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2022 (4) TMI 1527 - AT - Income TaxApplicability of provisions of section 144C - whether no variation in the income returned and the income assessed and accordingly the impugned assessment order was time barred? - HELD THAT:- This issue is covered in favour of the assessee by a series of order of the coordinate benches including in the cases of IPF India Property Cyprus Ltd. 2020 (2) TMI 1667 - ITAT MUMBAI], Cupiono Ltd. [2021 (4) TMI 1357 - ITAT MUMBAI], Mausmi SA Investments LLC [2019 (4) TMI 2079 - ITAT MUMBAI], Mosbacher India LLC. [2016 (12) TMI 235 - ITAT CHENNAI], DCIT vs. Magna International Inc [2019 (1) TMI 1199 - ITAT PUNE] AND Regen Renewable Energy Generation Global Limited [2020 (1) TMI 1632 - ITAT CHENNAI], even though learned Departmental Representative vehemently relied upon the stand of the Assessing Officer as embedded in the grounds of appeal set out herein above. Thus provisions of section 144C did not apply to the fact of this case as there was no variation in the income returned and the income assessed and accordingly the impugned assessment order was time barred. Decided in favour of assessee.
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