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TMI Blog2023 (11) TMI 1238X X X X Extracts X X X X X X X X Extracts X X X X ..... shabh Nigam, Ms. Anuja Pethia and Ms. Dacchita Shahi, Advocates. For the Respondent : Mr. Weeraj Jain and Mr. Aditya Vohra, Advocates. ORDER [Physical Hearing/Hybrid Hearing (as per request)] 1. This appeal concerns Assessment Year (AY) 2008-09. 2. Via the instant appeal, the appellant/revenue seeks to assail the order dated 25.06.2020 passed by the Income Tax Appellate Tribunal [in short "T ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ut giving any opportunity to the department? D. Whether on facts and circumstances of the case and also on prevailing law, the Hon'ble ITAT was justified in not appreciating that the claim was not made in the ITR and never raised before the AO and CIT(A)? E. Whether on facts and circumstances of the case and also on prevailing law, the Hon'ble ITAT was justified in holding that credi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e linked to the proposed question "C". According to the learned counsel for the respondent/assessee, the proposed questions "C," "D", and "E" are covered by the following judgments of the Karnataka High Court: (i) Wipro Ltd vs DCIT: (2015) SCC OnLine Kar 9196. (ii) PCIT vs Infosys Ltd: (2023) 147 taxmann.com 520 (Karnataka). (iii) CGI Information Systems and Management Consultants (P) Ltd ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... that the Special Leave Petition i.e., SLP No. 8381/2021, preferred by the appellant/revenue on 25.05.2021, was admitted on 14.12.2021. 10.1 Given this position, it is made clear that insofar as proposed questions "C", "D", and E are concerned, the appellant/revenue will have the liberty to approach the court for reviving the instant appeal, in case it were to succeed in the aforementioned matter ..... X X X X Extracts X X X X X X X X Extracts X X X X
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