DCIT, Circle-19(1), Delhi Vs. Outsourcepartners International Pvt. Ltd.

Parties Involved

Facts Summary

These Revenue’s and assessee’s cross appeals ITA Nos.5808/Del/2024 and 5975/Del/2024 for assessment year 2018-19 arise against the Commissioner of Income Tax (Appeals)/National Faceless Appeal Centre [in short, the “CIT(A)/NFAC”], Delhi’s DIN and order no. ITBA/NFAC/S/250/2024-25/1069930080(1), dated 24.10.2024 involving proceedings under section 143(3) of the Income-tax Act, 1961. The Revenue’s appeal seeks to revive the Assessing Officer’s action invoking section 14A read with Rule 8D disallowance of Rs.2,13,32,788/- made in assessment order dated 27.09.2021 and reversed in the lower appellate discussion. The assessee’s cross appeal argues that the CIT(A)/NFAC has erred in not adjudicating its corresponding substantive grounds seeking to reverse the CPC’s section 143(1) processing disallowing/adding the corresponding expenditure claims.…

Legal Issues

• 1. Revival of the Assessing Officer’s action invoking section 14A read with Rule 8D disallowance.
• 2. CIT(A)/NFAC’s error in not adjudicating the assessee’s corresponding substantive grounds.

Judgment Outcome

Decided in favour of Partly Assessee / Partly Revenue.

Precedents Relied Upon

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