2025 (5) TMI 1670

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....as under:- "issue a writ in the nature of mandamus or any other appropriate writ, order or direction declaring that the assessment proceedings for AY 2005-06 are barred by limitation therefore, direct the Respondents to grant refund of taxes paid/ deposited/adjusted in the case of Petitioner for AY 2005-06, along with applicable interest under Section 244A (1) and 244A (1A) of the Act, as per law;" 2. The petitioner is a company incorporated in India and is a 100 percent subsidiary of Schneider France. During the previous year relevant to Assessment Year [AY] 2005-06, the petitioner was engaged in the business of manufacturing low voltage and medium voltage equipments - Air Circuit Breakers (ACB), Miniature Circuit Breakers, Moulded Case....

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....f the Act. The said order is set out below: - "Order u/s 250 of Income Tax - Act 1961 Consequent upon the order passed by the Ld. CIT(A) vide order No. 28/08-09 dated 23.09.2009, the income of the assessee is recomputed as under:-   Assessed income u/s 143 (3) dated 10.12.2008 474,485,107/-   Less: Relief allowed by Ld. CIT(A) on a/c of:     Loss on foreign exchange fluctuation 72,06,000/-   Revised assessed income (474485107 - 7206000) 467,279,107   r/o 467,279,110" 7. The petitioner challenged the CIT(A)'s order before the learned Income Tax Appellate Tribunal [ITAT] in ITA No.4492/Del/2009. The learned ITAT allowed the said appeal for statistical purposes by the order dated 11.01.2016, and....