9911796707
TMI Blog2021 (4) TMI 768X X X X Extracts X X X X X X X X Extracts X X X X ..... oduction of oil and gas both in domestic and international markets. The company is also engaged in the ownership and operation of wind turbines for generation of wind power in India. 3. The Assessee had filed the return of income for the Assessment Year 2015-16 electronically on 27.11.2015 admitting a total income of Rs. 126,66,09,760/-. The return filed by the Assessee was processed u/s.143(1) of the Income Tax Act, 1961 (hereinafter referred to as 'the Act'). Subsequently, the case was selected for scrutiny under Computer Aided Scrutiny Selection (CASS) and notice u/s.143(2) of the Act dated 22.09.2016 was served on the Assessee. During the previous year relevant to the assessment year under consideration, the Assessee had entered into an international transaction with Associated Enterprises to the tune of Rs. 1018,47,03,207/- and specified domestic transactions to the tune of Rs. 19,32,98,095/-. The case has been referred to the Transfer Pricing Officer [TPO] and thereafter a notice u/s.142(1) of the Act was issued and after following the due procedures, the draft assessment order dated 31.12.2018 was completed and communicated to the Assessee. The Assessee has raised objectio ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he Corporate Guarantee is an International Transaction, the rate charged by the Assessing Officer at 1% is higher and submitted that 0.25% may be charged. Further, he relied upon the decision in the case of Asian Paints Limited Vs. Additional Commissioner of Income-Tax, Large Tax Payer Unit (LTU) reported in [2014] 41 Taxmann.com 71 (Mumbai - Trib.). He also relied upon the decision of the Hyderabad Bench of the Tribunal in the case of the Deputy Commissioner of Income-Tax, Circle - 16(1), Hyderabad Vs. Lanco Infratech Limited reported in [2017] 81 Taxmann.com 381 (Hyderabad - Trib.) 7. On the other hand, the learned Departmental Representative has submitted that the Corporate Guarantee given by the Assessee to an AE is an International Transaction and the rate charged by the Assessing Officer at 1% is reasonable and strongly supported the order passed by the Assessing Officer. 8. We have heard both the sides and considered the arguments and had gone through the orders of the lower authorities. 9. In so far as the issue that whether Corporate Guarantee issued by the Assessee to its AEs comes within the definition of International Transaction or not? The Finance Act, 2012 has ins ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ecision of the Hon'ble Mumbai High Court, it is clear that Corporate Guarantee by an entity on behalf of its AEs a subsidiary company is a international transaction. However, while arriving at a rate, the Assessing Officer has taken comparables from commercial banks to at arrive at mean margin of 1.04% and adopted such rate to determine the ALP of corporate guarantee issued by the Assessee. The Hon'ble Mumbai High Court has confirmed the order of the Tribunal wherein the Tribunal estimated the guarantee commission at the rate of 0.50%. We therefore by considering the facts and circumstances of the case, we are of the opinion that we will fix the guarantee commission at the rate of 0.50%. 11. Accordingly, we set aside the order passed by the Assessing Officer and direct the Assessing Officer to adopt at the rate of 0.50% commission on guarantee issued by the Assessee on behalf of its AEs, a subsidiary company. Thus the ground of appeal filed by the Assessee for the Assessment Year 2015 - 2016 is partly allowed for statistical purposes. 12. The third ground of appeal relating to Disallowance of Interest Expenditure: Facts are in brief that in the Assessment order, the Assessing O ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... apitalized, if the Assessee is not doing share trading business. The Assessing Officer by following the decision of the Hon'ble Jurisdictional High Court in the case of Commissioner of Income Tax Vs Trishul Investments Limited [2008] 305 ITR 434 (MAD) has observed that the interest paid for acquisition of shares would partake character of cost of share and therefore the same was rightly capitalized along with the cost of acquisition of shares. 13. The Assessing Officer further noted that in the Assessee's own case for the Assessment Year 2010 - 2011, the Hon'ble DRP has upheld the Assessing Officer's decision on the same issue, since the facts of the case remain the same, the panel agrees with the findings for the Assessment Year 2010 - 2011 and reaffirms the reasons given by Panel. Considering the above, the objection of the Assessee is not acceptable. The Assessing Officer has further noted that even with the decision of the Hon'ble DRP, this case has been reversed by the Hon'ble ITAT, the addition under this head is made to keep the issue alive, since the appeal of the department is pending before the Hon'ble Madras High Court. Accordingly, he has confirmed the addition. 