2024 (2) TMI 1112

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....ated 27.06.2023. The grounds of appeal raised by the assessee are as under : "General Grounds 1. On the facts and in the circumstances of the case and in law the Hon'ble DRP/Ld.AO has erred in assessing the total income of the Appellant at INR 842,703,639. 2. On the facts and circumstances of the case and in law, the Hon'ble DRP /Ld. AO has erred in not following the orders of Hon'ble Income Tax Appellate Tribunal and learned Commissioner of Income Tax (Appeals) on identical facts for earlier years i.e. AY 2018-19 & 2019-20. Addition in respect of Fees for Included Services('FIS') - INR 842,703,639 3. On the facts and circumstances of the case and in law, the Hon'ble DRP /Ld. AO has erred in taxing the amount of INR 84....

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....R filed copies of ITAT Orders in assessee's own case in ITA No. 258/PUN/2021, ITA No. 838/PUN/2022 & ITA No. 839/PUN/2022. Ld.AR read out the relevant paragraphs of the ITAT's Order and AO's order. Submission of ld.DR : 4. Ld. Departmental Representative(ld.DR) for the Revenue relied on the order of the Assessing Officer and DRP. However, ld.DR admitted that for A.Y. 2017-18, the identical issue in assessee's case has been decided by ITAT in assessee's favour. Findings & Analysis : 5. We have heard both the parties and perused the records. On perusal of the DRP's order, it is observed that DRP has accepted that for A.Y. 2017-18, 2018-19 and 2019-20 the ITAT has decided the very same issue in favour of assessee. The relevant paragraph 7.....