2025 (4) TMI 1796

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....ri Rajesh Kumar Dhanesta, Sr. DR ORDER PER M. BALAGANESH, A. M.: 1. The appeal in ITA No.1247/Del/2022 for AY 2011-12, arises out of the order of the Commissioner of Income Tax (Appeals)-27, New Delhi [hereinafter referred to as 'ld. CIT(A)', in short] in Appeal No. 22/10011/2018-19 dated 31.01.2022 against the order of assessment passed u/s 143(3)/144C(1) of the Income-tax Act, 1961 (her....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....strial and domestic switchgears, capacitors, cable and wires, compact fluorescent lamps and related components, electrical fans, electric motors, electrical wire accessories and luminaries lighting fixtures during the year. The assessment was completed under section 143(3) r.w.s. 144C(1) of the Act on 29.4.2015 determining total income at Rs. 204,44,55,222/- under normal provisions of the Act and ....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... ALP of Corporate Guarantee Fee by holding that the same is a debatable issue and there was no false claim made by the assessee in the return of income in any manner whatsoever on this issue. We do not find any infirmity in the said order of the ld CIT(A) as ultimately the quantum addition was made on an estimated basis to determine the ALP of Corporate Guarantee Fees and there was no furnishing o....