“appeal before the tribunal”

AppealsSection 253Section 25316,033 judgments

The decision most relied on for appeal before the tribunal is CIT v. Multiplan India Ltd. (38 ITD 320), cited in 2,267 judgments on BharatTax.

Leading authorities on appeal before the tribunal

CIT v. Multiplan India Ltd.

38 ITD 320 · 1991 · ITAT

2,267

citing judgments

An appeal before the Income Tax Appellate Tribunal can be dismissed for non-prosecution or treated as unadmitted when the appellant fails to appear, cooperate, or show diligence, in accordance with Rule 19(2) of the Income-tax (Appellate Tribunal) Rules. The law aids the vigilant, not those who sleep on their rights.

Estate of Late Tukojirao Holkar v. CWT

223 ITR 480 · 1997 · High Court

2,040

citing judgments

A court or tribunal is not bound to answer a reference or adjudicate an appeal on its merits if the party at whose instance the proceeding is made fails to appear at the hearing or take necessary steps for its proper conduct.

CIT v. Pruthvi Brokers & Shareholders

349 ITR 336 · 2012 · High Court

956

citing judgments

Appellate authorities can entertain fresh claims or revised computations of income made by an assessee, even if these were not submitted through a revised return of income.

National Thermal Power Co. Ltd. v. CIT

389 ITR 326 · 2016 · High Court

241

citing judgments

An appellate authority can admit and adjudicate additional grounds of appeal if they are legal in nature or go to the root of the matter, even if not raised before lower authorities or filed belatedly.

Commissioner of Income Tax Madras v. Chenniyappa Mudiliar

1 SCC 591 · 1985 · Reported

225

citing judgments

The appellate tribunal must render a proper decision on both facts and law, disposing of an appeal on its merits rather than dismissing it solely due to the appellant's absence. This obligation is derived from Section 33(4) of the Income Tax Act, 1922, and reflects principles of natural justice.

Otters Club v. DIT

392 ITR 244 · 2017 · High Court

202

citing judgments

The Bombay High Court did not approve an order being passed by the Tribunal beyond a period of 90 days.

CIT v. Bharat General Reinsurance Co Ltd.

81 ITR 303 · 1971 · High Court

202

citing judgments

Income received by an assessee for services rendered to an Indian company may not be taxable, particularly when the Revenue does not contest its non-taxability. This principle aligns with CBDT Circular No. 14 of 1955, which has been approved by the Supreme Court.

Shivsagar Veg Restaurant v. ACIT

317 ITR 433 · 2009 · High Court

202

citing judgments

Orders that are inordinately delayed are liable to be recalled and heard afresh, and the Appellate Tribunal President should frame guidelines for timely disposal of appeals.

Judgments citing appeal before the tribunal

M/S. Emerson Automation Solutions Intelligent Platforms Private Limited (Formerly M/S Ge Intelligent Platforms Private Limited), Bangalore vs. The Assistant Commissioner of Income Tax Circle-3(1)(2), Bangalore

In the result, grounds 10 and 11 are allowed for statistical purposes

ITA 356/BANG/2018[2013-14]Status: DisposedITAT Bangalore24 May 2022AY 2013-14

Bench: Shri Chandra Poojari, Am & Shri George George K, Jm It(Tp)A No.356/Bang/2018 : Asst.Year 2013-2014 M/S.Emerson Automation The Assistant Commissioner Solutions Intelligent Platforms Of Income-Tax, Circle 3(1)(2) V. Bangalore. Private Limited (Formerly Known As M/S.Ge Intelligent Platforms Private Limited) Velankani Tech Park, Building 9 First Floor, 43 Hosur Road Bangalore 560 100 Pan : Aaacg7573K (Appellant) (Respondent) Appellant By : S/Sri.Sachit Jolly & Aayush Nagpal, Advocates Respondent By : Sri.Sumer Singh Meena, Cit-Dr Date Of Pronouncement : 24.05.2022 Date Of Hearing : 17.05.2022 O R D E R Per George George K, Jm : This Appeal At The Instance Of The Assessee Is Directed Against Final Assessment Order Dated 30.10.2017 Passed U/S 143(3) R.W.S. 144C Of The I.T.Act. The Relevant Assessment Year Is 2013-2014. 2. The Brief Facts Of The Case Are As Follows: The Assessee Is A Company Engaged In The Business Of Process Industrial Automation That Includes Manufacture & Trading Of Automation Products, Solutions & Services For The Process Controlled Application. For The Relevant Assessment Year The Return Of Income Was Filed By The Assessee On 29.11.2013 Declaring Total Loss Of Rs.1,06,46,560. The 2 It(Tp)A No.356/Bang/2018 M/S.Emerson Automation Solutions Intelligent Platforms Pvt.Ltd Assessment Was Selected For Scrutiny By Issuance Of Notice U/S 143(2) Of The I.T.Act. During The Course Of Assessment Proceedings, The Matter Was Referred To The Transfer Pricing Officer (Tpo) To Determine The Arm’S Length Price (Alp) Of The International Transactions Undertaken By The Assessee With Its Associated Enterprises (Aes). The Tpo Vide Order Dated 31.10.2016 Passed U/S 92Ca Of The I.T.Act Proposed The Following Adjustments:- Segment Value Of Adjustment (Rs.) Manufacturing Segment 4,43,23,760 Hq Charges 86,39,654 Total 5,37,40,836

