Court :
ITAT New Delhi
Brief :
ITA No. 5444/Del/2016 is the assesee’s appeal against order dated 27.4.2016 passed by the Ld. Commissioner of Income Tax (Appeals) – 44, New Delhi {CIT (A)} for assessment year 2009-10 whereas ITA No. 5445/Del/2016 is assessee’s appeal against order dated 27.4.2016 passed by the Ld. CIT (A) – 44, New Delhi {CIT (A)} for assessment year 2010-11. Since, both the appeals involved identical issues, they were taken up for hearing together and are being disposed of by this common order for the sake of convenience.
Citation :
ITA Nos. 5444, 5445/Del/2016
INCOME TAX APPELLATE TRIBUNAL
DELHI BENCH “I-1”: NEW DELHI
(Through Video Conferencing)
BEFORE
SHRI R.K. PANDA, ACCOUNTANT MEMBER
AND
SHRI SUDHANSHU SRIVASTAVA, JUDICIAL MEMBER
ITA Nos. 5444, 5445/Del/2016
Asstt. Years 2009-10, 2010-11
Minda Furukawa Electric Pvt. Ltd.
Plot No. 68,
Echelon Industrial Area,
Sector -32
Gurgaon 122001
PAN AAFCM1986R
Respondent
Vs.
DCIT
Circle – 6(1)
New Delhi.
(Respondent)
Assessee by: Shri Ajay Vohra, Sr. Advocate
Shri Neeraj Jain, Advocate and
Shri Ramit Katyal, Advocate
Department by: Shri Surender Pal, CIT(DR)
Date of Hearing 14/09/2020
Date of pronouncemen
O R D E R
PER SUDHANSHU SRIVASTAVA, JUDICIAL MEMBER:
ITA No. 5444/Del/2016 is the assesee’s appeal against order dated 27.4.2016 passed by the Ld. Commissioner of Income Tax (Appeals) – 44, New Delhi {CIT (A)} for assessment year 2009-10 whereas ITA No. 5445/Del/2016 is assessee’s appeal against order dated 27.4.2016 passed by the Ld. CIT (A) – 44, New Delhi {CIT (A)} for assessment year 2010-11. Since, both the appeals involved identical issues, they were taken up for hearing together and are being disposed of by this common order for the sake of convenience.
2.0 The brief facts of the case pertaining to assessment year 2009-10 are that the assessee is a 51:49 % joint venture between Minda Capital Limited (owning 49% of shareholding) and Furukawa Electric Co. Ltd and Furukawa Automotive Parts Inc. (jointly owning 51% shareholding). The assessee operates as a manufacturer of wiring harness and supplies the same to its customers which are mainly original equipment manufacturers operating in Indian Automobile Industry. For the purpose of manufacturing, the assessee has a plant at Bawal in Haryana where wiring harness for four wheelers and other components related to wiring harness for example couplers, terminals, relay box, junction box and steering roll connectors etc. are manufactured.
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