SPE INDIA FILMS HOLDING LLC,MUMBAI vs. ACIT (INTL TAX) -4(2) (2) , MUMBAI

In the result ground no-2 raised by the assessee- is fully allowed

Bench: Shri Amit Shukla & Shri Gagan Goyalspe India Films Holding Llc C/O, Deloitte Haskins & Sells Llp One International Centre, Tower No.3, 27Th Floor-32Nd Floor, Senapati Bapat Marg, Elphinstone Road (W), Mumbai-400013. Pan: Aaocs1827L ...... Appellant Vs. Acit (International Taxation)-4(2)(2) 16Th Floor, Air India Building, Narimaon Point, Mumbai-400021. ..... Respondent Appellant By : Sh. P.J. Pardiwala/Paras Savla Respondent By : Sh. A.K. Keshari Date Of Hearing : 27/06/2022 Date Of Pronouncement : 21/09/2022 Order Per Gagan Goyal, A.M: This Appeal By The Assessee Is Directed Against The Order Of Dispute Resolution Panel-2, Mumbai [Hereinafter Referred To As [‘Drp’] Dated 06.01.2022 For The Assessment Year (Ay) 2018-19. The Assessee Has Raised The Following Grounds Of Appeal: “The Appellant, Objects To The Order Dated 19 January 2022 Passed Under Section 143(3) R.W.S 144C(13) Of The Income Tax Act, 1961 (Act) Passed By The Learned Assistant Commissioner Of Income-Tax (International Taxation) - 4(2)(2), Mumbai