TARGUS INDIA PRIVATE LIMITED,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-12(4), BENGALURU
In the result, the appeal filed by the assessee stands allowed for statistical purposes
ITA 1030/BANG/2022[2009-10]Status: DisposedITAT Bangalore01 Dec 2023AY 2009-10
Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year : 2009-10 M/S. Targus India Pvt. Ltd., No. 74, Prestige Ferozes, The Deputy Sampangi Ramaswamy Commissioner Of Temple Road, Income Tax, Vasanthnagar, Circle – 12(4), Bengaluru – 560 052. Bengaluru. Vs. Pan: Aacct2319J Appellant Respondent Assessee By : Shri Sreeharikutsa, Advocate : Shri Subramanian .S, Jcit Revenue By Dr Date Of Hearing : 30-11-2023 Date Of Pronouncement : 01-12-2023 Order Per Beena Pillaipresent Appeal Arises Out Of Order Dated 30.08.2021 Passed By Nfac, Delhi For A.Y. 2009-10 On Following Grounds Of Appeal: “1. The Order Of The Learned Commissioner Of Income-Tax (Appeals), Passed Under Section 250 Of The Act In So Far As It Is Against The Appellant Is Opposed To Law, Equity, Weight Of Evidence, Probabilities & The Facts & Circumstances In The Appellant'S Case. 2. The Appellant Denies Itself Liable To Be Assessed On A Total Income Of Rs.2,18,38,566/- As Against The Declared Total Income Of Rs. 6,61,672/-On The Facts & Circumstances Of The Case.
For Appellant: Shri SreehariKutsa, Advocate
Section 234ASection 234CSection 250
245/- in respect of the management fees on the facts and circumstances of the case.
4. The learned CIT(A) erred in upholding the disallowance of foreign exchange loss of Rs. 36,65,932/- on the facts and circumstances of the case.
5. The learned CIT(A) failed to appreciate that the management fee as well as foreign exchange loss