14. B ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of the Act has been deleted. 18. He further submitted that the Hon'ble ITAT for the Assessment Year 2010 - 2011 and for the Assessment Year 2011 - 2012 in M.A.Nos.067 & 68/Mds/2017, vide order dated 29.11.2017 in Paragraph No.21 has directed the Assessing Officer to comply with the directions of the Hon'ble ITAT with regard to the relevance of expenditure u/s.36(1)(iii) of the Act. 19. Subsequently, a consequential order has been passed by the Assessing Officer on 04.01.2018 for the Assessment Years 2010 - 2011 and 2011 - 2012, wherein the same issue has been deleted. He further submitted that even for the Assessment Year 2013 - 2014, DCIT finally has passed an order dated 26.03.2019 by allowing the interest expenditure u/s.36(1)(iii) of the Act. 20. The learned Counsel for the Assessee has further submitted that as per the Assessment Order which shows that the addition made by the Assessing Officer is only because the appeal is pending before the Hon'ble High Court and submitted that the issue is squarely covered by the decision of the Coordinate Bench of the Tribunal in the Assessee's own case for the Assessment Years 2010 - 2011, 2011 - 2012 and 2013 - 2014 and submitted tha ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 2012 - 2013. We find that in ITA No.450/Mds/2017 forAY 2012-13 vide order dated 19.06.2017, the Tribunal has followed the assessee's own case in ITA Nos. 585/Mds/2015 & 267/Mds/2016 for AYs 2010-11 & 2011-12 dated 14.09.2016. For the sake of convenience, the relevant portion of the order extracted by the Tribunal in assessee's own case is extracted as under: "After hearing to both the parties, we are of the opinion that the similar issue was considered by the Tribunal in Assessee's own case in I.T.A.Nos.585/Mds/2015 & 267/Mds/2016 for the Assessment Years 2010-2011 and 2011 - 2012 dated 14.09.2016 wherein the Tribunal held that:- 31. We find that the reliance placed on by the learned Departmental Representative on the judgement of the Madras High Court in the case of Trishul Investments (supra) is misplaced. The main contention of the learned Departmental Representative is that the interest expenditure on borrowings used for investment in wholly owned subsidiary cannot be allowed as deduction u/s.36(1)9iii) of the Act instead it should be added to the cost of investment, in view of the above judgment of the Madras High Court. In our opinion, when activity is undertaken as an in ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... y. Similarly, when the income is to be computed under the head "Profits and gains from business or profession", the deduction account of interest on borrowed fund is provided under section 36(1)(iii) the Act, where the business assets are acquired out of borrowed funds. At this stage, it may be pertinent to note that depreciation is also allowable as deduction under section 32 in respect of business assets on the cost of acquisition. In determining the cost of acquisition, the interest component after bringing the asset into existence is not taken into consideration as Explanation 8 to section 43 of the Act. If the interest is to be added to cost of acquisition, then the assessee would be entitled to double deduction once under section 36(1)(iii) and the other under section 32 of Act, which is not permissible in view of the decision of the Supreme Court in the case of Escorts Ltd. v. UOI[1993] 199 ITR 43. 31.5 Similarly, when the shares are purchased by way of investment, and the dividend is received in respect of such shares, the interest paid on borrowed funds has been held to be allowable as deduction against dividend income. The Supreme Court has gone a step further in the ca ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... terminal point is the time when the asset is brought into existence or when the asset is put in a working condition. Therefore, on the basis of the Supreme Court judgment, it cannot be said that expenditure incurred after the asset brought into existence, i.e., after the acquisition of the asset would form part of the actual cost. The Supreme Court laid down the proposition that interest paid on monies borrowed for acquisition of capital asset and to meet expenses connected with its installation etc. and capitalized, has to be added to the cost of asset for the purpose of deprecation. 