2019 (7) TMI 90

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....VAGNANAM, J. These Tax Case Appeals by the assessee, filed under Section 260-A of the Income Tax Act, 1961, ('the Act' for brevity) is directed against the order passed by the Income Tax Appellate Tribunal, "A" Bench, Chennai in I.T.A No.3137/Mds/2016, dated 22.03.2017 for the assessment years 2010-11. 2.The above Tax Case Appeal has been filed raising the following substantial questions....

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.... DRP dated 24.11.2015 in misreading para 3.2.1 and para 3.3.4 on the interpretation of the provisions in sub-sections (5), (7) and (8) of Section 144C of the Act proving perversity in recording findings at paras 7 & 8 of the impugned order both on facts and in law?" 3. We have heard Mr.T.Ravi Kumar, learned counsel for the appellant and Mr.A.S.Sriraman, learned counsel for the respondent/assessee....

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....y the impugned order. In doing so, the Tribunal referred to its earlier decision in an identical case in the case of ACIT Vs. Elegant Estates in ITA Nos.224 & 225/Mds/2016 & CO Nos.51 & 52/Mds/2016. Challenging the said order the Revenue is before us by way of this appeal. 6. Mr.T.Ravi Kumar, learned counsel for the Revenue sought to canvass two issues before us. The first issue is with regard t....

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....r by referring to the amendment with effect from 01.04.2010, Finance Act 2009 for the assessment year 2010-11. 8. Mr.T.Ravi Kumar, learned counsel for the Revenue referred to the decision of the Hon'ble Supreme Court in the case of Reliance Jute & Industries Ltd. Vs. Commissioner of Income Tax [1979 (120) ITR 0921] and a decision of the Allahabad High Court in the case of Krishna Mohan Agrawa....