Court :
ITAT New Delhi
Brief :
These are two appeals filed by the assessee for the same assessment year. First one in ITA No 2006/Del/2017 against the order of the ld CIT(A) -7, New Delhi dated 20.01.2017 for the Assessment Year 2010-11 wherein dismissing the appeal of the assessee against various disallowances/additions made by the learned The Deputy Commissioner Of Income Tax, Circle – 14 (1), New Delhi are confirmed. Second in ITA No 2191/DEL/2017 against the order of the learned Commissioner Of Income Tax Appeals – 7, New Delhi dated 25/1/2017 wherein the penalty levied u/s 271(1) (c) of the Act by the ld AO of ₹ 1250000000/– is confirmed.
Citation :
ITA No. 2191& 2006/Del/2017
INCOME TAX APPELLATE TRIBUNAL
DELHI BENCH “F”: NEW DELHI
BEFORE SHRI AMIT SHUKLA, JUDICIAL MEMBER
AND
SHRI PRASHANT MAHARISHI, ACCOUNTANT MEMBER
ITA No. 2191& 2006/Del/2017
(Assessment Year: 2010-11)
Quippo Telecom Infrastructure Pvt. Ltd, D-2, 5th Floor, Sourthern Park, Saket Place, New Delhi PAN: AAACQ1279N
(Appellant)
Vs.
The Assistant Commissioner of Income Tax , Circle-19(1), New Delhi
(Respondent)
Assessee by : Shri Ajay Vohra, Sr. Adv Shri Divyan Mittal, CA
Revenue by: Smt Sulekha Verma, CIT DR
Date of Hearing 13/12/2019
Date of pronouncement 06/03/2020
O R D E R
PER PRASHANT MAHARISHI, A. M.
1. These are two appeals filed by the assessee for the same assessment year. First one in ITA No 2006/Del/2017 against the order of the ld CIT(A) -7, New Delhi dated 20.01.2017 for the Assessment Year 2010-11 wherein dismissing the appeal of the assessee against various disallowances/additions made by the learned The Deputy Commissioner Of Income Tax, Circle – 14 (1), New Delhi are confirmed. Second in ITA No 2191/DEL/2017 against the order of the learned Commissioner Of Income Tax Appeals – 7, New Delhi dated 25/1/2017 wherein the penalty levied u/s 271(1) (c) of the Act by the ld AO of ₹ 1250000000/– is confirmed.
2. The assessee has raised following grounds of appeal in ITA No. 2006/Del/2017 for the Assessment Year 2010-11 against the order of the CIT – A [7] , New Delhi dated 20/1/2017 wherein the assessee preferred an appeal against the order of The Deputy Commissioner of Income tax , Circle 14 (1) , New Delhi [ The learned assessing officer/ AO] passed under section 143 (3) of The Income Tax Act 1961 [ The Act] on 15 March 2013
wherein the returned loss of assessee of Rs. 2258653756/– as per return dated 8/10/2010 was assessed at Rs. 2054110/–:-
“1.0 That on the facts and circumstances of the case, the Ld. CIT(Appeals) was not justified & grossly erred in confirming disallowance of expenditure incurred towards professional fee of Rs. 2,50,00,000/- in computing total income of the appellant.
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