2024 (1) TMI 162

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..... of revenue - HELD THAT:- The record shows that in the notes of accounts appended to the balance sheet as on 31.03.2017, the respondent/assessee had clearly indicated that it was not carrying forward the cumulative loss. It is not in dispute that the assessee has not carried forward the aforementioned loss registered upon transfer of the shares of the Indian entities. Respondent says that he has .....

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..... (ORAL): CM APPL. 67282/2023 [Application is filed on behalf of the appellant/revenue seeking condonation of delay in re-filing the appeal] 1. This is an application moved on behalf of the appellant/revenue seeking condonation of delay in re-filing the appeal. 1.1 According to the appellant/ revenue, there is a delay of 130 days in refiling the appeal. 2. Dr Shashwat Bajpai, lea .....

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..... sing Officer (AO) under Section 143(3) of the Act. 9. The CIT(A) s view is that the loss claimed by the respondent/assessee upon transfer of shares concerning Indian entities was both erroneous and prejudicial to the interest of revenue. 10. The record shows that in the notes of accounts appended to the balance sheet as on 31.03.2017, the respondent/assessee had clearly indicated that it was .....

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..... echnologies Pvt. Ltd. (Unlisted) 40,056,781 (219,546,516) (179,489,735) Total (408,993,773) (219,546,516) (628,540,289) 11. It is not in dispute that the respondent/assessee has not carried forward the aforementioned loss .....

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