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INCOME TAX APPELLATE TRIBUNAL (MUMBAI BENCH)
Smt. Beena Pillai, J, Smt. Renu Jauhri, ACJ
Skechers Sarl – Appellant
Versus
The Assistant Commissioner of Income Tax- 4(2)(1) – Respondent
| Table of Content |
|---|
| 1. nature of appeal and assessment details (Para 1 , 2) |
| 2. observations on services rendered by assessee (Para 5 , 6) |
| 3. conclusions on nature of services and tax obligations (Para 7 , 8) |
| 4. final adjudication of appeal and counsel arguments (Para 9 , 10) |
ORDER
Per: Smt. Beena Pillai, J.M.:
The present appeal filed by the assessee arises out of final assessment order dated 15/01/2025 passed by ACIT 4(2)(1), Mumbai for assessment year 2022-23 on following grounds of appeal:
“ On being aggrieved by the order dated 15 January 2025 passed by the Assistant Commissioner of Income Tax, International Tax Circle 4(2)(1), Mumbai ('herein referred to as the Ld. AO') under section 143(3) read with section 144C(13) of the Income-tax Act, 1961 ('the Act'), the present appeal is preferred on the following grounds, which it is prayed may be considered without prejudice to one another
On the facts and circumstances of the case and in law, the Ld. AO and the Hon'ble Dispute Resolution Panel-2, Mumbai ('DRP'):
General Ground:
1. erred in assessing the total income at INR 52,06,95,454 instead of income offered to tax as per Return of Income ('ROI') at INR 16,93,95,185, Final assessment order bar
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