In the result, the Tax Case Appeals are dismissed and the substantial questions of law are answered against the Revenue
Bench: Shri R.K. Panda & Shri K. Narasimha Charyassessment Year: 2011-12 Orchasp Limited Vs. Dy. Cit Hyderabad Circle 1(2) Pan:Aabcc4776F Hyderabad (Appellant) (Respondent) Assessee By: Shri P. Murali Mohan Rao, Ca Revenue By: Shri B. Yadagiri, Dr Date Of Hearing: 13/04/2023 Date Of Pronouncement: 20/04/2023 Order Per R.K. Panda, A.M This Appeal Filed By The Assessee Is Directed Against The Order Dated 23/03/2022 Of The Learned Cit (A)- Nfac, Relating To A.Y. 2011-12. 2. The Grounds Raised By The Assessee Are As Under: “1. On The Facts & In The Circumstances Of The Case The Appellate Order Passed By The Cit(A) Is Erroneous Both On Facts & In Law To The Extent The Order Is Prejudicial To The Interest Of The Appellant. 2. The Cit(A) Ought To Have Appreciated The Fact That The Amount Of Investment Made Is Completely In Wholly Owned Subsidiary Company Which Is Revenue In Nature & Not A Capital Expenditure. 3. The Ld. Cit(A) Ought To Have Accepted The Investments Written Off Of Rs.3,60,72,141/- Since The Said Amount Was Not Received From The Third Party To The Subsidiary & Thus, The Same Amount Was Written Off By The Virtue Of The Circular No. 69 Dt. 27-07-2011 Issued By Rbi.
penalty proceedings u/s. 271(1)(c) of the Income Tax Act since the appellant has neither concealed any income nor furnished any inaccurate particulars of income. 12. The assessee may add, alter or modify any other points to the grounds of appeal at any time before or at the time of hearing of the appeal.” 3. Grounds of appeal No.1