BARCLAYS BANK PLC,MUMBAI vs. CIT (INTERNATIONAL TAXATION)-RANGE-1, MUMBAI

In the result, the appeal by the assessee stands partly allowed

Bench: Shri Shamim Yahya (Am) & Shri Amarjit Singh (Jm)

68,30,713 Ground no 2 On the facts and in circumstances of the case in law, the learned CIT has erred in initiating proceedings under section 263 of the Act when the original assessment order has been passed under section 143(3) r.w.s. 144C(13

VODAFONE INDIA LIMITED,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 7(3), MUMBAI

In the result, the appeal of the assessee is allowed

144C(13)/(5) of the Act, completed the assessment, wherein a demand of Rs 297,26,54,239 was raised, however, no adverse observations/ additions was made with respect to the rights issue. 2.3 Subsequent to the above, the learned Commissioner of Income Tax-1, Chandigarh („learned CIT‟) passed an order under Section 263 of the Act, directing

TUBACEX PRAKASH INDIA P. LTD.,MUMBAI vs. ADDL/JT/CY/ASSTT/CIT/ ITO, NATIONAL E-ASSESSMENT CENTRE,, DELHI

In the result, the appeal filed by the assessee stands allowed on the additional grounds

Bench: Us, First We Would Like To Address Ground No.3 Wherein The Assessee Has Submitted That The Order Of The Ld. Tpo U/S.92Ca(3) Of The Act Dated 01/11/2019 Is Barred By Limitation & Hence, Invalid In Law.

13) of section 144C of the Act provides that upon receipt of directions issued under sub-section (5) of section 144C of the Act, the Assessing Officer shall in conformity with the directions complete the assessment proceedings. It goes without saying that if no objections are filed by the Assessee either before the DRP or the assessing

MARRIOTT INTERNATIONAL LICENSING COMPANY BV,MUMBAI vs. DCIT 3(2)(1), MUMBAI

Bench: Hon’Ble Sh. G. S. Pannu, V.P. & Hon’Ble Sh. Sandeep Gosain, Jm आयकरअपीलसं./ I.T.A. No. 2479, 2480 & 2481/Mum/2017 (निर्धारणवर्ा / Assessment Year: 2003-04, 2004-05 & 2007-08) In The Matter Of:-

13) of the Act being the impugned order. Thus, the impugned order dated 31st January, 2018 ignores the mandate of Section 144C of the Act. Resultantly^* it takes away the petitioner's right to object to the Draft Assessment Order before the DRP. Therefore, taking away a valuable right of the petitioner before the Assessing Officer passes a final