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2025 Supreme(Online)(ITAT) 8060

INCOME TAX APPELLATE TRIBUNAL (DELHI BENCH)
SHRI SUDHIR KUMAR, J, SHRI MANISH AGARWAL, ACJ
The DCIT, Circle 6(1) – Appellant
Versus
Maruti Suzuki India Ltd. – Respondent


Advocates:
For the Appellants/Petitioners: Ms. Amisha S. Gupta, CIT DR
For the Respondents:Shri Ajay Vohra, Sr. Advocate, Ms. Somiya Jain, CA

Table of Content
1. case facts and appeal background. (Para 1 , 2 , 3)
2. key legal questions on refund. (Para 4)
3. court’s directive for a.o verification. (Para 5)
4. result of appeal. (Para 6)

ORDER

PER MANISH AGARWAL, AM :

This appeal is filed by the revenue against the order of Ld. Commissioner of Income Tax (Appeals)-IX, New Delhi, [CIT(A), in short] dated 29.11.2013 in appeal No. 184/2011-12 arising out of the order passed u/s 254/250/143(3) of the Income Tax Act, 1961 (hereinafter referred as ‘the Act’) dated 27.01.2012 for Assessment Year 1997-98.

2. Brief facts of the case are that the appellant company is a public limited company engaged in the manufacturing of cars under the brand of Maruti Suzuki. The return of income for the A.Y. 1997-98 was filed on 28.11.1997 declaring an income of Rs.671,46,33,400/- which was revised on 13.03.1999 at an income of Rs. 668,42,71,770/-. The assessment was completed u/s 143(3) of the Act vide order dt. 24.03.2000 at an income of Rs.820,47,36,850/-. Thereafter various rounds of litigations were completed and finally, the Tribunal vide its order dt. 29.10.2010 has allowed certain relief to the assessee. While giving effect to the order of Trib

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