2025 (8) TMI 1781

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...., for the assessment year 2005-06; [vide order Annexure-H] bearing No. CIN:U74140KA2003PTC-32798 Dated 16-11-22. b) pass such other or further orders as this Hon'ble Court may deem fit in the facts and circumstances of the case, in the interests of justice and equity." 2. Heard Smt. Tanmayee Rajkumar, learned counsel appearing for the petitioner and Sri. Y.V. Ravi Raj, learned counsel appearing for the respondents. 3. The petitioner, a back office company in the name and style of 'Scicom Contact Centre Services Private Limited', is before the Court on the question of the respondent-Revenue not taking steps pursuant to the order of the Tribunal. 4. A little history is, for the assessment year 2005-06, returns of....

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....the assessee, but remitted the matter back to the Assessing Officer to initiate proceedings afresh and take it to its logical conclusion, nothing worth the name towards initiating proceedings, afresh has taken place till date, despite passage of close to 8 years, of passing of the order of the Tribunal. Therefore, the learned counsel submits that proceedings now to be taken is barred by law, in terms of the aforesaid orders. 7. Learned counsel appearing for the respondent- Revenue has not produced any order or any communication even to the petitioner to demonstrate, that the liberty under the order of Tribunal was even taken forward by the Revenue, as the order permitted initiation of proceedings afresh, which has not taken place till da....

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....d in not excluding comparables having any related party transactions. 3. The ld. CIT ()A erred in holding that the assessee is eligible for a standard deduction of 5% from Arm's Length Price (ALP) under the proviso to Section 92C (2) of the I.T.Act, 1961. 4. For these and other grounds that may be urged at the time of hearing, it is prayed that the order of the CIT (A) in so far as it relates to the above grounds may be reversed and that of the Assessing Officer may be restored. 5. The appellant craves leave to add, alter amend and /or delete any of the grounds mentioned above. 3. Learned DR of the revenue supported the assessment order. 4. Learned AR of the assessee supported the order of CI....