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“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

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

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

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

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

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

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

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

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

DCIT 5(1)(1), Mumbai vs. Air India Ltd, Mumbai

In the result, the appeals filed by the assessee are partly allowed for statistical purposes and the appeals filed by the revenue are dismissed

ITA 4485/MUM/2018[2011-12]Status: DisposedITAT Mumbai07 Dec 2022AY 2011-12

Bench: Shri Baskaran Br, Accountat Member & Shri Pavan Kumar Gadaleita No. 4467, 4518 & 4544/Mum/2018 (A.Y: 2010-11, 2011-12 & 2012-13)

For Appellant: Shri Madhur Agrawal.ARFor Respondent: Smt Sailaja Rai, CIT DR

Section 143(2)Section 14ASection 250Section 44A

Supra). The relevant extract of the judgment reads as under : FACTS During the year under consideration, the assessee failed to pay advance tax equivalent to 75 per cent of estimated tax. The Assessing Officer levied interest under section 215 as well as under section 139. The assessee claimed that since ... view. On appeal to the Supreme Court : HELD When interest is paid for committing a default in respect of a statutory liability to pay advance tax, the amount paid and the expenditure incurred in that connection is in no way connected with preserving or promoting the business of the assessee

M/S. Lupin Investments Pvt. Ltd (As A Sucessor to Novamed Investments Pvt. Ltd), Mumbai vs. Assistant Commisssioner of Income Tax, Circle 14(1) (1), Mumbai

In the result, the appeal filed by the assessee is allowed

ITA 1812/MUM/2022[2016-17]Status: DisposedITAT Mumbai30 Nov 2022AY 2016-17

Bench: Shri Baskaran Br, Accountat Member & Shri Pavan Kumar Gadalem/S. Lupin Investments Vs. Acit, Circle – 14(1)(1) Pvt Ltd (Successor To Mumbai. Novamed Investments Pvt Ltd.,) 159, Cst Road, Kalina, Santacruz (E), Mumbai – 400098. "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaacl1070G Appellant .. Respondent Appellant By : Shri Rajan Vora & Shri Hemen Chandaria.Ar Respondent By : Shri Manoj Sinha.Dr Date Of Hearing 10.10.2022 Date Of Pronouncement 30.11.2022 आदेश / O R D E R Per Pavan Kumar Gadale, Jm: The Assessee Has Filed The Appeal Against The Order Of National Faceless Appeal Centre (Nfac), Delhi / Cit(A) Passed U/S 250 Of The Act. The Assessee Has Raised Following Grounds Of Appeal:

For Appellant: Shri Rajan Vora &For Respondent: Shri Manoj Sinha.DR

Section 143(1)Section 143(1)(a)Section 154Section 234BSection 234CSection 250Section 35ASection 80G

computed under clause (b) by any M/s. Lupin Investments Pvt Ltd., Mumbai. tax deducted at source, any tax collected at source, any advance tax paid, any relief allowable under an agreement under section 90 of section GOA, or any relief allowable under section 91, any rebate allowable under Part

ACIT CC-43, Mumbai vs. Roha Dyechem P. Ltd, Mumbai

In the result, all the appeals of the assessee and revenue except ITA No

ITA 4295/MUM/2009[2007-08]Status: DisposedITAT Mumbai30 Nov 2022AY 2007-08

Bench: Shri Kuldip Singh () & Shri Om Prakash Kant () Assessment Year: 2004-05 Acit Cen Ci-43 Rohadyechem Pvt Ltd., 6Th Floor, R.No. 659, Aayakar Survoday Mill Compund, Bhavan, M.K.Rd. Vs. M.P. Mills, Tardeo, Mumbai 400 020 Mumbai-400 034 Pan No. Aaacr 4974P Appellant Respondent

Section 143Section 143(3)Section 153ASection 80HSection 80ISection 92C

basis of the return of income and not on the assessedincome. The assessee contended that in absence of any shortfall in payment of advance tax installments after taking into consideration the returnedincome, no interest is chargeable under section 234C ... relevant material on record. On plane reading of the section 234C of the Act during relevant period, it is evident that short fall in advance tax is to be calculated taking into consideration returned income, which has been defined in Explanation-1 below the section. Accordingly, we restore this issue

ACIT CC-43, Mumbai vs. Roha Dyechem P. Ltd, Mumbai

In the result, all the appeals of the assessee and revenue except ITA No

ITA 4294/MUM/2009[2004-05]Status: DisposedITAT Mumbai30 Nov 2022AY 2004-05

Bench: Shri Kuldip Singh () & Shri Om Prakash Kant () Assessment Year: 2004-05 Acit Cen Ci-43 Rohadyechem Pvt Ltd., 6Th Floor, R.No. 659, Aayakar Survoday Mill Compund, Bhavan, M.K.Rd. Vs. M.P. Mills, Tardeo, Mumbai 400 020 Mumbai-400 034 Pan No. Aaacr 4974P Appellant Respondent

