2024 (4) TMI 603

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....n Chande, Advocate. For the Respondents Through: Mr Prashant Meharchandani, Sr Standing Counsel with Mr Akshat Singh, Standing Counsel. Mr Ravi Prakash, CGSC with Ms Usha Jamnal, Adv. for UOI. RAJIV SHAKDHER, J.: (ORAL) 1. This writ petition concerns Assessment Year (A.Y.) 2011-12. 2. Via the instant writ petition, the petitioner/assessee seeks to assail the order [Annexure P-22] passe....

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....ted to provide reason for rejection of VsV appliation [sic...application], as per CBDT circular No-7/2020 dated 04.03.2020 in FAQ No-7, 11,14 and 36 you are not eligible to avail the benefit of VsV scheme. In the present case applicant trying to settle the part of appeal filed by the Revenue without considering the Revenue's SLP before Apex Court." 5. The record discloses the petit....

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....e the Dispute Resolution Panel [DRP]. The DRP allowed some objections of the petitioner/assessee while dismissing others. 6. Pursuant to the directions passed by the DRP, the AO framed a final assessment order dated 18.12.2015 computing the income of the petitioner/assessee at Rs. 2,28,02,36,684/-. The addition of interest from ECBs was retained, taking the total taxable income to Rs. 4,43,08,7....

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....No. 306/Del/2016, cross-appeals were filed before the Delhi High Court. The appeal of the petitioner/assessee before the Delhi High Court was numbered ITA 806/2017 while the respondent's/revenue's appeal was numbered ITA 1072/2017. 10. The denial of relief to the petitioner/assessee under the provisions of the Direct Tax Vivas Se Vishwas Act, 2020 [in short, "VSV Act"] is pivoted on the fact th....