SIX CONTINENTS HOTELS, INC.,GURGAON vs. ACIT CIRCLE 3(1)(2) INTL. TAXATION, NEW DELHI
In the result, the appeal of the assessee is partly allowed
ITA 3339/DEL/2023[2021-22]Status: DisposedITAT Delhi13 Jun 2024AY 2021-22
Bench: Shri Saktijit Dey & Shri Brajesh Kumar Singh
Section 143(3)Section 144(10)Section 144CSection 144C(13)Section 144C(5)Section 9(1)(vii)
case and in law, the Ld. AO has erred in not following the directions of the DRP without appreciating the fact that Section 144(10) of the Act mandates every direction issued by the Id. DRP is binding on the AO and hence, the impugned assessment order dated 28 September