Section 143Section 143(3)Section 153ASection 80HSection 80ISection 92C

basis of the return of income and not on the assessedincome. The assessee contended that in absence of any shortfall in payment of advance tax installments after taking into consideration the returnedincome, no interest is chargeable under section 234C ... relevant material on record. On plane reading of the section 234C of the Act during relevant period, it is evident that short fall in advance tax is to be calculated taking into consideration returned income, which has been defined in Explanation-1 below the section. Accordingly, we restore this issue

ACIT CC-43, Mumbai vs. Roha Dyechem P. Ltd, Mumbai

In the result, all the appeals of the assessee and revenue except ITA No

ITA 4293/MUM/2009[2002-03]Status: DisposedITAT Mumbai30 Nov 2022AY 2002-03

Bench: Shri Kuldip Singh () & Shri Om Prakash Kant () Assessment Year: 2004-05 Acit Cen Ci-43 Rohadyechem Pvt Ltd., 6Th Floor, R.No. 659, Aayakar Survoday Mill Compund, Bhavan, M.K.Rd. Vs. M.P. Mills, Tardeo, Mumbai 400 020 Mumbai-400 034 Pan No. Aaacr 4974P Appellant Respondent

Section 143Section 143(3)Section 153ASection 80HSection 80ISection 92C

basis of the return of income and not on the assessedincome. The assessee contended that in absence of any shortfall in payment of advance tax installments after taking into consideration the returnedincome, no interest is chargeable under section 234C ... relevant material on record. On plane reading of the section 234C of the Act during relevant period, it is evident that short fall in advance tax is to be calculated taking into consideration returned income, which has been defined in Explanation-1 below the section. Accordingly, we restore this issue

Roha Dyechem P. Ltd, Mumbai vs. ACIT Cen Cir 43, Mumbai

In the result, all the appeals of the assessee and revenue except ITA No

ITA 2863/MUM/2009[2007-08]Status: DisposedITAT Mumbai30 Nov 2022AY 2007-08

Bench: Shri Kuldip Singh () & Shri Om Prakash Kant () Assessment Year: 2004-05 Acit Cen Ci-43 Rohadyechem Pvt Ltd., 6Th Floor, R.No. 659, Aayakar Survoday Mill Compund, Bhavan, M.K.Rd. Vs. M.P. Mills, Tardeo, Mumbai 400 020 Mumbai-400 034 Pan No. Aaacr 4974P Appellant Respondent

Section 143Section 143(3)Section 153ASection 80HSection 80ISection 92C

basis of the return of income and not on the assessedincome. The assessee contended that in absence of any shortfall in payment of advance tax installments after taking into consideration the returnedincome, no interest is chargeable under section 234C ... relevant material on record. On plane reading of the section 234C of the Act during relevant period, it is evident that short fall in advance tax is to be calculated taking into consideration returned income, which has been defined in Explanation-1 below the section. Accordingly, we restore this issue

Roha Dyechem Pvt.Ltd., Mumbai vs. ACIT-Central Circle 43, Mumbai

In the result, all the appeals of the assessee and revenue except ITA No

ITA 2862/MUM/2009[2006-07]Status: DisposedITAT Mumbai30 Nov 2022AY 2006-07

Bench: Shri Kuldip Singh () & Shri Om Prakash Kant () Assessment Year: 2004-05 Acit Cen Ci-43 Rohadyechem Pvt Ltd., 6Th Floor, R.No. 659, Aayakar Survoday Mill Compund, Bhavan, M.K.Rd. Vs. M.P. Mills, Tardeo, Mumbai 400 020 Mumbai-400 034 Pan No. Aaacr 4974P Appellant Respondent

Section 143Section 143(3)Section 153ASection 80HSection 80ISection 92C

basis of the return of income and not on the assessedincome. The assessee contended that in absence of any shortfall in payment of advance tax installments after taking into consideration the returnedincome, no interest is chargeable under section 234C ... relevant material on record. On plane reading of the section 234C of the Act during relevant period, it is evident that short fall in advance tax is to be calculated taking into consideration returned income, which has been defined in Explanation-1 below the section. Accordingly, we restore this issue

