MANISH TYAGI,GHAZIABAD vs. ITO, GHAZIABAD
In the result, appeal filed by the assessee is partly allowed
ITA 5548/DEL/2015[2011-12]Status: DisposedITAT Delhi25 Mar 2021AY 2011-12
Bench: Shri Amit Shukla & Shri Prashant Maharishi(Through Video Conferencing) Manish Tyagi, Vs. Ito, House No. 131, Sector-6, Ward-1(4), Chiranjeev Vihar, Ghaziabad Ghaziabad Pan: Acgpt1413J (Appellant) (Respondent)
For Appellant: Ms. Prem Late Bansal, AdvFor Respondent: Shri Gaurav Dudeja, Sr. DR
Section 160Section 160(1)(i)Section 161(1)Section 163Section 2(14)Section 48Section 54F
person in India.
b)
In CIT vs T.I.& M. Ltd. (1978) 114 ITR 59 (Cal), it is held that as ordained by section 163(2), no person can be treated as the agent of non-resident unless he had an opportunity of being heard given by the Assessing Officer ... Express Newspapers (P) Ltd. (1978) 111 ITR 347 (Mad), it is held that Keeping in view the provisions of section 163(2) regarding opportunity of being heard to be given to the agent as also those of section 246(1 )(d) or 246(2A) or 246(2B) or section 246A