For Appellant: S/Sri.Sachit Jolly & Aayush Nagpal, AdvocatesFor Respondent: Sri.Sumer Singh Meena, CIT-DR

Section 143(2)Section 143(3)Section 71Section 92C

directions, the A.O. issued final assessment order dated 30.10.2017. Aggrieved by the final assessment order, the assessee has filed this appeal before the Tribunal. The assessee has filed revised ground. In the revised ground, the assessee has raised 12 grounds. However, during the course of hearing, the assessee has only

M/S. Sattva Media and Consulting Private Limited, Bengaluru vs. Deputy Commissioner of Income-Tax, Circle-6(1)(1), Bengaluru

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

ITA 124/BANG/2022[2019-20]Status: DisposedITAT Bangalore23 May 2022AY 2019-20

Bench: Smt. Beena Pillai & Ms. Padmavathy Sassessment Years : 2019-20 M/S. Sattva Media & Consulting Pvt. Ltd., The Deputy No. 294/295, 2Nd Floor, Commissioner Of Amarjyothi Layout, Income Tax, Opp. Egl Tech Park, Circle – 6 (1)(1), Domlur, Vs. Bangalore. Bangalore – 560 071. Pan: Aancs2959Q Appellant Respondent : Shri Sudheendhra B R, Assessee By Advocate : Shri Priyadarshi Mishra, Revenue By Addl. Cit (Dr) Date Of Hearing : 18-05-2022 Date Of Pronouncement : 23-05-2022 Order Per Beena Pillaipresent Appeal By The Assessee Has Been Filed By Assessee Against The Order Dated 23.12.2021 U/S. 250 Passed By The National Faceless Appeal Centre (Nfac), Delhi Relating To Assessment Year 2019-20 On Following Grounds Of Appeal: “The Grounds Mentioned Herein Below Are Independent & Without Prejudice To The Other Grounds Preferred By The Appellant. 1. General Ground 1.1 The Order Passed By The Cit(A), Nfac Is Bad In Law & Liable To Be Quashed.

For Respondent: Shri Sudheendhra B R

Section 139(1)Section 143(1)Section 250Section 36(1)(va)

relied on the amendment brought about to section 36(1)(va) and 43B of the I.T.Act. 4. Aggrieved, the assessee has filed this appeal before the Tribunal. 4.1 The Ld.AR submitted that an identical issue is decided in favour of the assessee by the coordinate Bench of this Tribunal

M/S. Sree Minerals, Bellary vs. The Deputy Commissioner of Income Tax, Circle-1, Bellary

In the result, the appeal filed by the assessee is dismissed in limine

ITA 719/BANG/2021[2009-10]Status: DisposedITAT Bangalore23 May 2022AY 2009-10

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year: 2009-10

For Appellant: Shri V. Srinivasan, A.RFor Respondent: Smt. Priyadarshini Baseganni, D.R

Section 143Section 143(3)

disallowing the claim of depreciation at Rs.3,46,78,764/-. Against this assessee is in appeal before us. The assessee filed this appeal before this Tribunal on 22.12.2021 though the CIT(A) order was dispatched to the assessee on 30.11.2015 and assessee required to file appeal before this M/s. Sree ... Managing Partner but, the same was not accepted by the learned CIT[A]; 3. Coming to the delay in filing the appeal before the Tribunal, it is submitted that the order of the learned CIT[A] was dispatched on 30/11/2015. At the relevant point of time: M/s. Sree Minerals, Bangalore

