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RAJIV SHAKDHER, GIRISH KATHPALIA
Principal Commissioner of Income Tax Delhi-4 – Appellant
Versus
Nestle India Ltd. – Respondent
JUDGMENT
Rajiv Shakdher, J.: (Oral)
1. This appeal concerns AY 2013-14.
1.1. This appeal filed by the appellant/revenue concerns Assessment Year (AY) 2013-14 and impugns a common order dated 31.07.2020 passed by the Income Tax Appellate Tribunal [in short, "Tribunal"]. The order dated 31.07.2020, thus, concerns the following AYs: AY 2010-11, AY 2011-12, AY 2012-13, AY 2013-14 (the AY in issue) and AY 2014-15,
1.2. Pertinently, via this order, as noticed above, the Tribunal has disposed of appeals concerning other AYs also, appeals concerning these AYs are listed on our board today as well.
2. Mr Abhishek Maratha, senior standing counsel, who appears on behalf of the appellant/revenue, informs us that the following issues arise for consideration:
(i) First, whether the Tribunal was correct in sustaining the deletion of addition made on account of disallowance of license fee amounting to Rs.1,17,83,98,395/-?
(ii) Second, whether the Tribunal was right in sustaining the view of the Commissioner of Income Tax (Appeals) [in short, "CIT(A)"] in reducing disallowance under Section 14A of the Act from Rs.33,42,193/- to Rs.20,13,989/-?
(iii) Third, whether the Tribunal was right in sustaining
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