2018 (11) TMI 1243

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....The revenue has filed the present appeal against the order dated 17.02.2014 passed by the Commissioner of Income Tax (Appeals)-6, Mumbai [hereinafter referred to as the "CIT(A)"] relevant to the AY. 1990-91. 2. The revenue has raised the following grounds: - "On the fact and in the circumstances of the case and in law, the learned CIT(A) has erred in relief 10 the assessee to the exten....

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....atter went up to the Hon'ble ITAT and the Hon'ble ITAT decided the matter controversy between the parties in ITA. No.3461/M/2009. The order giving effect to the said ITAT order dated 28.01.2011 was passed on 16.06.2011 in which the total income of the assessee was assessed to the tune of Rs. 18,28,264/- vide order u/s 154 of the Act dated 20.02.2007. Subsequently an another order dated 01.05.2012 ....

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....se of sister concern title as CIT Vs. M/s. Tata Sons Ltd. in ITA. No.3461/M/2009 and also covered by decision of the assessee's own case decided by Hon'ble ITAT for the A.Y. 1999-2000, 1998-99 & 1995-96. Therefore, in the said circumstances, the appeal of the revenue is liable to be dismissed. Before going further, we deemed it necessary to advert the finding of the CIT(A) on record.:- "4....

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....his rate has also changed from time to time) from the date of payment tax to the date on which the refund is granted [section 244A(l)(b)]." 5. On appraisal of the above mentioned finding, we noticed that the CIT(A) has decided the matter of controversy on the decision of  the Hon'ble ITAT in the assessee's own case for the A.Y. 1999-2000, 1998-99 & 1995-96. In brief, the CIT(A) has directe....