M/S. Wipro Limited, Bangalore vs. Deputy Commissioner of Income Tax, Circle-7(1)(2), Bangalore

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

ITA 2556/BANG/2019[2015-16]Status: HeardITAT Bangalore23 May 2022AY 2015-16

Bench: Shri N.V. Vasudevan & Shri B.R. Baskaranit(Tp)A No.2556/Bang/2019 Assessment Year : 2015-16

For Appellant: Shri S. Ganesh, Sr. ARFor Respondent: Shri T. Roumuan Paite, D.R

Section 143(3)

directions given Ld DRP. The assessee is aggrieved by the order so passed by the AO and hence it has filed this appeal before the Tribunal. The assessee has raised several grounds in a detailed manner. However, the Ld Senior Counsel appearing for the assessee has advanced his arguments

M/S. Vijay Steel Corporation Pvt. Ltd, Mumbai vs. ACIT 13(3) (2), Mumbai

Appeal is allowed

ITA 91/MUM/2022[2013-14]Status: DisposedITAT Mumbai20 May 2022AY 2013-14

Bench: Shri Vikas Awasthy & Shri Amarjit Singhआअसं. 91/मुं/2022("न.व.2013-14) M/S. Vijay Steel Corporation Ltd. 2, Sabhapati Bhavan, 19, Meera, Santacruz (West), Mumbai 400 054 : अपीलाथ"/ Appellant Pan;Aaacv-3517-E बनाम/ Vs. Acit-13(3)(2). Mumbai : ""थ"/ Respondent

For Appellant: S/Shri Vivek Jani &For Respondent: S/ Shri S.N.Kabra & Mathews

Section 115BSection 143(3)Section 154Section 68

assessee had filed appeal before CIT(A). After being unsuccessful before the First Appellate Authority, the assessee carried the issue in second appeal before the Tribunal in ITA No.6928/Mum/2018. The Tribunal vide order dated 27/01/2022 accepted the contentions of the assessee and deleted the addition u/s68 of the Act. Since ... assessee had also filed 4 appeal against the addition made in the assessment order. The assessee was unsuccessful before the CIT(A). In appeal before the Tribunal, the assessee agitated the addition made under section 68 of the Act on merits. The Tribunal vide order dated 27/01/2022(supra) deleted

Chandrashekher Ramraj Singh, Mumbai vs. ITO, 23(1)(3), Mumbai

In the result, appeal filed by the assessee is allowed

ITA 3133/MUM/2019[2014-15]Status: DisposedITAT Mumbai20 May 2022AY 2014-15

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Pavan Kumar Gadale, Hon'Blechandrashekher Ramraj Singh V. Income Tax Officer – 23(1)(3) 22-A, House No.4 108, Matru Mandir Sherley Rajan Road, Bandra (W) Tardeo, Nana Chowk Mumbai – 400050 Grant Road, Mumbai – 400 007 Pan: Aanps7840R (Appellant) (Respondent) Assessee By : Shri Prakash Jhunjhunwal & Shri Hemant Bahedia Department By : Shri R.A. Dhyani

For Appellant: Shri Prakash Jhunjhunwal &For Respondent: Shri R.A. Dhyani

Section 143(1)Section 143(2)Section 54Section 54F

present case was materially different from the terms of allotment and construction by D.D.A.. In that view of the matter, CIT appeals of the Tribunal correctly held that the assessee had acquired the property in question on 31st December, 2004 on which the allotment letter was issued. 6. Learned ... find any indication in the impugned judgment of the Tribunal though the revenue had argued such a contention in its appeal before the Tribunal.” 12. Similar view was expressed by Hon'ble High Court of Punjab and Haryana in the case of Ms. Madhu kaul v. CIT (supra) observing

Indianoil Skytanking Private Limited, Bangalore vs. Assistant Commissioner of Income Tax, Circle- 3(1)(1), Bengaluru

In the result, the appeals are partly allowed

ITA 407/BANG/2020[2017-18]Status: DisposedITAT Bangalore20 May 2022AY 2017-18

Bench: Shri George George K. & Ms. Padmavathy S

For Appellant: Shri Padamchand Khincha, CAFor Respondent: Shri Sumer Singh Meena, CIT(DR)(ITAT), Bengaluru

