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Income Tax - Case Laws
Showing 1 to 20 of 667 Records
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2020 (12) TMI 1389 - ITAT DELHI
Accrual of income - income accrued but not received has not been accounted for by the Assessee - assessee claimed royalty payment on accrual basis on the basis of the quantification as per the existing guidelines of the Office of the Directory General of Hydrocarbon (DGH) - system of accounting is being followed consistently - change of accounting policy which is also changed according to the CAG report which is mandatory for the Assessee Board to follow - HELD THAST:- It is pertinent to note that the assessee has followed the same method of accounting which is receipt basis for taking remittance on DGH as an income. The change in account in policy in reference to CAG’s observation/report was basically to strengthen the fund management of the Assessee Board. The assessee accounted for Rs. 4657 lacs as an income from the sale of data from DGH.
From the perusal of the records it can be seen that from accounting purposes it is taken as outstanding on 31st March, 2008 and a sum was realized in the next assessment year and has been accounted for as income. This fact was no where denied by the Revenue. Thus, the CIT(A) has totally ignored this aspect and simply on the basis of change of accounting policy which is also changed according to the CAG report which is mandatory for the Assessee Board to follow, confirmed the addition. The same is not justified as the accounting policy principles were thoroughly followed by the Assessee Board and the income was reported for A.Y. 2009-10 which is next assessment year. There is no revenue loss as well. Therefore, the Assessing Officer as well as the CIT(A) was not correct in making addition.
Addition of Royalty payable to State Government being prior period expense - CIT(A) has given a categorical finding that the royalty payable to Arunachal upto December 2008, the assessee has debited such expenses on the mercantile basis and since these liabilities of payment of royalties have been provided in the relevant year in pursuance of the DGH letters dated 23.03.2009 and 27.03.2009 having detailed working. Once the royalty expenses have been crystallized in the relevant Assessment Year, these are not the contingent liability when the genuineness of the same is not questioned by the Revenue authorities. Hence, there is no need to interfere the findings of the CIT(A).
Assessee is allowed and appeal of the revenue is dismissed.
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2020 (12) TMI 1382 - ITAT JODHPUR
Categorization of income Surrendered during survey - Excess cash surrendered at the time of survey outside the business income - Addition u/s 115BBE - assessee argued that cash discrepancies are business receipts - HELD THAT:- Upon due consideration, we find that the surrender was made by the assessee during survey proceedings at business premises. During the survey action, discrepancies in stock as well as cash were found by the authorities and to make up the same the assessee made a surrender of the same and duly declared the same in his return of income.
It is to be noted that the cash discrepancies were found at the business premises. The assessee does not have any other source of income.
Therefore, the cash discrepancies would be nothing but the business receipts for the assessee. It could not be said that the said income arose from undisclosed sources since the source of the same was to be accepted as business receipts and nothing else. CIT(A), in our considered opinion, was not correct in upholding the action of Ld. AO in taxing the same as per Section 115BBE. We hold that the said receipts would constitute business income to be taxed as per slab rates. Assessee appeal allowed.
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2020 (12) TMI 1381 - ITAT CHENNAI
Revision u/s 263 - Period of limitation - whether order passed u/s.263 is barred by limitation u/s.153(5)? - HELD THAT:- As per Sub-section (3) of Section 153 of the Act, an order of fresh assessment in pursuance of an order u/s.263 of the Act, setting aside or cancelling an assessment, may be made at any time before the expiry of nine months from the end of the financial year in which the order u/s.263 of the Act is passed by the Commissioner.
Therefore, the order giving effect to that order passed by the AO dated 26.02.2016 is clearly beyond the time limit allowed u/s.153(3) of the Act and hence the ld.AR’s plea is sustained. The order of the AO dated 26.02.2016 is quashed. Assessee appeal allowed.
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2020 (12) TMI 1378 - ITAT DELHI
Validity of Reopening of assessment u/s 147 - Addition u/s 68 - reasons to believe - Allegation of non independent application of mind and unwarranted and in a mechanical manner and is not sustainable in the eyes of law - HELD THAT:- We find that initiation of assessment are on Wrong and non-existing facts, because it mentions that “M/s. Binary Semantics Ltd.” is shown to have received following entries”. Thereafter 07 entries have been given for which re-asstt. proceedings have been initiated. The initiation has been done for Rs. 2,47,50,000/- from 07 parties against correctly received only Rs. 1,10,00,000/- from 03 parties.
