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Indian Railway Finance Corporation Ltd Vs. DCIT

Case No: ITA No. 1103/Del/2023
Court: INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “C”: NEW DELHI
Date: 9/25/2024

Parties Involved

appellantIndian Railway Finance Corporation Ltd
respondentDCIT

Facts Summary

The case involves an appeal by Indian Railway Finance Corporation Ltd against the order of the National Faceless Appeal Centre (NFAC), Delhi, which upheld the addition of certain amounts to the book profit by the Assessing Officer under section 143(1) of the Income-tax Act, 1961. The assessee had filed a revised income tax return and restated financial statements, which were not considered by the Assessing Officer and the NFAC. The assessee argued that the additions were arbitrary and in violation of the principle of natural justice. The Tribunal found that the NFAC erred in making additions without issuing an enhancement notice as mandated by section 251(2) of the Act.

Decision in favour of

Assessee

Legal Issues

  • 1. Addition of Rs. 146,24,18,751/- to Book Profit by Ld. AO
  • 2. Addition by Ld. CIT(A) of Rs. 613,51,23,330/- to Book Profit on account of Income Tax Paid/Payable
  • 3. Addition by Ld. CIT(A) of Rs. 15479,03,84,000/- to Book Profit on account of Reserves / Provisions as at 31.03.2019

Judgment Outcome

Decided in favour of Assessee.

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