31.8 Thus in our opinion if the money was borrowed for purchase of shares of subsidiary company for the purpose of acquiring controlling interest and acquisition of such controlling interest was of the business of the assessee and it resulted in promote the business of the assessee as well as helpful to the assessee for having management control over said such subsidiary company, then the interest expenditure should be allowed u/s.36(1)(iii) of the Act. Further if the Assessing Officer found that investment in shares of subsidiary company not for maintaining controlling interest, then the Assessing ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s not applicable as expenses incurred outside India (Dubai). For the sake of convenience, the relevant portion is extracted as under: "7. Non-Deduction of TDS for Technical Services rendered: 7.1. It is seen from the financials furnished by the assessee that it has incurred an amount of Rs. 64.00 crores towards Professional and Consultancy Fees. On verification of the details, it is seen that the assessee has not deducted tax for an amount of Rs. 2,48,46,142/- stating that the TDS is not applicable as expenses incurred outside India and paid out India (from Dubai). Sl.No. Name of the Service Provider Amount (in Rs.) 1) Anchor Marine Equipment Co., 530,835 2) Aqualis Offshore Marine Services 318,901 3) Bahwan Cybertech Private Limited 340,062 4) Blue Chip Marine fzc 205,620 5) Bureau veritas 11,17,805 6) Capt. Mark O Carroll 42,34,657 7) Capt. Bernardlesage 9,64,960 8) Moreno & Associates 13,131 9) Oilfield Audit Services Inc. 5,04,795 10) Parveen Kapoor 16,60,592 11) PT. Tenga Baru Nuansa Persada 89,879 12) Seaworks Survey Est. 5,01,352 13) Sing Class 40,31,891 14) Solas Marine Services Co., L.L.C. 4,20,530 15) Tube Star Internatio ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... been considered by the Co-ordinate Bench of the Tribunal in assessee's own case for A.Y 2012-13 in ITA No.450/Mds/2017 dated 19.06.2017. 28. On the other hand, the learned Departmental Representative relied upon the order of the lower authorities. 29. In the Assessment Order, the Assessing Officer has noted that the Assessee has paid professional & consultation fee and had not deducted the TDS. The case of the assessee is that the Assessee has made certain payments as consultancy fees to various parties. These services were utilized by the company for earnings from the source located outside India, i.e. for rig and consultancy or for the purpose of business or profession carried on outside India, i.e. Dubai Branch; as such these incomes were not chargeable to tax to non-resident service providers. It is submitted that the Assessing Officer without examining the provision of Section 195(2) of the Act simply made an addition to Section 9(1)(vii)(b) of the Income Tax Act, 1961. It is submitted that the Assessee has not utilized the services of the parties in India and also payments were made outside India and the services received from non-residents utilized in business or professio ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... wance for non deduction of tax of payment of drilling services & Management fee: Facts are in brief that in the Assessment Order, the Assessing Officer has noted that on verification of the Profit and Loss account for the year ended 31.03.2015, it is seen that the Assessee had claimed an amount of Rs. 6,67,75,950/- towards 'Drilling Services and Management Fees' under the head 'other expenses'. The Assessee has filed the details in respect of the payment on Drilling Services and Management Fees and by considering the same, the Assessing Officer has held that the payment with regard to Management Fees amounting to Rs. 6,67,75,950/- paid to Haledon International Corporation and Hester Development Inc. attracts the provisions of Section 9(1)(vii) and tax has to be deducted at source of these payments. Accordingly, the sum is added to the total income of the Assessee. 34. Dispute Resolution Panel [DRP] has confirmed the order of the Assessing Officer. 35. The learned Counsel for the Assessee has submitted that the issue involved in this appeal is squarely covered by the decision of the Co-ordinate Bench of the Tribunal in the Assessee's own case for the Assessment Year 2012 - 2013 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... al relating to denial of tax credit u/s. 90 of the Act: Facts are in brief that the assessee has earned interest income of Rs. 8,67,00,000/- from M/s. Aban Holdings Pvt. Ltd. which is a Singapore registered company and withholding the tax of SGD equivalent to INR Rs. 1,12,96,962/- has been deducted by M/s. Aban Holdings Pvt. Ltd. under the Singapore Income Tax Act. The assessee has claimed credit of the same in the return of income. The AO disallowed relief u/s. 90 of the Act amounting to Rs. 1,12,96,962/- which was deducted by Singapore authorities on the