In the reasons, M/s. Binary Semantics Ltd. has been shown as beneficiary. Assessee has got no connection with this company. Hence, it is a wrong reason/wrong basis of initiation. Further, Chart of Co’s from whom amount has been received has been given in reasons that first 04 parties (1,37,50,000/-) are wrongly mentioned. No amount has been received from them.
In this case initiation of reopening proceedings is mechanical and Non-application of Mind and Borrowed satisfaction because the initiation is on the basis of report of Inv. wing only; No prime facie enquiry done by A.O. before initiating proceedings; Hence, it is a case of initiation on wrong facts and on borrowed satisfaction without application of mind which makes the proceedings un-sustainable. Our view is fortified by the decision of Sarthak Securities Co. (P) Ltd. [2010 (10) TMI 92 - DELHI HIGH COURT] wherein it has been held that no independent application of mind by the AO by acting under information from Inv. Wing. – Notice u/s. 147 to be quashed.
Limitation Period - As we have perused the documentary evidences filed by the assessee especially the notice u/s. 148 of the Act prepared by the AO and sent to post office and delivered to the assessee as stated by the Ld. Counsel for the assessee. As in the case of Kanubahi M. Patel (HUF) vs. Hiren Bhattr [2010 (7) TMI 704 - GUJARAT HIGH COURT] the assessment is barred by limitation and hence, null and void.
Thus reopening of assessment orders quashed - Decided in favour of assessee.
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2020 (12) TMI 1377 - SC ORDER
Nature of receipt - Refund of excise duty claimed from DGFT - Business receipt or capital gain - As decided by HC refund or drawback would go to ultimately reduce the cost of the project and had therefore to be treated as a capital receipt - HELD THAT:- Special Leave Petition is dismissed on the ground of delay.
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2020 (12) TMI 1375 - ITAT BANGALORE
Settlement of dispute under Direct Taxes Vivad Se Vishwas Act, 2020 - Assessee has filed Form No.1 & 2 for the appeal filed by the assessee and it has also received Form No.3. - HELD THAT:- Since the issues contested in the appeal of the assessee have been settled under the Direct Taxes Vivad Se Vishwas Act, 2010, we dismiss the appeal of the assessee as withdrawn. However, we give liberty to the assessee to seek recall of this order in accordance with law, if the circumstances so warrant.
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2020 (12) TMI 1371 - ITAT BANGALORE
TP Adjustment - selection of comparable - HELD THAT:- As observed that DRP/TPO for year under consideration did not consider objections raised by assessee against comparables selected by Ld.TPO and simply followed DRP directions issued for AY 2014-15.
As AY: 2014-15 has been set aside by this Tribunal, we deem it fit and proper to remit the issues to file of Ld.AO/TPO for taking necessary action of passing a speaking order by granting fair opportunity to assessee of being heard. It is also observed that all these are pending before lower authorities and we find no reason adjudicate these issues at this stage - we set aside all issues to Ld.AO for readjudication of issues in the light' of the findings given in earlier years.
Disallowance of provision for onerous contract - HELD THAT:- AR could not prove from the records that the same has been debited to profits & Loss account. Accordingly we reject this ground. However, assessee may claim such amount in relevant year of Accrual. Accordingly Ground stands dismissed.
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2020 (12) TMI 1370 - ITAT DELHI
TP Adjustment - bench marking AMP functions of the assessee - HELD THAT:- On careful consideration of the finding of the learned dispute resolution panel we note that it has issued direction following the decision of the honourable Delhi High Court in Sony Ericsson mobile Co private limited. [2015 (3) TMI 580 - DELHI HIGH COURT] - DR could not point out ny infirmity in the direction of Ld DRP where in it has rejected Bright line test approach in bench marking AMP functions of the assessee. In view of this, we do not find any infirmity in the direction of the learned dispute resolution panel. Accordingly ground of the appeal of the learned assessing officer are dismissed.
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2020 (12) TMI 1368 - ITAT DELHI
TP Adjustment - technical services segment - Comparable selection - HELD THAT:- Exclude ‘Engineers India Ltd.’ being a public sector undertaking and not comparable with the assessee.
CEIL is a wholly-owned subsidiary of ‘Engineers India Ltd.’, which is a government of India undertaking. The ‘Engineer India Ltd.’ has already been held by the Tribunal as a government of India undertaking.
