9911796707
TMI Blog2022 (9) TMI 1567X X X X Extracts X X X X X X X X Extracts X X X X ..... Advocate. For the Respondent : Mr. Vishal Kalra with Mr. S.S. Tomar, Advocates. JUDGMENT MANMOHAN, J (Oral): 1. Present income tax appeal has been filed challenging the order dated 11th October, 2021 passed by the Income Tax Appellate Tribunal ('ITAT') in ITA 4720/Del./2017 for the Assessment Year 2009-10. 2. Learned counsel for the Appellant states that the ITAT has erred in deleting the add ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... group services is covered by the judgement of this Court dated 28th July, 2016 in assessee's own case in ITA 386/2016 and other connected matters for the Assessment Years 2007- 08 & 2008-09, wherein this Court has held as under:- "3. ... The contention of the Assessee was that agreement between the Assessee and its AE was a composite one and could not be split up for the purposes of holding tha ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... elow have accepted the contention of the assessee that the assessee was justified in not charging interest on the delayed payments by the AEs and in not levying any interest on delayed payments made by the non-AEs, as the debtor days given to the non-AEs were more than the debtor days given to the AEs. The ITAT also recorded that at times 120 days are given to the non-AE entity for payment from bi ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
