2023 (11) TMI 1388

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....sessee in ITA No. 260/Hyd/2023 for A.Y. 2009-10. In this appeal, though the assessee has raised as many as nine grounds, out of them, grounds 3, 4 and 6 are only the effective grounds. Grounds 3 and 4 are with respect to passing of ex parte order by the ld. CIT(A) and ground no.6 is with respect to disallowance u/s 40(a)(ia) of the Act at Rs. 3,54,62,432/- on Royalty and SAP maintenance expenditure. 3. In the other two appeals of assessee i.e., ITA Nos. 261 and 262/Hyd/2023, though assessee has raised many grounds, however, all the grounds are similar to that of the grounds of ITA No. 260/Hyd/2023 except the amounts involved. Hence, we are not reproducing all those grounds for the sake of brevity. 4. As the facts and i....

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....dt. 24.12.2020 and 23.02.203. Para No. 5 of the order of ld. CIT(A) reads as under : "5. The following notices were given to appellant. The detailed chart regarding this is given as under : Notice issued u/s 250 Issued Date Fixing for hearing Remarks ITBA/NFAC/F/APL_1/2020- 21/1029218356(1) 24.12.2020 08.01.2021 Uncompiled by the appellant / assessee ITBA/NFAC/F/APL_1/2022- 23/1050037042(1) 23.02.2023 02.03.2023 Uncompiled by the appellant / assessee In response to the "Notice of Hearing" neither appellant nor his representative filed / forwarded any submissions." 8. Per contra, ld. DR submitted that the assessee has not appeared before the lower authorities. Further, it was submitted that the provisions of DTAA wil....