Sarwar Ahuja, vs. Income Tax Officer, Ward 6(1),

Accordingly dismissed. Pending applications are also dismissed

Bench: The Learned Itat Assailing The Order Dated 05.01.2024 Passed By The Assessing Officer [Ao] Under Section 147 Read With Section 144C(13) Of The Act. 3. The Assessee Is A Company, Which Is Tax Resident Of The United States Of America [Usa]. The Assessee Has Also Furnished A Tax Residency Certificate [Trc] From The Concerned Authorities Of The Said Country. Digitally Signed By:Tarun Rana Signing Date:01.06.2025 13:30:53 Signature Not Verified

Section 144C(1) of the Act. 9. The Assessee filed its objections to the draft assessment order before the Dispute Resolution Panel [DRP] which were rejected by an order dated 27.12.2023. During the proceedings before the DRP, the Assessee also furnished additional evidence including with regard to allocation of corporate charges and repair and maintenance services. However, the DRP upheld

Principal Commissioner of Income Tax-2 vs. M/s.Viskha Container Terminal Private Limited

Bench: RAMESH RANGANATHAN,KONGARA VIJAYA LAKSHMI

Pricing Officer (TPO) vide letter dated 30.11.2009 and during the course of proceeding before the TPO, assessee vide its letter dated 09.06.2010 categorically stated that its registered office was at Hyderabad and it stood merged with Wipro Ltd., pursuant to the scheme of amalgamation approved by the High Court of Andhra Pradesh vide order dated 21.02.2008 and scheme of amalgamation