2022 (6) TMI 1066

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....has filed this appeal against order dated 14.12.2018 in appeal no. 202/2017-18 for the assessment year 2015-16 passed by Commissioner of Income Tax (Appeals)-12, New Delhi (hereinafter referred to as the First Appellate Authority in short 'Ld. F.A.A.') in regard to the assessment order dated 30.12.2017 passed u/s 143(3) of the Income Tax Act, 1961 (hereinafter referred to as 'the Act') by ACIT, Ci....

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....In response, the AR of the assessee attended on 20.12.2017 and filed reply to the show cause notice. The reply of the assessee has been carefully examined and is not found tenable. In reply, the AR has only quoted the judgement of Hon'ble J&K High Court in the case of Shree Balaji Alloys which has already been discussed in para 3.2. However, no reply whatsoever has been given to the findings of th....

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....n @ 100% of the profits derived from the undertaking, this element of subsidy, received in' earlier years, was continuously being treated by it as revenue in nature as this was not resulting into any statutory tax liability. The moment the assessee steps into the sixth year of its production from the date of its inception, it tries to take a contrary stand altogether. The action of the assesse....

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....TA No. 1619/AHD/2008 in DCIT vs. M/s. Munnjal Auto Industries and in assessee's own case for assessment year 2013-14 of Delhi Bench to contend that as with regard to the assessee's case, there is no error in findings of Ld. CIT(A). 7. Giving thoughtful consideration to the matter on record it can be observed that in assessee's own case for assessment year 2013-14 a Coordinate bench decision in M/....