B.RAMAKOTAIAH, VIVEK VARMA
ICICI Prudential Insurance Co. Ltd. – Appellant
Versus
Assistant Commissioner of Income-tax, Circle-6(1), Mumbai – Respondent
Per Bench - These appeals are by assessee for the assessment years 2005-06 to 2008-09 and cross appeals by revenue for the respective assessment years. These appeals are on common issues, even though amounts vary from year to year. Therefore, all the appeals were heard together and common order is passed.
2. We have heard the learned Counsel Shri S.E. Dastur and the learned CIT (DR) Shri Subachan Ram in detail and also perused the submissions made by the respective parties and reliance on various case law and paper books placed on record in respective years. Their arguments were incorporated wherever necessary. For the sake of convenience, the issues in assessment year 2005-06 are discussed elaborately.
ITA No.6854/Mum/2010 - AY 2005-06:
3. This is an assessee's appeal in which assessee has raised the following grounds:
"1. The CIT (Appeals) has erred in not accepting the loss of Rs.150.45 crores returned by the appellant.
2. The CIT (Appeals) erred in holding that the surplus as reflected in Form-I is the taxable income of the appellant.
3. The CIT(Appeals) erred in upholding the taxable income for the year at Rs.98.96 crores by holding that the amount transferred from the sharehol
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