SHANTHI FORTUNE (INDIA) PRIVATE LIMITED,TIRUPUR vs. ACIT TDS CIRCLE, COIMBATORE
In the result, the appeal filed by the assessee is allowed and the appeal filed by the Revenue and the CO filed by the assessee are dismissed
ITA 2385/CHNY/2018[2009-10]Status: DisposedITAT Chennai30 Nov 2022AY 2009-10
Bench: Shri V. Durga Rao & Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A. No.2385/Chny/2018 िनधा"रण वष"/Assessment Year: 2009-10 M/S. Shanthi Fortune (India) Vs. The Assistant Commissioner Of Private Limited, Income Tax, Door No. 38, Trichy Road, Tds Circle, Coimbatore. Palladam 641 664. [Pan: Aajcs4289D] आयकर अपील सं./I.T.A. No.2557/Chny/2018 िनधा"रण वष"/Assessment Year: 2009-10 & C.O. No. 88/Chny/2019 [In I.T.A. No.2557/Chny/2018] The Income Tax Officer, Vs. M/S. Shanthi Fortune (India) Tds Ward, No. 121, Private Limited, Sixty Feet Road, Tirupur 641 602. Door No. 38, Trichy Road, Palladam 641 664. (अपीलाथ" /Appellant) (""थ"/Respondent/Cross Objector) Department By : Shri P. Sajit Kumar, Jcit Assessee By : Shri N Arjun Raj, C.A. सुनवाई की तारीख/ Date Of Hearing : 17.11.2022 घोषणा की तारीख /Date Of Pronouncement : 30.11.2022 आदेश /O R D E R Per V. Durga Rao: Both The Cross Appeals Filed By The Assessee As Well As Revenue Are Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals) 2, Coimbatore, Dated 25.06.2018 Relevant To The Assessment
For Appellant: Shri N Arjun Raj, C.AFor Respondent: Shri P. Sajit Kumar, JCIT
Section 153(3)Section 254
v.
Ram Kumar [MANU/SC/0405/2001: (2001) 8 SCC 24], has elaborately discussed the scope and ambit of an amending legislation and its retrospectivity and held that every litigant has a vested right in substantive law but no such right exists in procedural law. This Court has held that the law relating to forum and limitation is procedural in nature whereas
