2022 (8) TMI 560

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....45/Delhi/2022 - -<br>Income Tax<br>Shri C.N. Prasad, Judicial Member And Shri Pradip Kumar Kedia, Accountant Member For the Assessee : Sh. Akul Agarwal, Advocate, Sh. Divyanshu Agarwal, Advocate, Sh. M. R. Sahu, CA, Sh. D. C. Garg, CA Sh. Ankit Gupta, CA, Sh. R. A. Gupta, CA, Sh. Suneer Kunsia, CA, Sh. Anmol Anand, Advocate Ms. Priya Tandon, Advocate, Shri Divyanshu Agarwal, Advocate, Sh. Ekans....

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.... rival submissions and perused the material available on record. The issue is no more res-integra. The issue has already been settled in favour of the assessee by various judicial pronouncements by the Tribunal. The Hon'ble Jurisdictional High Court of Delhi in the case of PCIT vs Pro Interactive Service (India) Pvt.Ltd. in ITA No.983/2018 [Del.] order dated 10.09.2018 held as under:- "In....

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....hat the amendment will take effect from 01st April 2021 and will prospectively apply in relation to the assessment year 2021-22 and subsequent assessment year. In such a situation, we are of the view that the amendment brought out by Finance Act, 2021 does not apply to the assessment year under consideration. 6. Before us, the Revenue has not placed any material on record to demonstrate that th....

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....Synthetics (P.) Ltd. vs. DCIT (2022) 137 taxmann.com 475 (Mum. Trib) observed that scope of prima facie disallowance under Section 143(1) is inherently very limited and only such disallowance can be made under this statutory provision as can be conclusively held to be inadmissible based on material on record. The claim of the assessee for allowability of employee's contribution to PF/ESIC under Se....