9911796707
TMI Blog2022 (4) TMI 798X X X X Extracts X X X X X X X X Extracts X X X X ..... ainst the assessee. - Decided in favour of assessee. - ITA No. 2877/Chny/2018 - - - Dated:- 22-3-2022 - HON BLE SHRI MAHAVIR SINGH, VICE PRESIDENT AND HON BLE SHRI MANOJ KUMAR AGGARWAL, AM Appellant by : Shri V. Ravichandran (CA)-Ld. AR Respondent by : Shri G. Johnson (Addl. CIT) Ld. DR ORDER Manoj Kumar Aggarwal ( Accountant Member ) 1. Aforesaid appeal by assessee for Assessment Year (AY) 2010-11 arises out of the order of learned Commissioner of Income Tax (Appeals)-16, Chennai [in short CIT(A) ] dated 14-08-2018 in the matter of order u/s 201(1) / 201(1A) passed by Ld. DCIT (Int. Taxation)-2(1) (in short AO ), Chennai on 31.03.2017. 2. In the order dated 31.03.2017, the assessee has been held to be as ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... r of the Commissioner of Income Tax Appeals-16 upholding the order of the Respondent, the Deputy Commissioner of Income Tax, International Taxation 2(1) Chennai, passed under section 201(1) and 201(1A) of the Income Tax Act 1961 for Assessment Year 2010-11. 2. The impugned order relates to the payment of ocean freight on cargo of coal imported by the appellant of ₹ 3,58,49,468 to Noble Chartering Inc. 3. While preparing for the appeal hearing, the appellant realised that no such payments had been made during the previous year relating to Assessment Year 2010-11 but such a payment had been made during financial year 2013-14. 4. The appellant therefore seeks this hon'ble Tribunal's leave to raise the following ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ce at No. 6, Sardar Patel Road, Guindy, Chennai - 600032 do solemnly affirm and declare as follows: 1. OPG Power Generation Private Limited had no transactions with Noble Chartering Inc., during the financial year 2009-10 (Assessment Year 2010-11) nor was any payment made to Noble Chartering Inc. 2. The company had made freight payment of USD 5,77,751.20 (Indian Rupee equivalent ₹ 3,58,49,468) during financial year 2013-14 and the payment was made on 30th December, 2013 against invoice number NCHAR16168 dated 27.12.2013. 7. When these documents were confronted to the revenue, Ld. Sr. DR placed on record the report of concerned Assessing Officer, which read as under: Sub: Assessee Appeal in the case of OPG Power Ge ..... X X X X Extracts X X X X X X X X Extracts X X X X
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