2018 (4) TMI 1797

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....R ORDER PER J. SUDHAKAR REDDY, AM: This is an appeal by the Assessee directed against the order of the Final assessment order passed u/s 144C(5) r.w.s. 143(3) of the Income Tax Act, 1961 (The Act) relating to A.Y. 2012-13. 2. The assessee has raised the following grounds of appeal :- "1. That the learned Assessing Officer in course of modifying the assessment for giving effect....

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....T.K.M.Global Logistics Ltd. A.Y.2012-13 2 "1. On the facts of the case and in law, the order of the Transfer Pricing Officer (hereinafter referred to as "TPO") passed u/s 92 CA(3) of the Income-tax Act, 1961, (hereinafter referred to as the 'Act'), subsequently confirmed in part by the Dispute Resolution Panel (hereinafter referred to as "Panel") and consequently incorporated by t....

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....o andl or amend, alter, modify or rescind the grounds hereinabove before or at the time of hearing of the appea." 4. The ld. Counsel for the assessee Shri R.N.Dutt, Advocate pleaded for admission of additional grounds. The ld. DR opposed the same on the ground that they arise out of an order passed u/s 154 of the Act. 5. After hearing the rival submissions, we find that the additional ground....

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....elay in filing shall be considered sympathetically as and when the appeal is filed before the Appellate Authority. 7. Now coming to the regular grounds of appeal, we find that the only issue is with respect to the disallowance made u/s 14A r.w.r. 8D of the Act. The dividend income derived by the assessee is Rs. 5,64,333/-. The Hon'ble Delhi High Court in the case of Joint Investment Pvt. Ltd. V....