Roha Dyechem Pvt.Ltd., Mumbai vs. ACIT-Central Circle 43, Mumbai

In the result, all the appeals of the assessee and revenue except ITA No

ITA 2860/MUM/2009[2004-05]Status: DisposedITAT Mumbai30 Nov 2022AY 2004-05

Bench: Shri Kuldip Singh () & Shri Om Prakash Kant () Assessment Year: 2004-05 Acit Cen Ci-43 Rohadyechem Pvt Ltd., 6Th Floor, R.No. 659, Aayakar Survoday Mill Compund, Bhavan, M.K.Rd. Vs. M.P. Mills, Tardeo, Mumbai 400 020 Mumbai-400 034 Pan No. Aaacr 4974P Appellant Respondent

Section 143Section 143(3)Section 153ASection 80HSection 80ISection 92C

basis of the return of income and not on the assessedincome. The assessee contended that in absence of any shortfall in payment of advance tax installments after taking into consideration the returnedincome, no interest is chargeable under section 234C ... relevant material on record. On plane reading of the section 234C of the Act during relevant period, it is evident that short fall in advance tax is to be calculated taking into consideration returned income, which has been defined in Explanation-1 below the section. Accordingly, we restore this issue

Roha Dyechem P. Ltd, Mumbai vs. ACIT Cen Cir 43, Mumbai

In the result, all the appeals of the assessee and revenue except ITA No

ITA 2859/MUM/2009[2002-03]Status: DisposedITAT Mumbai30 Nov 2022AY 2002-03

Bench: Shri Kuldip Singh () & Shri Om Prakash Kant () Assessment Year: 2004-05 Acit Cen Ci-43 Rohadyechem Pvt Ltd., 6Th Floor, R.No. 659, Aayakar Survoday Mill Compund, Bhavan, M.K.Rd. Vs. M.P. Mills, Tardeo, Mumbai 400 020 Mumbai-400 034 Pan No. Aaacr 4974P Appellant Respondent

Section 143Section 143(3)Section 153ASection 80HSection 80ISection 92C

basis of the return of income and not on the assessedincome. The assessee contended that in absence of any shortfall in payment of advance tax installments after taking into consideration the returnedincome, no interest is chargeable under section 234C ... relevant material on record. On plane reading of the section 234C of the Act during relevant period, it is evident that short fall in advance tax is to be calculated taking into consideration returned income, which has been defined in Explanation-1 below the section. Accordingly, we restore this issue

ACIT Cen Ci-43 vs. Roha Dyechem P. Ltd, Mumbai

In the result, all the appeals of the assessee and revenue except ITA No

ITA 10/MUM/2009[2004-2005]Status: DisposedITAT Mumbai30 Nov 2022AY 2004-2005

Bench: Shri Kuldip Singh () & Shri Om Prakash Kant () Assessment Year: 2004-05 Acit Cen Ci-43 Rohadyechem Pvt Ltd., 6Th Floor, R.No. 659, Aayakar Survoday Mill Compund, Bhavan, M.K.Rd. Vs. M.P. Mills, Tardeo, Mumbai 400 020 Mumbai-400 034 Pan No. Aaacr 4974P Appellant Respondent

Section 143Section 143(3)Section 153ASection 80HSection 80ISection 92C

basis of the return of income and not on the assessedincome. The assessee contended that in absence of any shortfall in payment of advance tax installments after taking into consideration the returnedincome, no interest is chargeable under section 234C ... relevant material on record. On plane reading of the section 234C of the Act during relevant period, it is evident that short fall in advance tax is to be calculated taking into consideration returned income, which has been defined in Explanation-1 below the section. Accordingly, we restore this issue

Mindteck (India) Limited, Bangalore vs. Deputy Commissioner of Income Tax, Circle-4(1)(1), Bangalore

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

ITA 211/BANG/2022[2017-18]Status: DisposedITAT Bangalore30 Nov 2022AY 2017-18

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Padam Chand Khincha, A.RFor Respondent: Shri K. Sankar Ganesh, D.R

declaring a total income of Rs.9,25,46,830. The tax liability of Rs 3,05,98,758, was discharged by TDS and advance tax aggregating to Rs. 5,67,94,546, resulting in refund of Rs. 2,61,95,790. 2.4 The aforesaid revised return was picked

M/S Infosys Limited, Bangalore vs. The Deputy Commissioner of Income Tax, Circle-3(1)(1), Bangalore

