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INCOME TAX APPELLATE TRIBUNAL (BANGALORE BENCH)
Shri Prashant Maharishi, VP, Shri Soundararajan K., J
M/s Anand Diagnostic Laboratory – Appellant
Versus
CIT(Appeals)-15, Bangalore – Respondent
| Table of Content |
|---|
| 1. grounds of appeal presented by the assessee. (Para 1 , 2) |
| 2. facts regarding search and assessment order details. (Para 3 , 4) |
| 3. assessment officer's position on discount disallowance. (Para 5 , 9) |
| 4. contentions regarding allowance of discounts. (Para 6 , 10) |
| 5. court's analysis of previous judgments related to discount claims. (Para 11 , 12) |
| 6. arguments against applying specific supreme court judgment. (Para 14 , 15) |
| 7. court’s reasoning against applying provisions of section 45(4). (Para 25 , 26) |
| 8. final conclusion on appeal outcome. (Para 30 , 33) |
ORDER
Per Prashant Maharishi, Vice President
1. These are two appeals in ITA No.968/Bang/2024 for AY 2017-18 & ITA No.969/Bang/2024 for AY 2018-19 filed by M/s Anand Diagnostic Laboratory (the assessee/appellant) against the appellate order passed by the CIT(Appeals)-15, Bangalore dated 29.3.2024 and 25.3.2024 respectively wherein the appeals filed by the assessee against the assessment orders passed u/s 143 (3) of the Act for both the years were dismissed.
AY 2017-18
2. In ITA No.968/Bang/2024 the assessee is aggrieved by the appellate order and has raised the following grounds of appeal :-
“1. The order of the learned Commi
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