interest income from M/s. Aban Holding Pvt. Ltd. under the Singapore Income Tax Act. The assessee has submitted before us that since the income from foreign country of Rs. 8,66,10,040/- was offered to tax by the assessee, the assessee is entitled to get credit to the extent of tax paid in a foreign country. The assessee has filed breakup of the interest income in paper book page No.481 and also filed details of the withholding the tax received from Singapore tax authorities in paper book page No.440 to 441. It is also submitted that the issue is covered in favour of the assessee for the AY 2012-13 vide order dated 19.09.2017 in ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... income of the branches of the assessee shall also taxable in India i.e it would be included in the return of income filed by the assessee in India and whatever taxes have been paid by the branches in the other contracting states i.e the source country, credit of such taxes shall be given. Thereafter, the Tribunal in this case remitted the issue to the file of the Assessing Officer to decide afresh in the light of the above order of the Tribunal in the case of Bank of Baroda in I.T.A.No.2927/Mum/2011 dated 25.7.2014. Later assessee filed MA in MA Nos. 95 & 96/Mds/2016 stating that the direction given by the Tribunal is not appropriate. Since the assessee has no income from any branches in Singapore, that decision cannot be applied to the assessee's case. The Tribunal while adjudicating the said MA vide order dated 29.7.2016 held as follows : "We have heard the rival submissions and perused the material on record. In our opinion, the interpretation of the order of the Tribunal by the ld. AR is misconceived. The Tribunal was of the opinion that if the income from foreign country is offered to tax by the assessee by whatever means, the assessee has to get tax credit to the extent th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ract and others (Generally termed as Forex Derivatives). These instruments protect the foreign currency receivable of the exporters for the exports in goods and services. These instruments offer protection by allowing the exporters to exchange the foreign currencies received out of exports to Indian rupees in a pre-agreed rate of exchange in future specified date, subject to various terms and conditions that vary according to the type of derivative countries. 46. So far as the facts of the Assessee is concerned, the confirmation submitted by the Assessee showed that the contracts were not settled by actual delivery but by cancellation or premature closure by paying or receiving the difference in the amount between the rate at which the contract has been entered and the prevailing exchange rate on the date of cancellation of the settlement. Thus, the Assessee's explanation that forward contract are basically risk management tools and they are useful in facilitating temporary hedging of price risks that was found to be incorrect. So, it is decided that the incomes received from the Forward and Options Contracts and loss on the same is not an income or loss from his business and acco ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ent, he relied upon the decision of the Hon'ble ITAT of Bangalore Bench in the case of M/s. Essilor India Private Limited Vs. The Deputy Commissioner of Income Tax in IT(TP)A. No.190, 176 (B)/2014 for the Assessment Year 2013 - 2014. 51. He also submitted that it is a business decision taken by the Assessee and to protect the interest of the business, he has entered into a Forex contract and subsequently he had suffered some loss. The Assessing Officer cannot say that it is not necessary for the Assessee to enter into such a contract. 52. On the other hand, the learned Departmental Representative strongly supported the order passed by the authorities below. 53. We have heard both the sides and perused the materials available on records and had gone through the orders of the authorities below. 54. The Assessing Officer has disallowed the Forex loss of the Assessee mainly on the ground that the Assessee need not enter into such a contract for the nature of the business of the Assessee. Secondly, the Assessing Officer had denied the Forex loss of the Assessee on the ground that the Assessee has not furnished the risk analysis statement identifying the exposure and also had not fi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e Assessing Officer has asked the Assessee to clarify as to why the disallowance should not be made u/s.14A r.w.Rule 8D. The Assessee replied that they had not incurred any expenditure in connection with earning exempt income and that the disallowance u/s.14A of the Act is not called for. The Assessing Officer after considering the explanation of the Assessee has noted that the Assessee has incurred an amount of Rs. 93.01 crores as Finance Cost on its borrowed capital during the year. Though the Assessee has claimed that such borrowed funds were not utilized for making investments, it could not clearly establish the same. Funds for a Company come in a common kitty and it comprises of borrowed funds, share capital and retaining earnings (Reserves & Surplus). Therefore, to argue that no portion of the interest paid relates to investment is not valid. 