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INCOME TAX APPELLATE TRIBUNAL (BANGALORE BENCH)
SHRI GEORGE GEORGE K, VP, SHRI WASEEM AHMED, AM
The Deputy Commissioner of Income Tax, International Taxation, Circle -1(2), Bengaluru – Appellant
Versus
M/s. Blue Yonder Inc. – Respondent
| Table of Content |
|---|
| 1. tribunal upheld prior legal conclusions on reimbursement taxability. (Para 2 , 3 , 12) |
| 2. cit(a) ruled favorably for the assessee on classifications of payments. (Para 4 , 10) |
| 3. assessee received reimbursements which revenue classified for taxation. (Para 5 , 6) |
| 4. judicial consistency mandates adherence to prior court rulings. (Para 11) |
| 5. final result denied revenue's appeal, affirming cit(a) order. (Para 15) |
ORDER
Per Bench :
These appeals at the instance of the Revenue are directed against two Orders of CIT(A) both dated 09.05.2024 passed under section 250 of the Act. The relevant Assessment Years are 2012-13 and 2018-19. Assessee has also filed Cross-objection [(CO) No.34/Bang/2024] for Assessment Year 2012-13 challenging the validity of reopening of Assessment.
2. Common issues are raised in these appeals and the CO; hence, they were heard together and are being disposed off by this consolidated order.
3. First, we shall adjudicate the Revenue’s appeals.
4. IT(IT)A No.1302/Bang/2024 (Assessment Year 2012-13) and IT(IT)A No.1326/Bang/2024 (Assessment Year 2018-19)
The grounds raised for both the Assessment Years are identical. They read as follows:
(i) Whether on the f
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