9911796707
TMI Blog2022 (12) TMI 783X X X X Extracts X X X X X X X X Extracts X X X X ..... is appeal filed by the Revenue is directed against the order dated 18.05.2018 passed by the Commissioner of Income Tax (Appeals)-31, New Delhi relating to Assessment Year 2013-14. 2. Brief facts of the case as culled out from the material on record are as under :- 3. Assessee is a company stated to be engaged in the business of manufacturing of Polyester Cotton Yarn, Cotton Yarn, manmade Fibre y ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... facts and circumstances of the case, the Ld. CIT(A) was justified in restricting arm's length price of compensation for providing corporate guarantee on behalf of its A.E. @1% instead of 2.58% determined by AO after a detailed discussion in the assessment order thereby giving relief of Rs.5,60,11,287/- to the appellant." 2. "Whether on the facts and circumstances of the case, the Ld CIT(A) was ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... (PB)/2019 dated 03.01.2020 has admitted the petition. He further submitted that Hon'ble Company Law Tribunal has declared moratorium in terms of Section 14 of the Insolvency and Bankruptcy Code, 2016 ('IBC'). He submitted that by virtue of the declaration of moratorium, all liabilities of assessee pertaining to any governmental dues related to a period prior to the approval of the Resolution Plan ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... t Hon'ble National Company Law Tribunal vide order dated 03.01.2020 has admitted the petition filed by Edelweiss Asset Reconstruction Company Ltd. against the assessee u/s 7 of the IBC Code and has declared moratorium in terms of Section 14 of the Insolvency and Bankruptcy Code ('IBC'), 2016. 7. Hon'ble Apex Court in the case of PCIT vs. Monnet Ispat & Energy Ltd. (2019) 107 Taxmann.com 481 (SC) ..... X X X X Extracts X X X X X X X X Extracts X X X X
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