We find that ‘Wapcos’ has been mentioned as government of India undertaking-Ministry of water resources. Similarly, Projects and Development India Ltd. is also one of the Government of India undertakings as evident from the Annual Report of the Company. The Projects and Development India Ltd. is Mini Ratna Company under the Department of Fertilizers, Government of India. In view of the above factual position, respectfully following the finding of the Tribunal in 2010-11 these companies being Government of India undertakings, are directed to be excluded from the set of the comparables. The Learned AO/TPO is accordingly directed to re-compute the transfer pricing adjustment after excluding above for companies.
Adjustment for interest on receivables - TPO observed that assessee has received payment against invoices raised on Associated Enterprises after delay of substantial period, which in case of some invoices has been allowed for more than 200 days - HELD THAT:- In the case of Kusum Healthcare Private Limited [2017 (4) TMI 1254 - DELHI HIGH COURT] held that wherever working capital adjusted margin of comparables has been taken into consideration while benchmarking the main international transaction of sales to AEs, no separate adjustment on account of interest on receivable is required as same get subsumed in working capital adjustment. In the instant case, pursuant to the direction of the Learned DRP, the Learned TPO has computed mean margin of the comparables at 19.93 % , which is available on page 44 of the appeal set. This average margin has been computed using working capital adjusted OP/OC for comparable companies. Thus it is evident that in the instant case working capital adjusted margin of the comparable companies has been considered for determination of arm’s-length price of the international transaction and therefore, following the decision of the Hon’ble jurisdictional High Court (supra), no separate adjustment for interest on receivable is required.
Disallowance u/s 40(a)(ia) - travelling and conveyance cost and salaries paid to the seconded employees constitute fee for technical services - HELD THAT:- As in earlier year identical expenses incurred on travel and conveyance and salary on seconded employees has not been found is liable for disallowance u/s 40(a)(ia) of the Act. This action of the Assessing Officer has not been found erroneous or fraud by the higher authorities of the Income Tax Department and, therefore, once the AO has accepted that the payments are not liable for disallowance, we do not find any reason for agitating those very payments by the Assessing Officer in the year under consideration. Accordingly, we direct the AO to delete the disallowance made under section 40(a)(ia) of the Act on payments reimbursed to foreign AEs towards travel and conveyance cost on salary cost of the seconded employees. The grounds of the appeal are accordingly allowed.
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2020 (12) TMI 1367 - ITAT BANGALORE
TP Adjustment - adjustment has been made without properly appreciating the business model of the assessee - HELD THAT:- This issue was there in the appeal for the assessment year 2014- 2015, wherein the Tribunal in [2020 (2) TMI 1642 - ITAT BANGALORE] after examining the facts of the case, had accepted the contention of the assessee that the TPO conducted transfer pricing analysis on erroneous understanding of the business model of the assessee. Accordingly, the entire transfer pricing issue was set aside to the TPO with a direction that the transfer pricing analysis may be carried out having regard to the business model of the assessee - we restore the entire transfer pricing analysis for de novo consideration to the AO / TPO. Appeal filed by the assessee is allowed for statistical purposes
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2020 (12) TMI 1366 - ITAT BANGALORE
TP Adjustment - MAM selection for distribution segment - assessee has taken Resale Price Method (RPM) to anlayse the segment - TPO said that RPM method can be used only for pure traders who do not do any local value addition - HELD THAT:- In this case, the TPO himself has recorded that the assessee manufactured goods at Rs.83,35,010 and traded goods of Rs.1,73,77,415. However he clubbed the entire turnover and applied TNMM method to determine the ALP.
With regard to sale of traded goods, it is appropriate to apply the RPM method if there was no value added to the traded goods. In case pure sale of traded goods, RPM method is Most Appropriate Method and it does not involve any manufacturing activity. Accordingly, we remit this issue to the file of AO/TPO with direction to the assessee to furnish the segmented details of sale of traded goods and then the AO/TPO shall apply RPM method in respect of sale of traded goods. This additional ground is partly allowed for statistical purposes.
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2020 (12) TMI 1365 - ITAT MUMBAI
Penalty imposed u/s 271AA and 271BA - adjustment to the arm's length price of the international transaction, the TPO has observed that the assessee has not complied with the provisions of section 92D and 92E - HELD THAT:- Transfer pricing provisions would not be applicable. Consequently, the assessee is not required to comply with the provisions contained u/s 92D and 92E.
