JAIN IRRIGATION SYSTEMS LTD,,JALGAON vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 2,, JALGAON
Appeal is partly allowed in above terms
ITA 227/PUN/2018[2013-14]Status: DisposedITAT Pune22 Dec 2022AY 2013-14
Bench: Shri S.S.Godara & Dr.Dipak P.Ripoteआयकरअपीलसं. / Ita No.227/Pun/2018 िनधा"रणवष" / Assessment Year : 2013-14 Jain Irrigation Systems Ltd., The Deputy Commissioner Of Jain Plastic Park, N.H No.6, Vs Income Tax, Circle-2, Jalgaon – 425001. . Jalgaon. Pan: Aaacj 7163 Q Appellant/ Assessee Respondent /Revenue Assessee By Shri Percy Pardiwala; Shri Prashant Maheshwari & Ms.Monicamulchandani – Ar’S Revenue By Shri B Koteswara Rao – Dr Date Of Hearing 23/09/2022 Date Of Pronouncement 22/12/2022 आदेश/ Order Per S.S.Godara, Jm: This Assessee’Sappeal For Assessment Year 2013-14Is Directed Against Thedeputy Commissioner Of Income Tax, Cricle-2, Jalgaon’S Assessment Order Dated 29.10.2017, Framed In Furtherance To The Dispute Resolution Panel-3, Mumbai (Drp)’S Direction Dated 25.09.2017 Passed In Objection No.78, In Proceedings U/S 143(3) R,.W.S 144C(5) Of The Income Tax Act, 1961 [In Short “The Act”].
Section 143(3)Section 92D
Section 92D of the Act read with Rule 10D of the Income tax Rules, 1962 and the various submissions made by the Appellant.
2. Provision of Corporate Guarantee
2.1
On the facts and in circumstances of the case and in law, the learned AO and the learned TPO erred in concluding and the Hon’ble DRP erred in confirming