59. The Assessing Officer further noted that the Assessee cannot earn dividend income without the existence of management. The Assessee must have been incurred administrative expenses and without incurring the expenses, it is not possible to earn dividend income and accordingly the Assessing Officer has invoked Section 14A r.w.R-8D and ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 66. It is also the case of the Assessee that no disallowance u/s.14A has to be made because the Assessee is having sufficient own funds. However, as for the Assessing Officer, the Assessee is not able to submit the details and substantiate that the borrowed funds are not utilized for the purpose of the business. 67. Thus, we set aside the order passed by the Assessing Officer and remit the issue back to the file of the Assessing Officer to examine afresh, keeping in view the decision of the Delhi Bench Special of the Tribunal (supra), passed order thereupon. Thus the ground of appeal filed by the Assessee is allowed for statistical purposes. 68. The ninth ground of appeal relating to Disallowance of long term capital loss : Facts are in brief that in the Assessment Order the Assessing Officer has noted that during the current year the Assessee has claimed Long Term Capital Loss on sale of investments in the equity shares of M/s. Aban Holdings Private Limited, Singapore who is wholly owned foreign subsidiary of the Assessee (or in other words buy-back of shares by the wholly owned foreign subsidiary). The details of the shares sold, such as the number of shares sold, sale consi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 5.06.2014 6,41,026 0.7800 5,00,000 30.06.2014 60,25,641 0.7800 47,00,000 01.07.2014 1,02,56,410 0.7800 80,00,000 Total 1,87,17,949 1,46,00,000 Further investment in the shares of Aban Holdings Private Limited for the FY.2014 - 2015 Date of Investment Explanation No. of shares Amount of USD 14.07.2014 Equity Investment in Wholly owned subsidiary 135,13,513 100,00,000 14.07.2014 Equity Investment in Wholly owned subsidiary 67,56,757 50,00,000 14.07.2014 Equity Investment in Wholly owned subsidiary 67,56,757 50,00,000 14.07.2014 Equity Investment in Wholly owned subsidiary 67,56,757 50,00,000 Total 337,83,783 250,00,000 69. From the above, the Assessing Officer has noted that the Assessee has sold tranche of shares in the wholly owned subsidiary M/s. Aban Holdings Private Limited from 13.06.2014 to 01.07.2014 for a sum of USD 146,00,000 incurring huge long term capital loss, only thirteen days later a sum of USD 250,00,000 was invested in the same shares by the Assessee. Since this is against a common prudence, the Assessee was asked to explain the transaction along with copies of buyback offer, copies of valuation rep ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Rules, 1962. The company has incurred Long Term Capital Loss of $1,83,33,297 equivalent to INR 1,08,61,22,342/- after claiming index cost of acquisition. A detailed working of Long Term Capital Loss has been enclosed herewith for your kind consideration. Since, the investment in shares was held for more than 2 years and the same were sold at the value determined as per Rule 11 UA, our company has rightly claimed the long term capital loss on sale of such shares and same may kindly be allowed to carry forward to future years. We would like to submit that the part of the above transaction had taken place in FY 2013-14 relevant to AY-2014-15 and a total capital loss on sale of shares of MIs Aban Holding Private Limited was arrived at 112,66,71,005/-. During the course of scrutiny proceedings, queries was raised regarding the Long Term Capital Loss claimed by our company and after our reply, the same was ace Private by the Assessing officer for A Y2014-15. Since the loss in current year in on the same transaction, we request you to kindly accept the Long Term Capital loss claimed by our company. Herein, it is once again submitted before you kind office that the during the FY 201 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... clusion that the Assessee has undertaken the transaction that is buying and selling of shares of the Assessee's wholly owned subsidiary without any valid reasons and the same is not substantiated by the Assessee by placing relevant materials and not disclosed the real reason behind undertaking such transactions. Accordingly, the long term loss claimed by the Assessee is disallowed. 