2019 (3) TMI 1312

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.... For the Applicant : Mr. Kanchan Kaushal, FCA For the Department : Mr. Ramesh Chander, CIT (DR), AAR, Mr. S.R. Kaushik, Addl CIT-DR (AAR), Mr. Abhishek Tripathy, ACIT DR(AAR) And Ms. Ekta Jain, Addl. CIT, Range-11 ORDER We heard Mr. Kanchan Kaushal, Ld. FCA for the applicant in support of the admission of the application and Mr. Ramesh Chander, Ld. Departmental Representative.Report dat....

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....red u/s245(R)(2)(2)(iii) that relates to a transaction or issue which is designed prima facie of the avoidance of income tax [ except in the case of a resident applicant falling in sub-clause(iii) of clause (b) of section 245N]. In this report it is also stated that notice under section 143(2) of the Income-tax Act,1961 has been issued to the applicant. Thereafter yet another report dated 12.03....

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....d both the reports together, it is apparent that the only objection raised by the Department appears to be regarding alleged tax avoidance. We asked Ld. DR to show us any material in support the plea of tax avoidance. However, at this stage he was unable to furnish any such material. We must note that this matter has been adjourned at least on two occasions. Hence it is not possible to adjourn it ....