In the result, the appeal filed by the assessee stands partly allowed

ITA 718/BANG/2017[2012-13]Status: DisposedITAT Bangalore28 Nov 2022AY 2012-13

Bench: Shri Chandra Poojaria & Smt. Beena Pillaiassessment Appeal No. Appellant Respondent Year M/S. Infosys Ltd., The Assistant Electronic City, Commissioner It(Tp)A No. Hosur Road, Of Income Tax, 2012-13 718/Bang/2017 Bangalore – 560 Circle – 100. 3(1)(1), Pan: Bangalore. Aaaci4798L : Shri Padamchand Khincha, Assessee By Ca : Shri K.V. Arvind & Shri Dilip, Revenue By Standing Counsels For Dept. Date Of Hearing : 15-09-2022 Date Of Pronouncement : 28-11-2022 Order Per Beena Pillaipresent Appeal Arises Out Of Final Assessment Order Dated 28/02/2017 Passed By The Ld.Acit, Circle – 3(1)(1), Bangalore For A.Y. 2012-13 On Following Grounds Of Appeal: General & Legal Grounds 1. The Order Passed By The Learned Assessing Officer & The Directions Of Hon’Ble Drp To The Extent Prejudicial To The Appellant Is Bad In Law & Liable To Be Quashed. Grounds On Denial Of Deduction Claimed Under Section 10Aa In Respect Of 4 Sez Units Viz., Chennai – Unit 1, Chandigarh, Mangalore - Unit 1 & Pune Unit 1 2. The Learned Assessing Officer Has Erred In Denying Deduction Claimed Under Section 10Aa In The Return Of Income Totally Amounting To Rs. 2227,82,65,630 In Respect

Section 10ASection 14ASection 2Section 2(24)Section 40

applicable, TDS credit should be fully allowed to the extent of Rs.223,20,83,172 as claimed during the assessment. TDS credit and advance tax relating to ICIL not allowed even though it was allowed in the Draft assessment order 53. The learned AO has erred in not allowing ... credit and advance tax relating to Infosys Consulting India Ltd merged with the appellant amounting to Rs.27,73,096 and Rs.75,00,000 even though the same was allowed in the draft assessment order. Grounds on allowability of incremental foreign tax credit which was allowed in the Draft assessment order

M/S. Praxair India Private Limited, Bengaluru vs. Deputy Commissioner of Income Tax, Circle-3(1)(1), Bangalore

In the result, both the appeals of the assessee in IT(TP)A No

ITA 199/BANG/2021[2015-16]Status: DisposedITAT Bangalore22 Nov 2022AY 2015-16

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri T. Suryanarayana, Senior A.RFor Respondent: Shri K. Sankar Ganesh, D.R

Section 143Section 143(3)Section 92C

tax deducted at source of INR 58,175,493 instead of INR 60,847,909 as claimed by the Appellant. 15. Short credit of advance tax The learned AO erred in giving credit of advance tax of INR 9,50,00,000 instead

M/S Praxair India Private Limited, Bangalore vs. Assistant Commissioner of Income Tax Circle-2, Bangalore

In the result, both the appeals of the assessee in IT(TP)A No

ITA 3336/BANG/2018[2014-15]Status: DisposedITAT Bangalore22 Nov 2022AY 2014-15

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri T. Suryanarayana, Senior A.RFor Respondent: Shri K. Sankar Ganesh, D.R

Section 143Section 143(3)Section 92C

tax deducted at source of INR 58,175,493 instead of INR 60,847,909 as claimed by the Appellant. 15. Short credit of advance tax The learned AO erred in giving credit of advance tax of INR 9,50,00,000 instead

M/S. Kopran Ltd, Mumbai vs. DCIT -7(1), Mumbai

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

ITA 501/MUM/2022[2014-15]Status: DisposedITAT Mumbai21 Nov 2022AY 2014-15

Bench: Shri Prashant Maharishi, Am & Shrisandeep Singh Karhail, Jm M/S Kopran Ltd. 1St Floor, Parijat House, The Dcit–7(1) 1076, Mumbai Vs. Dr. E Moses Road,Worli, Mumbai-400 018 (Respondent) (Appellant) Pan No. Aaack3202D Assessee By : S/Shri Vijay Mehta & Bhupendra Karkhanis, Ars Revenue By : Shri Tejinder Pal Singh, Dr Date Of Hearing: 23.08.2022 Date Of Pronouncement : 21.11.2022

For Appellant: S/Shri Vijay Mehta &For Respondent: Shri Tejinder Pal Singh, DR

Section 133Section 143Section 68

sheet comprising of Loan & Advances, Debtors and Investments (in shares etc.). These assets will almost match the figures of their Business Creditors. (d) The advance tax payments or self assessment tax payments are NIL despite their Turn Over running in to Several Crores. It clearly reveals the companies are only

Ronak Gems Private Limited, Mumbai vs. Deputy Commissioner of Income Tax, Central Circle 2(4), Mumbai