Though, the assessee was unsuccessfully on the aforesaid stand before the AO, TPO as well as the DRP, however, the Tribunal while considering assessee’s contention [2019 (1) TMI 1999 - ITAT MUMBAI] has restored the issue to the DRP for re–considering assessee’s claim that there was no international transaction of revenue nature between the assessee and the AE in the relevant financial year.
Thus, in our considered opinion, when assessee’s contention regarding not having any international transaction with the AE is still unresolved and is pending before the DRP, it would not be logical and proper to proceed in the matter of imposition of penalty u/s 271AA and 271BA - The requirement of complying with the provisions of section 92D and 92E of the Act only arises in the event of assessee having any international transaction with the AE.
Since, the aforesaid preliminary claim is now pending for decision before the DRP, we are inclined to set aside the impugned orders of Commissioner (Appeals) and restore the issue relating to imposition of penalty under section 271AA and 271BA to the AO - AO, if warranted, may initiate proceedings under the aforesaid provisions on the basis of outcome of the decision of the DRP in the quantum proceedings. Grounds raised by the assessee are allowed for statistical purposes.
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2020 (12) TMI 1364 - ITAT CHENNAI
Exemption u/s 54F - purchase of two residential properties at two different locations on two different dates - HELD THAT:- As per the provisions of the section 54F of the Act, the assessee has violated clause (ii) provided in sub-section (a) of section 54F of the Act, where it is stated that if the assessee purchases any new residential house other than new asset within a period of one year after the date of transfer of original asset, then the assessee is not entitled to claim exemption u/s.54F - In this case on perusal of the facts available on record, lower authorities have recorded categorical findings that assessee has purchased two different residential properties on two different dates and claimed exemption u/s.54F of the Act in contravention of provisions of law. Therefore, we are of the considered view that the assessee is not entitled for exemption u/s.54F of the Act.
We are of the considered view that assessee is not entitled for exemption u/s.54F of the Act for purchase of two residential houses at two different locations on two different dates. The position remains same even after amendment to section 54F by the Finance Act, 2014 w.e.f. 01.04.2015. Therefore, we are of the considered view that the learned CIT(A) has right in denial of exemption claimed u/s.54F of the Act and hence, we are inclined to uphold the findings of the learned CIT(A) and dismiss the appeal filed by the assessee.
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2020 (12) TMI 1363 - ITAT MUMBAI
TP Adjustment - Upward adjustment in respect of international transaction of freight receipts and expenses - benchmarking under CUP - HELD THAT:- As decided in assessee own case [2012 (4) TMI 260 - ITAT MUMBAI] Tribunal has accepted the benchmarking done by the assessee under CUP method and has also held that the profit sharing ratio of 50:50 is prevalent both in respect of agreement entered into between group companies with unrelated parties as well as the assessee.
Respectfully following the same, we uphold the plea of the assessee, and delete the impugned arm’s length price adjustment - The assessee gets the relief accordingly.
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2020 (12) TMI 1362 - ITAT JAIPUR
Validity of Reopening of assessment u/s 147 - non issuing and serving of notice U/s 143(2) - assessee had filed return after stipulated period of 30 days but before finalization of assessment - HELD THAT:- In the present case, the assessee had filed return, though, after stipulated period of 30 days but before finalization of assessment and in case the A.O. had found that there were problems with the return which required explanation by the assessee, then the A.O. ought to have followed up with a notice U/s 143(2).
As no notice U/s 143(2) of the Act was issued which is mandatory requirement in reopen procedure and in our view issuance of notice U/s 143(2) is mandatory in reassessment proceedings initiated U/s 148 which has also been clearly laid down in the case of Alpine Electronics Asia PTE Ltd. [2012 (1) TMI 100 - DELHI HIGH COURT] consedring case of M/S. HOTEL BLUE MOON [2010 (2) TMI 1 - SUPREME COURT] held that Section 143(2) was applicable to a proceedings U/s 147/148 of the Act also. Since, in the present case, no notice U/s 143(2) of the Act was issued or served, therefore, in our view, it relates all the subsequent proceedings as invalid. In view of the above facts and circumstances, we set aside the orders of the authorities below and quash the reassessment proceedings initiated U/s 147 of the Act and allow grounds of assessee.