Section 115Section 143(3)Section 36(1)(iii)Section 37(1)Section 80Section 80I

State Government or a local authority or statutory body as in clause (b) of section 80IA(4). 21. The assessee is in appeal before the Tribunal aggrieved by the decision of the lower authorities. 22. Besides the above, the assessee is also contending the quantification of deduction u/s.80IA which ... Nos.583/Bang/2019, 299 & 407/Bang/2020 Page 27 of 43 facility in the light of provisions of SPRH agreement. The aforesaid finding has been affirmed in appeal by the Tribunal. The aforesaid findings are concurrent findings of fact which do not suffer from any perversity. Learned counsel for the revenue was unable

M/S. Indianoil Skytaking Private Limited, Bangalore vs. Assistant Commissioner of Income Tax, Circle- 3(1)(1), Bangalore

In the result, the appeals are partly allowed

ITA 299/BANG/2020[2016-17]Status: DisposedITAT Bangalore20 May 2022AY 2016-17

Bench: Shri George George K. & Ms. Padmavathy S

For Appellant: Shri Padamchand Khincha, CAFor Respondent: Shri Sumer Singh Meena, CIT(DR)(ITAT), Bengaluru

Section 115Section 143(3)Section 36(1)(iii)Section 37(1)Section 80Section 80I

Deputy Commissioner of Income Tax, Circle- 6(1)(2), Bengaluru vs. M/S. Symbol Technologies India Private Limited, Bengaluru

In the result, appeal by the assessee and that by the Revenue are treated as partly allowed

ITA 2221/BANG/2019[2011-12]Status: DisposedITAT Bangalore20 May 2022AY 2011-12

Bench: Shri N. V. Vasudevan & Shri Laxmi Prasad Sahu

For Appellant: Shri. Aliasgar Rampurwala, CAFor Respondent: Shri. Pradeep Kumar, CIT(DR)(ITAT), Bengaluru

Section 92Section 92(1)Section 92B(1)

assessee filed appeal before CIT(A). To the extent the assessee did not get relief from the CIT(A), the assessee has preferred appeal before the Tribunal. The revenue is aggrieved by the order of the CIT(A) to the extent the plea of the assessee was accepted. 8. Ground ... held that FCS Software Solutions Ltd., is functionally comparable to the assessee. Aggrieved by the order of the CIT(A), Revenue is in appeal before the Tribunal. 20. Learned Counsel for the assessee brought to our notice decision of the Tribunal rendered in the case of Marvell India

M/S. Symbol Technologies India Private Limited, Bengaluru vs. Deputy Commissioner of Income Tax, Circle- 6(1)(2), Bengaluru

In the result, appeal by the assessee and that by the Revenue are treated as partly allowed

ITA 2057/BANG/2019[2011-12]Status: DisposedITAT Bangalore20 May 2022AY 2011-12

Bench: Shri N. V. Vasudevan & Shri Laxmi Prasad Sahu

For Appellant: Shri. Aliasgar Rampurwala, CAFor Respondent: Shri. Pradeep Kumar, CIT(DR)(ITAT), Bengaluru

Section 92Section 92(1)Section 92B(1)

Shailesh R. Somani, Mumbai vs. Income Tax Officer Ward 19(3) (3), Mumbai

In the result, appeal by assessee is partly allowed

ITA 1455/MUM/2021[2010-11]Status: DisposedITAT Mumbai19 May 2022AY 2010-11

Bench: Shri Vikas Awasthy & Shri S.Rifaur Rahman आअसं.1455/मुं/2021 ("न.व. 2010-11) Shailelsh R. Somani, B/307, Indraprastha Ii, Jitendra Road, Malad (E), Mumbai 400 097 Pan: Anwps-2126-C ...... अपीलाथ" /Appellant बनाम Vs. Income Tax Officer Wd 19(3)(3), ..... ""तवाद"/Respondent Mumbai अपीलाथ" "वारा/ Appellant By : Shri Mandar Vaidya, Advocate With C.A H.K Chheda ""तवाद" "वारा/Respondent By : Shri Suresh Pariasamy सुनवाई क" "त"थ/ Date Of Hearing : 11/05/2022 घोषणा क" "त"थ/ Date Of Pronouncement : 19/05/2022 आदेश/ Order

For Appellant: Shri Mandar Vaidya, Advocate with C.A H.K ChhedaFor Respondent: Shri Suresh Pariasamy

