HOTEL POLO TOWER PRIVATE LIMITED,SHILLONG vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE- SHILLONG, SHILLONG
In the result, the appeal of the assessee is allowed
ITA 287/GTY/2019[-]Status: DisposedITAT Guwahati11 Nov 2021
Bench: Shri Partha Sarathi Choudhury & Shri Manoj Kumar Aggarwali.T.A. No.287/Gau/2019 Assessment Year: 2016-17 Hotel Polo Towers (P) Ltd..…….……………….…………...………..….. Appellant Polo Grounds, Shillong-793001, Meghalaya. [Pan: Aabct0864B] Vs. Acit, Circle, Shillong………….....….………………………………… Respondent Appearances By: Shri K. M. Roy, Ca, Appeared On Behalf Of The Appellant. Shri N.T. Sherpa, Jcit, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : November 10, 2021 Date Of Pronouncing The Order : November 11, 2021 Order Shri Partha Sarathi Choudhury:
Section 14ASection 14A(2)
Section 14A(2) of the Act, read with Rule 8D of the Rules, we also make it clear that before applying the theory of apportionment, the AO needs to record satisfaction that having regard to the kind of the assessee, suo moto disallowance