PARIS ELYSEES INDIA PVT. LTD.,JAIPUR vs. DCIT, CIRCLE-7, JAIPUR
ITA 681/JPR/2023[2012-13]Status: DisposedITAT Jaipur19 Sept 2024AY 2012-13
Bench: Him Against The Order Dated 05.12.2019 Passed Under Section 147/143(3) Of The Income Tax Act, [ For Short “Act” ] By Acit, Circle-07, Jaipur.
For Appellant: Sh. Rohan Sogani, CAFor Respondent: Sh. Anup Singh, Addl. CIT
Section 115JSection 147Section 148Section 151Section 250Section 253(5)
u/s 147 is illegal and deserves to be quashed.
GROUND NO. 3
ADJUSTMENT OF Rs. 83,74,399 UNDER CLAUSE
(i) TO EXPALNATION 1 TO SECTION 115JB(2).
SUBMISSIONS
1. Ld. AO was under misconception that such write off of CWIP would be covered under clause (i) of Explanation 1 to Section 115JB(2) i.e., the amount set aside