Section 5

assessee on 05/11/2018. The assessee gave all relevant documents to the Chartered Accountant Shri Harakchand K. Chheda for filing of the appeal before the Tribunal. The Chartered Accountant could not file appeal during limitation period as his ailing Mother-in-law was staying with his family

Dow Chemicals International Pvt Ltd. As Successor of Rohm and Haas (India) Pvt Ltd, Mumbai vs. ITO 14 (1)(3), Mumbai

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

ITA 7936/MUM/2019[2015-16]Status: DisposedITAT Mumbai19 May 2022AY 2015-16

Bench: Shri Om Prakash Kant () & Shri Rahul Chaudhary () Assessment Year: 2015-16 Dow Chemical International Private Income Tax Officer-14(1)(3), Limited As Successor Of Rohm & Hass Room No. 458, 4Th Floor, (India) Private Limited, Vs. Aayakar Bhavan, M.K. Road, Godrej It Park-P2, 1St Floor Block B, 02, Mumbai-400020. Lbs Road, Godrej Business District, Pirojshanagar, Vikhroli (West), Mumbai-400079. Pan No. Aaacr 2855 F Appellant Respondent

For Appellant: Mr. Rajan R. Vora/For Respondent: Dr. Yogesh Kamat, CIT-DR

Section 92C

addition for compensation received on termination of contractual rights amounting to ₹17,87,49,236/-. Aggrieved, the assessee, is in appeal before the Tribunal, raising the grounds as reproduced above. Dow Chemical International Private Limited as successor of Rohm and Hass 10 (India) Private Limited 5. Before us, the assessee

ACIT 22 (3), Mumbai vs. M/S Rukhana Enterprises, Mumbai

In the result, all the appeals of the Revenue are dismissed

ITA 6509/MUM/2019[2013-14]Status: DisposedITAT Mumbai19 May 2022AY 2013-14

Bench: Us.

Section 143(3)Section 68

Appeals) on the basis of remand report of Assessing Officer allowed the claim of the assessee , revenue was not entitled to maintain an appeal before the Tribunal against said order of Commissioner (Appeals). The ld. AR before us argued that if the remand report of the ld. AO is considered ... been mentioned, the same is grossly erroneous as is evident from the authorisation memo issued by Pr. Commissioner of Income Tax for preferring appeal to the Tribunal. We find from the M/s. Rukhana Enterprises aurhorisation memo duly signed by Pr. Commissioner of Income Tax, the correct addition to be disputed

ACIT 22 (3), Mumbai vs. M/S Rukhana Enterprises, Mumbai

In the result, all the appeals of the Revenue are dismissed

ITA 6507/MUM/2019[2011-12]Status: DisposedITAT Mumbai19 May 2022AY 2011-12

Bench: Us.

Section 143(3)Section 68

ACIT 22 (3), Mumbai vs. M/S Rukhana Enterprises, Mumbai

In the result, all the appeals of the Revenue are dismissed

ITA 6506/MUM/2019[2010-11]Status: DisposedITAT Mumbai19 May 2022AY 2010-11

Bench: Us.

Section 143(3)Section 68

DCIT-5(1)(2), Mumbai vs. M/S Dharmanandan Diamonds Pvt Ltd., Mumbai

In the result, the appeal of the Revenue is dismissed

ITA 4232/MUM/2019[2013-14]Status: DisposedITAT Mumbai19 May 2022AY 2013-14

Bench: Shri Om Prakash Kant () & Shri Rahul Chaudhary () Assessment Year: 2013-14 Dy. Commissioner Of Income- M/S Dharmanandan Tax, Circle 5(1)(2), Diamonds Pvt. Ltd., R.No. 568, Aayakar Bhavan, Vs. Fc-7081-82, M.K. Road, Bharat Diamond Bourse, Mumbai-400020. Bkc, Bandra (East), Mumbai-400051. Pan No. Aaccd 6676 J Appellant Respondent Revenue By : Dr. Yogesh Kamat, Cit-Dr Assessee By : Rashmikant C. Modi/ Ketki Rajeshirke, Ars Date Of Hearing : 23/03/2022 Date Of Pronouncement : 19/05/2022

For Appellant: Rashmikant C. Modi/For Respondent: Dr. Yogesh Kamat, CIT-DR

Section 271GSection 92Section 92DSection 92D(3)

discussed. In nutshell, levy of penalty under section 271G of I.T. Act, 1961 is hereby deleted.” 3. Aggrieved, the Revenue is in appeal before the Tribunal raising the grounds as reproduced above. M/s Dharmanandan Diamonds Pvt. Ltd. 19 4. Before us the assessee has filed a paperbook containing pages

