TATA CUMMINS PRIVATE LIMITED,PUNE vs. THE DCIT CIRCLE-1-JAMSHEDPUR AND THE ASSESSMENT UNIT, INCOME-TAX DEPARTMENT, NFAC, DELHI, JAMSHEDPUR
In the result, appeal of the assessee is partly allowed for statistical purposes
ITA 430/RAN/2024[2021-22]Status: DisposedITAT Ranchi12 Jun 2025AY 2021-22
Bench: Shri George Mathan & Shri Ratnesh Nandan Sahaytata Cummins Private Limited, D.C.I.T., Cummins India Office, Tower-A, 7Th Circle-1, Vs. Floor, Survey No. 21, Balewadi, Pune, Jamshedpur. Maharashtra. Pan No. Aaact 6353 L Appellant/ Assessee Respondent/ Revenue
Capital gains' which is one of the heads of income. If by application of the provisions of Section 45 read with Section 48 which are integrally connected with each other, the income cannot be said to arise, Section 92 of the Act does not come to the aid of Revenue, even though it is an international transaction. The expression 'income
