2020 (2) TMI 1022

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....) No. 1 for the Opponent(s) No. 1   ORAL ORDER (PER : MR. BHARGAV D. KARIA) 1 This Tax Appeal is filed at the instance of the Revenue under Section 260A of the Income Tax Act, 1961 [for short, 'the Act, 1961'] and is directed against the order dated 27th May 2019 passed by the Income Tax Appellate Tribunal, Ahmedabad 'C' Bench, Ahmedabad in ITA No.1338/Ahd/2018 for the assessment ....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....ayments and upholding the same on some other grounds raised therein?" 3. The respondent assessee has filed its return of income for the assessment year 2013-14 declaring total loss of Rs. 1,35,18,193/. The Assessing Officer, by order dated 22nd March 2018, finalised the assessment under Section 143(3) of the Act, 1961. 4. Thereafter, the Principal Commissioner of Income Tax [for short, 'the ....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....ly, after considering the submissions made by the respondent assessee, the PCIT vide order dated 21st March 2018 under Section 263 of the Act, 1961 directed the Assessing Officer to pass fresh assessment order after providing an opportunity of being heard to the respondent assessee in view of the observations made in the order under Section 263 of the Act, 1961. 5. Being aggrieved by the order ....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....d 19th September 1995, the Tribunal held that where payment is made to the shipping agents of the nonresident, ship owner or charter, the agent steps into the shoe of the Principal i.e. shipping company and according to the provisions under Section 172 of the Act, 1961 which provides for shipping business in respect of the nonresidents would be applicable and the provisions of Section 194C or 195 ....