DELL INDIA PRIVATE LTD.,,BANGALORE vs. JCIT, BANGALORE
In the result, the appeal filed by the assessee is partly allowed and the appeal filed by the Revenue is partly allowed for statistical purposes
ITA 562/BANG/2015[2010-11]Status: DisposedITAT Bangalore18 Aug 2022AY 2010-11
Bench: Shri George George K. & Ms. Padmavathy S
For Appellant: Shri T. Suryanarayana, Senior AdvocateFor Respondent: Shri Praveen Karanth, CIT(DR)(ITAT), Bengaluru
Section 143(3)Section 92C
rectification of the mistake in holding that the amounts received are not refundable, which was also rejected. In the final assessment order, the AO confirmed the addition.
26. Ld AR submitted that –
• “The learned AO has erred in disallowing an amount of Rs. 1,248,869,986 contending the income has been accrued to the assessee during the current financial