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TMI Blog2023 (8) TMI 457X X X X Extracts X X X X X X X X Extracts X X X X ..... ppellants (By Shri. E.I. Sanmathi, Standing Counsel) For The Respondent (By Shri. T. Suryanarayana, Senior Advocate For Ms. Tanmayee Rajkumar, Advocate) JUDGMENT P.S. DINESH KUMAR, J., This appeal by the Revenue is directed against order dated July 19, 2019 in ITA No. 1080/Bang/2019 passed by the ITAT [Income Tax Appellate Tribunal], Bengaluru, for A.Y. [Assessment Year] 2014-15 has ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... paid in USA; iii) Foreign remittance without deducting TDS; and iv) Lease of Sasken brand to related parties free of cost. 4. In substance, the argument canvassed by the Revenue is that the CIT(A), in his order passed under Section 263 of the Act [Income Tax Act, 1961], has rightly directed the AO for reconsideration of the issues. 5. Shri Suryanarayana for the assessee has taken us through ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... and AY. 2014-15, the assessee has offered the same to tax. This aspect was misconstrued by the CIT(A) to the effect that the assessee was claiming expenditure. The ITAT has rightly analyzed and held that there was no ground for revision under Section 263. 8. The second issue is with regard to payment of state tax paid in USA. The ITAT has noticed that the AO had applied his mind and taken a decis ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ecorded that the AO has taken a 'possible view' on this aspect after 'due enquiry and application of mind'. Similarly, with regard to the fourth issue namely, lease of 'Sasken brand' to related parties free of cost, the AO has taken a 'possible view'. 10. In the authority relied upon by the Revenue, the Apex court has held in para 21 that there can be no doubt that so long as the view taken by th ..... X X X X Extracts X X X X X X X X Extracts X X X X
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