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INCOME TAX APPELLATE TRIBUNAL (DELHI BENCH)
G.S. Pannu, VP, Astha Chandra, J
ADVICS COMPANY LTD. KARNATAKA – Appellant
Versus
ACIT CIRCLE INTERNATIONAL TAXATION-1(1)(1) DELHI – Respondent
| Table of Content |
|---|
| 1. appeal against assessment order. (Para 1 , 2) |
| 2. details on employee reimbursements. (Para 3) |
| 3. grounds of appeal covering various tax issues. (Para 4 , 5 , 6) |
| 4. court's legal reasoning regarding fts. (Para 10 , 11 , 12) |
| 5. conclusion and allowance of appeal. (Para 17 , 18 , 19 , 20 , 21) |
ORDER
PER ASTHA CHANDRA, JM
The appeal filed by the assessee is directed against the final assessment order dated 19.03.2022 passed under section 143(3) r.w.s. 144C(13) of the Income Tax Act, 1961 (the “Act”) in pursuance to the directions of Ld. Dispute Resolution Panel (“DRP”) pertaining to the Assessment Year (“AY”) 2017-18.
2. The assessee has taken the following grounds of appeal:-
“General Grounds
1. On the facts and circumstances of the ease, the assessment order passed by the Learned Assessing Officer (‘Ld. AO’) under section 143(3) r.w.s. 144C(13) of the income tax Act, 1965 (‘the Act’) pursuant to the directions of the Ld. Dispute Resolution Panel (‘Ld. DRP’) is bad in law, unlawful and unjust.
2. On the facts and circumstances of the case and in law, the Ld. AO has erred in determining the total income of the Appellant at INR 12.75.31,101 as against the returned income of IN
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