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INCOME TAX APPELLATE TRIBUNAL (PUNE BENCH)
SHRI R. K. PANDA, VP, MS ASTHA CHANDRA, J
Revenue – Appellant
Versus
M/s. Vista Nirman Private Limited – Respondent
| Table of Content |
|---|
| 1. assessment and appeal process overview (Para 1 , 2 , 3 , 4 , 5) |
| 2. court's analysis on the reassessment proceedings (Para 6 , 10 , 15 , 30) |
| 3. judgement reaffirming capital receipt nature (Para 7 , 31 , 38) |
| 4. arguments against the validity of re-assessment (Para 8 , 9 , 11 , 12 , 13) |
| 5. final ruling on dismissal of appeal (Para 40) |
ORDER
PER R.K. PANDA, VP :
This appeal filed by the Revenue is directed against the order dated 15.09.2023 of the CIT(A), Pune – 12, relating to assessment year 2011-12. The assessee has filed the Cross Objections against the appeal filed by the Revenue. For the sake of convenience, the appeal filed by the Revenue and the Cross Objections filed by the assessee were heard together and are being disposed of by this common order.
2. There is a delay of 30 days in filing of the CO before the Tribunal by the assessee, for which the assessee has filed a condonation application along with an affidavit explaining the reasons for such delay which is due to spinal problem of the Director. After considering the contents of the condonation application filed along with affidavit and after hearing the Ld. DR, the delay in filing of the CO is condoned and t
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