Bench: Shri Sanjay Garg & Shri Girish Agrawalassessment Year: 2014-15 Deputy Commissioner Of Berger Paints India Ltd. Income-Tax, Circle-10(1) Vs. 129, Park Street Kolkata Kolkata-17 (Pan: Aabcb0976E) (Appellant) (Respondent) & Assessment Year: 2014-15 Berger Paints India Ltd. Deputy Commissioner Of Vs. 129, Park Street Income-Tax, Circle-10(1) Kolkata-17 Kolkata (Appellant) (Respondent) Present For: Assessee : Shri J. P. Khaitan, Sr. Advocate & Shri Pratyush Jhunjhunwala, Advocate Revenue : Shri Amol Kamat, Cit, Dr Date Of Hearing : 19.07.2022 Date Of Pronouncement : 29.07.2022 O R D E R Per Girish Agrawal: Both These Cross Appeals By The Revenue & Assessee Are Arising Out Of Order Of Ld. Cit(A)-22, Kolkata Vide Appeal No. 14/Cit(A)-22/14-15/16-17/Kol Dated 31.02.2018 Against The Order Of Dcit, Circle-10(1), Kolkata Passed U/S 143(3) Of The Income-Tax Act,1961 (Hereinafter Referred To As The Act), Dated 31.12.2016 For Ay 2014-15. 2. Before Us, Shri J. P. Khaitan, Sr. Advocate & Shri Pratyush Jhunjhunwala, Advocate Appeared For The Assessee & Shri Amol Kamat, Cit, Dr Represented The Revenue. Ld. Counsel For The Ita No. 2299/Kol/2019 By Assessee Berger Paints India Ltd. Ays 2014-15 Assessee Has Placed On Record, A Brief Note On The Submissions Made Along With Paper Books & Chart Substantiate The Claims Made By The Assessee In The Assessment Year Under Appeal.

10,21,06,200/- in respect of its Units at Pandicharry, Goa and Jammu by disregarding that it was not correctly apportioned ? ITA No. 2299/Kol/2019 by Assessee Berger Paints India Ltd. AYs 2014-15 ii) Whether on the facts and in the circumstances of the case the Learned Tribunal has erred in law in upholding the order of CIT (Appeal