In the result, appeal of the assessee is allowed

ITA 4604/MUM/2018[2016-17]Status: DisposedITAT Mumbai16 Nov 2022AY 2016-17

Section 139Section 142Section 143Section 143(2)Section 143(3)Section 147Section 148Section 156

tax or interest is found due on the basis of such return, after adjustment of any tax deducted at source, any advance tax paid, any tax paid on self-assessment and any amount paid otherwise by way of tax or interest, then, without prejudice to the provisions of sub-section

M/S. Trishul Buildtech & Infrastructures Pvt. Ltd., Bengaluru vs. The Deputy Commissioner of Income-Tax, Central Circle-2(2), Bengaluru

In the result, assessee’s appeals are partly allowed

ITA 109/BANG/2022[2018-19]Status: DisposedITAT Bangalore14 Nov 2022AY 2018-19

Bench: Shri Chandra Poojari & Shri George George K.

For Appellant: Shri A. Shankar, Senior AdvocateFor Respondent: Shri Manjunath Karkihalli, D.R

ITA Nos.107 to 109/Bang/2022 M/s. Trishul Buildtech & Infrastructures Pvt. Ltd., Bangalore IN THE INCOME TAX APPELLATE TRIBUNAL “B’’ BENCH: BANGALORE

M/S. Trishul Buildtech & Infrastructures Pvt. Ltd., Bengaluru vs. The Deputy Commissioner of Income-Tax, Central Circle-2(2), Bengaluru

In the result, assessee’s appeals are partly allowed

ITA 108/BANG/2022[2017-18]Status: DisposedITAT Bangalore14 Nov 2022AY 2017-18

Bench: Shri Chandra Poojari & Shri George George K.

For Appellant: Shri A. Shankar, Senior AdvocateFor Respondent: Shri Manjunath Karkihalli, D.R

ITA Nos.107 to 109/Bang/2022 M/s. Trishul Buildtech & Infrastructures Pvt. Ltd., Bangalore IN THE INCOME TAX APPELLATE TRIBUNAL “B’’ BENCH: BANGALORE

M/S. Trishul Buildtech & Infrastructures Pvt. Ltd., Bengaluru vs. The Deputy Commissioner of Income-Tax, Central Circle-2(2), Bengaluru

In the result, assessee’s appeals are partly allowed

ITA 107/BANG/2022[2016-17]Status: DisposedITAT Bangalore14 Nov 2022AY 2016-17

Bench: Shri Chandra Poojari & Shri George George K.

For Appellant: Shri A. Shankar, Senior AdvocateFor Respondent: Shri Manjunath Karkihalli, D.R

ITA Nos.107 to 109/Bang/2022 M/s. Trishul Buildtech & Infrastructures Pvt. Ltd., Bangalore IN THE INCOME TAX APPELLATE TRIBUNAL “B’’ BENCH: BANGALORE

M/S Dell International Services India Private Limited, Bangalore vs. Joint Commissioner of Income Tax Ltu, Bangalore

In the result, the appeals of the assessee and the revenue are partly allowed

ITA 932/BANG/2017[2012-13]Status: DisposedITAT Bangalore14 Nov 2022AY 2012-13

Bench: Smt. Beena Pillai & Ms. Padmavathy Sit(Tp)A No.844/Bang/2017 Assessment Year : 2012-13 The Joint Vs. M/S.Dell International Services India Commissioner Of Private Limited, Income Tax, Ltu, (For The Merged Entity Dell India Bangalore. Private Limited), No.12/1, 12/2A, 13/1A, Divyashree Gardens, Challagutta Village, Varthur Hobli, Bangalore – 560 071. Pan : Aaach1925Q Appellant Respondent It(Tp)A No.932/Bang/2017 Assessment Year : 2012-13 M/S.Dell International Services Vs. The Joint Commissioner India Private Limited, Of Income Tax, Ltu, (For The Merged Entity Dell India Bangalore. Private Limited), Bangalore – 560 071. Pan : Aaach1925Q Appellant Respondent Revenue By : Shri Manjunath Karkihalli, Cit(Dr)(Itat), Bengaluru. Assessee By : Shri T. Suryanarayana, Advocate Date Of Hearing : 07.11.2022 Date Of Pronouncement : 14.11.2022

For Appellant: Shri T. Suryanarayana, AdvocateFor Respondent: Shri

Section 143(2)Section 92C

issue to the AO with a direction to examine the additional evidence and allow the claim accordingly. GROUND NO. 12: Credit of TDS and advance tax: 80. It is submitted that the Assessing Officer erred in granting TDS credit only to the extent