INCOME TAX OFFICER WARD - 1(1)(1), SURAT vs. V R SURAT PVT. LTD. FORMERLY KNOWN AS M/S DHANLAXMI INFRASTRUCTURE PVT. LTD., SURAT

In the result, cross objection filed by the assessee (in CO

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.329/Srt/2022 Assessment Year: (2015-16) (Physical Hearing) Income Tax Officer, Ward- Vs. V R Surat Pvt. Ltd. 1(1)(1), Surat, Room No.111, 1St (Formerly Known As M/S. Floor, Aayakar Bhawan, Majura Dhanlaxmi Infrastructure Pvt. Gate, Surat-395001 Ltd.,).F. No.29, Virtuous Retail, Surat Dumas, Nr. Dumas Resort, Magdalla, Surat– 395007 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaccd5578R (Assessee) (Respondent) ""या"ेप. सं./Co No.16/Srt/2022 [Arising Out Of Ita No.329/Srt/2022] Assessment Year: (2015-16)

Price of the above a specified International Transactions.” 14. Therefore, we note that for AY.2013-14, the Assessing Officer had accepted the coupon rate of the same FCCDs. Only factual difference was in that year the same debentures were held by another AE located in Cyprus. It is a well settled legal position that factual matters which permeate through more than

HUBERGROUP INDIA PRIVATE LIMITED,VAPI vs. PR. COMMISSIONER OF INCOME TAX, VALSAD