2026 (7) TMI 1869

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.... For the Assessee : Shri Nikhil Tiwari & Ms. Karishma Gosalia, ARs For the Revenue : Shri Satya Pal Kumar - CIT(DR) ORDER PER PRABHASH SHANKAR [A.M.] :- The present appeal arising from the appellate order dated 22.05.2025 is preferred by the assessee against the order passed by the Learned Commissioner of Income-tax (Appeals)/National Faceless Appeal Centre, Delhi [hereinafter referr....

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.... the business of manufacturing and trading of precision measuring equipment and related services, software development, market support and business support services. The assessee company e-filed its return of income for the year declaring total income of Rs. 80,98,52,990/-. The said return was processed u/s. 143(1) on 08.04.2019 of the Act. The case was selected for scrutiny. Though the Internatio....

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....g to him question of adjudicating the same did not arise at all. 5. Before us, the ld.AR has contended that the issue of excess refund was raised before the AO vide letter dated 03.03.2021 and 08.06.2020 for claiming the refund of excess DDT paid in the light of DTAA with Switzerland. However, neither the AO considered the same nor the ld.CIT(A) on merits. It is claimed that such a contention w....