Fouress Engineering (India)Pvt. Ltd, Mumbai vs. DCIT-5(1)(2), Mumbai

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

ITA 1427/MUM/2021[2013-14]Status: DisposedITAT Mumbai18 May 2022AY 2013-14

Bench: Shri Sanjay Garg () & Shri Om Prakash Kant () Assessment Year: 2013-14 M/S Fouress Engineering (India) Dy. Commissioner Of Income Pvt. Ltd., Tax-5(1)(2), 4Th Floor, Mahalaxmi Chambers, 22, Vs. Aayakar Bhavan, M.K. Road, Bhulabhai Desai Road, Churchgate, Mumbai-400026. Mumbai-400020. Pan No. Aaacf 5897 K Appellant Respondent

For Appellant: Mr. Jeevraj P. Jain &For Respondent: Mr. S.N. Kabra, DR

further appeal, the Ld. CIT(A) partly allowed the appeal of the assessee. 7. Aggrieved with the additions sustained, the assessee is in appeal before the Tribunal raising grounds as reproduced above. 8. Before us, the assessee filed a Paper Book containing pages 1 to 32. M/s Fouress Engineering (India

Bell Teleservices India Private Limited, Bangalore vs. Deputy Commissioner of Income Tax, (CPC), Bangalore

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

ITA 655/BANG/2021[2018-19]Status: DisposedITAT Bangalore18 May 2022AY 2018-19

Bench: Smt.Beena Pillai, Jm & Ms.Padmavathy S, Am

For Appellant: Sri.Sanketh Nayak, CAFor Respondent: Sri.Priyadarshi Mishra, Addl.CIT-DR

Section 139(1)Section 143(1)Section 36Section 36(1)(va)Section 43B

I.T.Act by Finance Act, 2021 is clarificatory and has got retrospective operation. 5. Aggrieved, assessee has filed this appeal before the Tribunal. The learned AR submitted that an identical issue was decided in favour of the assessee by the Tribunal in the case of M/s. Shakuntala Agarbathi Company Vs. DICT

Cerner Healthcare Solution India Private Limited(Earlier Known As Cerner India Health Services Private Limited) ( Erstwhile Cerner Healthcare Solutions Private Limited), Bangalore vs. Deputy Commissioner of Income Tax, Circle-2(1)(1), Bangalore

The appeal is allowed in favour of the assessee

ITA 254/BANG/2021[2016-17]Status: DisposedITAT Bangalore18 May 2022AY 2016-17

Bench: Shri George George K. & Ms. Padmavathy S

For Appellant: Shri Chavali Narayan, CAFor Respondent: Dr. Manjunath Karkihalli, CIT(DR)(ITAT), Bengaluru

Section 10ASection 143(1)Section 143(3)Section 144CSection 271(1)(c)Section 37Section 40

No.254/Bang/2021 Page 4 of 14 capital in nature. The DRP confirmed the disallowance made by the AO. The assessee filed an appeal before the Tribunal contending disallowance. 7. The learned AR submitted that the expenses accrued over the vesting period is cross charged by Cerner Corporation to the assessee ... recognize severance of employer-employee relationship between IT(TP)A No.254/Bang/2021 Page 8 of 14 expatriate and Cerner Corporation. Aggrieved, the assessee is appeal before the Tribunal. 12. The learned AR reiterated the submissions made before the lower authorities that there is no technical knowledge ‘made available’ to the assessee

Assistant Commissioner of Income Tax Circle - 1, Bellary vs. M/S Auro Minerals, Hospet

In the result, appeal of the Revenue is partly allowed and that of the Assessee allowed

ITA 1543/BANG/2018[2012-13]Status: DisposedITAT Bangalore18 May 2022AY 2012-13

Bench: Shri N. V. Vasudevan & Ms. S. Padmavathy

For Appellant: Shri. Percy Pardiwala, Sr. AdvocateFor Respondent: Shri. Srinivas T. Bidari, CIT(DR)(ITAT), Bengaluru

Section 143(3)

documents of proof of payment credited to the forest department.” 55. Aggrieved by the order of the CIT(A), the Revenue is in appeal before the Tribunal. We have heard the rival submissions. The AO disallowed the sum in question on the ground that the required details were not filed