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TMI Blog2022 (3) TMI 719X X X X Extracts X X X X X X X X Extracts X X X X ..... 4.10.2016 u/s 143(3) DCIT, Circle-11(1), New Delhi (hereinafter referred to as "the Ld. Assessing officer or AO) was partly allowed. 2. The brief facts are HBA Studio Private Limited formerly known as Hirsch Bedner Associates Private Limited, the Appellant, filed its original return of income ROI on 29 November 2014 declaring a total income of Rs. 3,93,39,370/- and claiming a refund of Rs. 320. The Appellant's return was selected for scrutiny assessment. The assessment order dated 24 October 2016, was passed by the Deputy Commissioner of Income tax Circle 11(1) under section 143(3) of the Act wherein the income of the Appellant was assessed at Rs. 4,59,85,300/-. In framing the assessment Learned Assessing Officer made disallowance in respe ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... h that debt has become irrecoverable. 4. That the assessment as made and order of the Ld. CIT(A) are against law and facts of the case involved. 5. That the grounds of appeal as herein are without prejudice to each other. 6. That the appellant respectfully craves leave to add, amend, alter and / or forego any ground(s) at or before the time of hearing." 5. Arguments were heard and on behalf of assessee it is submitted that all the grounds are interconnected. It is contended that it is engaged in hospitality interior design worldwide providing services in interior and graphic designs and in providing art consultancy. It was submitted that high-end decorative and display products are purchased by the assessee from external vendors to b ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... CIT (2010) 323 ITR 397 to contend that the assessee is not required to prove that the amounts have become irrecoverable in the light of amendment in Section 36 (1)(vii) of the Act with effect from 01.04.1999. 6. On behalf of the revenue it was contended that the orders of lower tax authorities have no infirmity and are based on correct appreciation of facts and law. 7. Appreciating the arguments and matter on record it can be observed that the assessee has placed on record the purchase orders on four vendors referred to in para 6.2 of order of Ld. FAA advances shown non recoverable to whom were disallowed. They mentions that under the head "project Shadara Kempinki Hotel" the orders were placed. The project being abandoned led to non-ret ..... X X X X Extracts X X X X X X X X Extracts X X X X
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