2025 (6) TMI 1947

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....Respondent : Sri.Sanjit Kumar Das, CIT-DR ORDER PER INTURI RAMA RAO, AM : This appeal filed by the assessee is directed against the order of the National Faceless Assessment Centre / Commissioner of Income-tax (Appeals) ["the CIT(A)"] dated 30.11.2023 passed u/s.143(3) r.w.s. 263 of the Income-tax Act, 1961 ("the Act") for the assessment year 2017-2018. 2. Briefly the facts of the case are t....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....f revision setting aside the assessment order for the failure of the AO to examine the applicability or otherwise of the provisions of sec.40(a)(iib) of the Act in respect of guarantee commission paid to State Government of Kerala. Pursuant to the order of the revision passed by the PCIT, the AO passed the assessment order u/s.143(3) r.w.s. 263 of the Act making addition in respect of guarantee co....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....ood covered against the appellant company. 7. We heard the rival submissions and perused the material available on record. The issue in the present case relates to the allowability of bank guarantee commission paid to the State Government of Kerala. It is an undisputed fact that the appellant is a wholly owned undertaking of State Government of Kerala. The appellant company made payment of guaran....