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2020 (12) TMI 1361 - MADRAS HIGH COURT
Transfer of case u/s 127 - As submitted Authority to whom the proceedings were transferred has already passed the Assessment Order and the same has been served on the Appellant Assessee also - HELD THAT:- We are of the opinion that the Writ Appeal has become infructuous in view of the Assessment Order having been passed by the Assessing Authority in pursuance of the impugned transfer order under Section 127 - We are further of the opinion that the Transfer Order passed under Section 127 is more in the nature of an administrative order rather than quasi-judicial order and the Assessee cannot have any right to choose his Assessing Authority, as no prejudice can be said to have been caused to the Assessee depending upon which Authority of the Department passes the Assessment Order.
Assessee can only be concerned with getting an opportunity of hearing before the concerned Assessing Authority and adduce his evidence and make his submissions before the concerned Assessing Authority. The Income Tax Department has recently introduced a Scheme of Faceless Assessments which will avoid personal hearing and physical interaction of Assessee and Assessing Authority altogether.
Assessee need not even know the name of the Assessing Authority who will deal with his case. The process of hearing appears to have been undertaken by the Assessing Authority who passed the order on 30.12.2016 during the pendency of the writ petition with the permission of the Court, and the Assessment Order to be kept in sealed cover and which was served on the Assessee after the dismissal of the Writ Petition on 05.12.2017.
We do not see anything wrong in the Assessing Authority passing the Assessment Order in the present case and for other years with the due permission of the Court itself and keeping that in a sealed cover until the writ petition was dismissed on 05.12.2017. Even thereafter, the orders were sought to be served only along with a communication dated 21.01.2019 to which the Assessee responded by his letter dated 07.02.2019 and thereafter, another letter by the Chartered Accountants of the Assessee, Mr.R.Balachandran, a response for payment of outstanding tax was given by stating that they were not liable to pay the tax as assessed in the orders in question merely because the Writ Appeal was pending before this Court. It is made clear that there was no stay order from the Division Bench of this Court either against the recovery or passing of the order itself or service thereof on the Assessee.
In our opinion, therefore, there was an abuse of process of the Court in the writ proceedings by the Assessee and taking advantage of the pending litigation, the Assessee has tried to ride roughshod over the Departmental Authorities which it was not entitled to do. An assessment of the tax liability under the Income Tax Act is an obligation of the Assessing Authority and equally obliged is the Assessee to abide by it subject to his right to avail remedy by way of appeals as provided in the Law. Instead of choosing either availing of those remedies or paying the tax as assessed by the Assessing Authority, the Assessee seems to be resting upon the pendency of the litigation in this Court which in our considered opinion was wholly misconceived in the first instance, and infructuous in any case with the passing of the Assessment Order on 30.12.2016.
Therefore, we dismiss this Writ Appeal without interfering with the order of the learned Single Judge in any manner or the Assessment Order passed by the Assessing Authority or the Transfer Order passed by the Revenue Authorities under Section 127.
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2020 (12) TMI 1360 - ITAT DELHI
TP Adjustment - Comparable selection - HELD THAT:- Companies functionally dissimilar with that of assessee AND companies did not passing 25% threshold of RPT filters need to be deselected.
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2020 (12) TMI 1359 - ITAT BANGALORE
Direct tax Vivad Se Vishwas Scheme - order of CIT(A) passed under sections 201(1) and 201(1A) - HELD THAT:- As assessee has moved an application in which it is stated that the assessee has filed Form 1 under direct tax Vivad Se Vishwas Scheme, 2020 in respect of the present appeals. The assessee has also obtained Form 3 certificate containing particulars of tax arrears and the amount payable in Form 3 from the Income Tax Department. In the circumstances, the assessee has prayed for withdrawing the appeals.
The appeals are accordingly dismissed as withdrawn.
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2020 (12) TMI 1358 - ITAT MUMBAI
TDS u/s 194J - Disallowance of deduction claimed towards payment made to National Stock Exchange (NSE) and Bombay Stock Exchange (BSE) for lease line charges/V–SAT and transaction charges - As per AO payment made to NSE and BSE is in the nature of fee for technical and managerial services requiring deduction of tax at source - Disallowance u/s 40(a)(ia) for non–deduction of tax at source - assessee objected to the proposed disallowance by stating that the payment made is not for availing technical or managerial services - whether the payment made by the assessee towards online trading service made available by NSE and BSE is in the nature of technical services? - HELD THAT:- As relying on Hon'ble Supreme Court in case of CIT Vs. Kotak Securities Ltd [2016 (3) TMI 1026 - SUPREME COURT] we hold that the payment made by the assessee towards lease line/V–SAT and transaction charges not being in the nature of fee for technical services will not be amenable to section 194J of the Act. Accordingly, we delete the disallowance made under section 40(a)(ia). Ground no.1, raised by the assessee is allowed.
