M/S. TATA TECHNOLOGIES LTD.,,PUNE vs. DEPUTY DIRECTOR OF INCOME-TAX,,
In the result, appeal of assessee is partly allowed
ITA 1433/PUN/2014[2007-08]Status: DisposedITAT Pune05 Apr 2018AY 2007-08
Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita No.1433/Pun/2014 यििाारण वषा / Assessment Year : 2007-08 M/S. Tata Technologies Limited, Plot No.25, Rajiv Gandhi Infotech Park, अऩीऱाथी/Appellant Hingewadi, Pune – 411057 …. Pan: Aaact3092N Vs. The Dy. Director Of Income Tax …. प्रत्यथी / Respondent (International Taxation)-Ii, Pune
For Appellant: S/Shri Dhanesh Bafna and Arpitha ChoudaryFor Respondent: S/Shri Vivek Aggarwal and Mukesh Jha
Section 115ASection 195Section 201Section 201(1)Section 9(1)(vi)Section 90(2)
11. The learned Departmental Representative for the Revenue on the other hand, pointed out that the findings of CIT(A) at page 10 were that Explanation introduced in 2012 was clarificatory in nature and hence, was applicable to earlier years. He placed reliance on the ratio laid down by the Hon'ble Supreme
Court in the case of Transmission Corporation