2022 (6) TMI 1540

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..... Vatsalla Jha. ORDER PER VIKAS AWASTHY, JM : This appeal by the assessee is directed against the assessment order dated 26/03/2021 passed under section 143(3) r.w.s. 144C(13) of the Income Tax Act, 1961 [in short 'the Act']. 2. Shri Shekhar Gupta appearing on behalf of the assessee submitted at the outset that he is not pressing ground No. 1 of the appeal. 2.1 In respe....

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....ve fairly admitted that the Tribunal in assessee's own case in preceding assessment years has considered this issue. 4. Both sides heard. The assessee in appeal has raised two grounds. In ground No. l of appeal, the assessee has assailed the findings of Assessing Officer in holding corporate guarantee commission as international transaction. The ld. Authorized Representative of the ass....

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....led appeal before the Tribunal in ITA No. 882/Mum/2017 (supra). The Co-ordinate Bench upheld the findings of CIT (A) and dismissed the appeal of Revenue. Similarly, in the assessment year 2013-14, the CIT(A) restricted the corporate guarantee commission rate to 0.5%. The Revenue agitated the issue before the Tribunal in ITA No. 5720/Mum/2017(supra). The Tribunal following its earlier ....