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2023 Supreme(Del) 5981

RAJIV SHAKDHER, GIRISH KATHPALIA
Principal Commissioner of Income Tax – Appellant
Versus
Security Printing And Mining Corporation of India Ltd. – Respondent


Advocates appeared:
Mr Puneet Rai, Sr Standing Counsel with Mr Ashvini Kumar, Standing Counsel, for the Appellant.
Mr Rajiv Tyagi & Mr Rohit Gupta, Advocates, for the Respondent.

JUDGMENT

Girish Kathpalia, J. - By way of this appeal, brought under Section 260A of the Income Tax Act 1961, the revenue has assailed order dated 30.06.2022 passed by the Income Tax Appellate Tribunal in ITA No. 272/Del/2019 pertaining to the Assessment Year 2014-15. On notice of the appeal, the respondent/assessee entered appearance through counsel. We heard learned counsel for both sides in the light of the judicial precedents cited by them.

2. Briefly stated, circumstances relevant for present purposes are as follows.

2.1. The respondent/assessee, a public sector undertaking engaged in the business of designing and printing of bank notes, minting of coins, medallion seals and tokens etc, filed its return of income for the Assessment Year 2014-15 on 09.10.2014, declaring its income to be Rs.512,53,01,630/-.

2.2. The case of the respondent/assessee came under scrutiny and the Assessing Officer passed Assessment Order dated 19.12.2016 under Section 143(3) of the Act, thereby assessing the concerned income to be Rs.518,41,94,170/- after making additions to the tune of Rs.1,92,91,622/- on account of disallowance made under Section 14A of the Act and a further amount to the tune of Rs.3,

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