. ननधााररती की ओर से /Assessee By : Shri P.K.Mishra & Sanjeev Swain, Advs राजस्व की ओर से /Revenue By : Shri Charan Dass, Sr. Dr सुनवाई की तारीख / Date Of Hearing : 12/10/2023 घोषणा की तारीख/Date Of Pronouncement : 12/10/2023 आदेश / O R D E R Per Bench : This Is An Appeal Filed By The Assessee Against The Order Of The Ld. Cit(A), Cuttack, Dated 31.10.2019, Passed In I.T.Appeal No.0398/2015- 16 For The Assessment Year 2014-2015. 2. The Appeal Of The Assessee Is Delayed By 25 Days For Which The Assessee Has Filed Necessary Application For Condonation Of Delay & The Affidavit. The Reason For Delay Is Mentioned To Be On Account Of Urinary Infection & High Blood Pressure & The Consequential Medical Treatment. The Affidavit Filed By The Assessee Has Not Been Controverted By The Revenue. Consequently, The Delay In Filing The Present Appeal Is Condoned & The Appeal Is Disposed Off On Merits. 3. It Was Submitted By The Ld. Ar That The Issue In The Appeal Was Against Holding The Assessee As An Assessee In Default For Non-Deduction

For Appellant: Shri P.K.Mishra & Sanjeev Swain, AdvsFor Respondent: Shri Charan Dass, Sr. DR

Section 194CSection 201Section 201(1)

levy any interest under section 201(1A) of the Act, especially when the contractor had paid more amount of tax by way of advance tax than what was payable by it. It was the submission that the levy as raised on the assessee u/s.201 & 201(1A) is liable

Million Traders Bhopal P Ltd, Bhopal vs. The ACIT, CPC, Bengaluru

In the result, the appeal of assessee is allowed for statistical purposes

ITA 125/IND/2023[2018-19]Status: DisposedITAT Indore12 Oct 2023AY 2018-19

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

Section 143(1)Section 234B

individual license holders then the Page 5 of 24 ITA No.124/Ind/2023 & ITANo.35/Ind/2023 Million Trader Bhopal Page 6 of 24 credit of advance tax collected from the transactions of purchase has to be allowed in the hands of the company which is the actual purchaser/buyer and also offering the income from

Million Traders Bhopal P Ltd, Bhopal vs. The ACIT, CPC, Bengaluru

In the result, the appeal of assessee is allowed for statistical purposes

ITA 124/IND/2023[2017-18]Status: DisposedITAT Indore12 Oct 2023AY 2017-18

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

Section 143(1)Section 234B

M/S. Linklaters, Mumbai vs. The DDIT (It) 4(1), Mumbai

In the result, appeal filed by the revenue is dismissed

ITA 3280/MUM/2008[2005-2006]Status: DisposedITAT Mumbai11 Oct 2023AY 2005-2006

Bench: Shri Aby T. Varkey, Hon'Ble & Shri S. Rifaur Rahman, Hon'Blelinklaters V. Ddit (International Taxation) – 4(1) Scindia House, N.M. Road C/O. Deloitte Haskins & Sells Llp Bellard Estate, Mumbai - 400001 Indiabulls Finance Centre Tower 3 28Th Floor, Senapati Bapat Marg Elphinstone Road (West) Mumbai - 400013 Pan: Aabfl2160M (Appellant) (Respondent) Ddit (International Taxation) – 4(1) V. Linklaters Scindia House, N.M. Road C/O. Deloitte Haskins & Sells Llp Bellard Estate, Mumbai - 400001 Indiabulls Finance Centre Tower 3 28Th Floor, Senapati Bapat Marg Elphinstone Road (West) Mumbai - 400013 Pan: Aabfl2160M (Appellant) (Respondent)

Section 143(3)Section 244ASection 44C

234B of the Act was deleted by the Ld CIT(A) by holding that the assessee is not liable to pay advance tax, since the Tax is deductible at source on the entire amount received by the assessee. The Ld D.R placed reliance on the decision rendered

DDIT (It)-4(1), Mumbai vs. M/S. Linklaters, Mumbai

In the result, appeal filed by the revenue is dismissed

ITA 3039/MUM/2008[2005-2006]Status: DisposedITAT Mumbai11 Oct 2023AY 2005-2006

Section 143(3)Section 244ASection 44C