9911796707
TMI Blog2022 (10) TMI 183X X X X Extracts X X X X X X X X Extracts X X X X ..... 9-2022 - SHRI SHAMIM YAHYA, ACCOUNTANT MEMBER SHRI KUL BHARAT, JUDICIAL MEMBER Appellant by Ms. Rashmita Jha, CIT DR Respondent by Shri Salil Aggarwal, Sr.Adv. Shri Anil Makhija, Adv. ORDER PER KUL BHARAT, JM : Both appeals filed by the Revenue against the orders of Ld. CIT(A)-23, New Delhi dated 30.11.2018 and Ld.CIT(A)-43, New Delhi dated 27.02.2019 for the Assessment Years 2013-14 2014-15 respectively. Since identical grounds have been raised, both appeals were taken up together for hearing and are being disposed off by way of consolidated order for the sake of brevity. 2. First we take up the Revenue s appeal in ITA No. 807/Del/2019 pertaining to Assessment Year 2013-14. The Revenue has raised foll ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... this Tribunal in assessee s own case in ITA Nos.8677 8678/Del/2019 for the Assessment Years 2015-16 2016-17 (supra) has decided the issue in favour of the assessee by observing as under:- 8. We have heard both the parties and perused the records. Ld. counsel of the assessee submitted that issue is squarely covered in favour of the assessee by the decision of Hon ble Delhi High Court in assessee's own case. He submitted that the assessing officer despite being told that the case is covered by Hon ble Delhi High Court decision in assessee's own case chose to ignore the Hon ble High Court decision and decide the issue against the assessee. Ld. DR for the Revenue, on the other hand, could not dispute the submission that identic ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the Revenue is dismissed. ITA No.3870/Del/2019 [Assessment Year : 2014-15] 8. Now, we take up the Revenue s appeal in ITA No. 3870/Del/2019 pertaining to Assessment Year 2014-15. The Revenue has raised following grounds of appeal:- 1. Whether the Ld. CIT(A) has erred on facts and in law by deleting the addition of profit of Rs. 38.87,63,486/- of the assessee from providing technical services to other airlines. 2. Whether profit of the assessee from providing technical services to other airlines is covered by Article 8(1) and 8(4) of the DTAA between India and Germany, and by Articles 8(1) and 8(3) of the DTAA between India and Netherlands. 3. The appellant craves to add, amend, modify or alter any grounds of appeal at any ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
