2025 (3) TMI 1425

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.... r.w.s. 144C of the Income-tax Act, 1961 (hereinafter referred to as 'the Act'). 2. Heard both the parties. Case file perused. 3. The assessee pleads the following substantive grounds in the instant appeal: 1. That on the facts and in the circumstances of the case & in law, the order passed by the Ld Commissioner of Income Tax (Appeals) 44 [Ld. CIT(A)"), to the extent confirming Assessing Officer's ["AO"] action, is bad in law and void ab-initio 2. That on the facts and in the circumstances of the case & in law, the Ld. CIT(A) grossly erred in not allowing deduction in respect of Provision created on account of litigation of INR 15,155,582. 3. That on the facts and circumstances of the case and in law, t....

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.... 5. Without prejudice to Ground Nos. 3-3.2 above, in case the rate of DDT is not restricted based on the beneficial provisions of the India- Sweden tax treaty, cess of INR 2,94,52,500 paid on DDT should be allowed as deduction for computing the total income as per the provisions of the Act. 6. That on facts and in the circumstances of the case and in law, the AO/CIT(A) has erred in not allowing complete credit of Tax Deducted at Source of INR 3,276,930,422 7. That on facts and in the circumstances of the case and in law, the AO/CIT(A) has erred in not allowing complete Foreign Tax Credit u/s 90/91 of INR 1,793,404 That the above grounds of appeal are without prejudice and notwithstanding each other, ....