TaxTMI 
TaxTMI 
2023 (8) TMI 637
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....see has raised the following grounds:- "Based on the facts and circumstances of the case, the Appellant respectfully craves leave to prefer an appeal under section 253(1) of the Income-tax Act, 1961 ('the Act') against the order passed under section 250 of the Act by the National Faceless Appeal Centre (NFAC) on the following grounds, which are independent and without prejudice to each other: 1. On the facts and circumstances of the case and in law, the NFAC erred in upholding the order passed by the learned Assessing Officer (AO) denying legitimate credit of advance tax paid amounting to INR 1,10,00,000 which was otherwise allowable and could not be claimed in the return of income. 2. On the facts and circumstances of the cas....
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.... to 3 has not been quantified since the grounds relate to a single issue and INR. 1,10,00,000 is entirely a credit for legitimate advance tax paid by the Appellant that needs to be granted in totality." 3. The only dispute raised by the assessee, in the present appeal, is pertaining to the denial of credit of advance tax amounting to Rs. 1,10,00,000 paid by the assessee. 4. The brief facts of the case are that the assessee is engaged in the business of providing freight forwarding and supply chain management services to global customers of DAMCO Group. For the year under consideration, the assessee filed its return of income on 30/11/2013 declaring a total income of Rs. 18,58,74,940. The return filed by the assessee was selected for scrut....
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....of advance tax amounting to Rs. 1,10,00,000 as well as relevant extracts of Form 26AS wherein the aforesaid payment is duly reflected. 6. On the other hand, the learned Departmental Representative vehemently relied upon the orders passed by the lower authorities and submitted that this claim was neither made in the return of income nor any revised return of income was filed by the assessee and therefore the claim has been correctly rejected. 7. We have considered the submissions of both sides and perused the material available on record. From the perusal of the challan of payment of advance tax, we find that an advance tax of Rs. 44 lakh was paid by the assessee on 14/06/2012, and an advance tax of Rs. 66 lakh was paid by the assessee on ....