Disallowance of Security Transaction Tax (STT) u/s 43B(a) - assessee has not actually paid STT during the year under consideration, the Assessing Officer invoked the provisions of section 43B(a) of the Act and disallowed the deduction claimed - HELD THAT:- As section 101 r/w rule 6 and 7, requires ever recognized Stock Exchange and mutual fund to furnish prescribed return to pay STT to the credit of Central Government. Thus, on a conjoint reading of the aforesaid provisions, it is very much clear that the liability to pay STT is on the Stock Exchanges. Assessee is merely acting as an agent of the Stock Exchanges for collecting STT from the buyers and sellers of the shares while facilitating those transactions as a broker. Thus, it is very much clear that the liability to pay STT is not on the assessee. As evident, the assessee has not debited the STT to the Profit & Loss Account. Rather, he has shown it as a Balance Sheet item under the head Liability. That being the case, the liability of STT which the assessee is merely a custodian of, cannot be treated as liability of the nature coming within the ambit of section 43B(a) of the Act. The decisions relied upon by assessee also supports this view. Accordingly, we direct the deletion of disallowance made under section 43B(a) of the Act. These grounds are allowed.
TP adjustment on brokerage commission - adjustment relates to brokerage commission charged to the AE for providing broking services - TPO has made the disputed adjustment by applying the commission charged to non–AE @ 0.28% as CUP - HELD THAT:- On a perusal of the decision of the Tribunal in assessment year 2013–14, [2020 (12) TMI 1051 - ITAT MUMBAI] we find that the disputed issue on which the Tribunal has restored back the issue to the AO/TPO relating to arm's length price adjustment of intra group services. It is very much clear from the reading of the said order, wherein, it has been discussed that while the assessee had determined the arm's length price of intra group service applying TNMM, TPO, though, had applied CUP, however, ultimately he had determined the arm's length price by estimating the cost of employee on man–hour basis. Therefore, it is very much clear that the issue dealt with and decided by the Tribunal in assessment year 2013–14 is not similar to the issue with which we are presently concerned. Rather, on appreciation of relevant facts, we are of the view that the issue arising in these grounds is squarely covered by the decision of the Tribunal in assessment year 2011–12 as reproduced above. In view of the aforesaid, we delete the addition made by the Assessing Officer. The grounds raised are allowed.
TP Adjustment on the brand fee - HELD THAT:- As decided in own case 2002–03 [2013 (11) TMI 927 - ITAT MUMBAI] expenditure incurred by the assessee on royalty and business development could not be considered as excessive compared to the comparable parties. CIT(A) has also applied the TNMM method for benchmarking international transactions. There are 29 comparables selected details of which have already been given earlier which gave an average margin of -5.5% and, in case, loss making companies were excluded, the average margin came to 16.06% whereas in case of the assessee the margin declared was 57.58%. CIT(A) has therefore held that no TP adjustment is required to be made in case of the assessee with which, on the facts of case, we fully agree. We, therefore, see no infirmity in the order of CIT(A) in deleting the addition made and the same is therefore, upheld - Thus we delete the addition made on account of transfer pricing adjustment. This ground is allowed.
Non–grant of credit of TDS - HELD THAT:- We direct the AO to consider the claim of the assessee by verifying the material on record and allow credit for TDS as per law.
Levy of dividend distribution tax (DDT) - HELD THAT:- The submission of assessee that the assessee has already paid the DDT, we direct the Assessing Officer to verify assessee’s claim of payment of DTT and decide the issue accordingly. The ground raised by the assessee is allowed for statistical purposes.
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2020 (12) TMI 1357 - KERALA HIGH COURT
Right to file application u/s 119 - HELD THAT:- As petitioner that an application u/s 119 of the Income Tax Act is being filed before the respondent, the Writ petition is closed without prejudice to the right of the petitioner to pursue the said application.
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