75. The Assessing Officer also relied upon the decision of the Madras High Court in the case of M/s. Premier Synthetic Industries Vs. Income Tax Officer, Ward - II (7), Coimbatore [2012] 22 Taxmann.com 333 (Mad.). Keeping in view of the direction given by the DRP. 76. The ld. Counsel for the assessee has argued that the assessee has taken a business decision of buy and sale the shares therefore, the AO cannot step into the shows of the assessee. Further he relied on the decision of Hon'ble Supreme Court in the case of S.A Builders Vs. CIT 288 ITR 01 (SC). He further submitted that the capital loss on account of sale of shares was not adjusted against any capital gain even till date. Accordingly, no tax benefit was levied therefore, obtained by the assessee company after the capital loss was booked by ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... es of M/s. Aban Holdings Private Limited, Singapore, Assessee's wholly owned subsidiary company and that no third party in involved. The transaction is between the Assessee's own sister concern and the Assessee. The Board has taken a decision on 13th November, 2013. As regards to the entire buyback of the shares, the Assessing Officer for the Assessment Year 2014 - 2015, in the scrutiny proceedings allowed the capital loss of the Assessee. In the year under consideration, the Assessing Officer says that the Assessment Year 2014 - 2015 is different from the Assessment Year 2015 - 2016. The Board has taken a decision with regard to the buyback of the shares. One transaction has already been completed for the Assessment Year 2014 - 2015 and the same is allowed by the Assessing Officer. The remaining part of the transaction is completed during the subsequent year and the Assessing Officer has doubted the same on the ground that the Minutes of the Meeting has not been placed before the Assessing Officer and also the Assessee has sold the same shares to M/s. Aban Holdings Private Limited, Singapore. We find that the reason given by the AO in our opinion is justified for the reason that t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e towards fees for advising on issues relating to business strategy. It is most humbly submitted that during the Financial Year 2014 - 2015, our company was going through difficult business period that had to go for corporate restricting in order to service the liabilities. M/s. Emkay Global Financial Services Limited is a company founded in the year 1995 is providing financial advice in various areas and is listed in the major recognized stock exchanges of India including Bombay Stock Exchange. The company is located in Mumbai and its PAN is AAACE 0994L. During the year under consideration, M/s. Emkay Global Financial Services Limited ha provided our company consultancy services in respect of financial restructuring of our company and accordingly has raised an invoice of Rs. 1,89,00,000/- towards such services and also charged service tax @ 12.36% of Rs. 23,36,040/-. Thus, the payment was made after deducting the applicable TDS. It is not out of place to submit here that the above payments are reflected in the Form 26AS of M/s. Emkay Global Financial Services Limited and the same is offered by them to Income Tax. Further, M/s. Emkay Global Financial Limited is not a related pa ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... or the purpose of business is allowable u/s.37 of the Income Tax Act, 1961 and submitted that the Assessee has received consultancy services from M/s. Emkay Global Financial Limited for financial restructuring. It is for the purpose to run the business of the Assessee and therefore the same cannot be disallowed. He further submitted that the Assessee has deducted service tax and also the Tax Deducted at Source [TDS] in respect of the payment made to Emkay Global Financial Limited. He also submitted that the Assessee has taken a decision in respect of his business and a Consultant is engaged for which he had paid consultancy charges for the services and therefore the Assessing Officer cannot sit upon the business decision taken by the Assessee and disallow the expenditure which is incorrect. To support his arguments, he relied upon the decision in the case of M/s. S.A. Builders Limited Vs. Commissioner of Income Tax (Appeals) reported in 288 ITR 1/158 Taxmann 74 (SC); Assistant Commissioner of Income Tax Vs. Durgapur Tea Company [2003] 131 Taxmann 39; Principal Commissioner of Income Tax Vs. Basti Sugar Mills Company Limited reported in [2018] 98 Taxmann.com 401 (Delhi). He also re ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
