M/S. PIAGGIO VEHICLES PVT.LTD,,PUNE vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE - 4,, PUNE
In the result, appeal of the assessee is dismissed
ITA 868/PUN/2022[2015-16]Status: DisposedITAT Pune23 Dec 2024AY 2015-16
Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.868/Pun/2022 िनधा"रण वष" / Assessment Year: 2015-16 Piaggio Vehicles Private Ltd., V The Assistant Sky One Corporate Park, S Commissioner Of Income Ground Floor, Survey Tax, Circle-4, Pune. No.239/02, Near Pune Airport, Pune – 411032. Pan: Aabcp1225G Appellant/ Assessee Respondent / Revenue Assessee By Shri Siddhesh Chaugule – Ar Revenue By Shri Vidya Ratan - Dr Date Of Hearing 18/12/2024 Date Of Pronouncement 23/12/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeals)-13, Pune For Assessment Year 2015-16 Dated 06.10.2022 Passed Under Section 250 Of The Income Tax Act, 1961. The Assessee Has Raised The Following Grounds Of Appeal : “1. Refund Of Excess Taxes Paid On Dividend Distributed On The Facts & Circumstances Of The Case & In Law, The Hon'Ble Cit(A) Has Erred In Not Granting The Benefit Of Article 11 Of The India-
Section 115Section 2(24)Section 250Section 3Section 4
10(33), disallowable under Section 14A of the Act?”
33. While answering the said question this Court considered the object of insertion of Section 14A in the Income Tax Act by Finance Act, 2001, details of which have already been noticed.
Noticing the objects and reasons behind introduction of Section
11
14A of the Act this Court held that: “Expenses
