Tarun Bhalla Vs ACIT, International Taxation, Circle-1(1)(2), New Delhi

Parties Involved

Facts Summary

This appeal pertains to the assessment year 2016-17, where the assessee, Tarun Bhalla, contested the assessment order dated 19.03.2024 issued by the ACIT, Circle-1(1)(2), International Taxation, Delhi. The order was framed following the directions of the Dispute Resolution Panel (DRP)-2, New Delhi dated 14.02.2024, in proceedings under sections 147 and 144 of the Income Tax Act, 1961. The primary issue in the case is the assessee’s status as an 'eligible assessee' under section 144C(15)(b)(ii) of the Act. The lower authorities had treated the assessee as an 'eligible assessee' for passing a 'draft' order on 31.05.2023, which was upheld in principle by the DRP’s directions and culminated in the assessment order dated 19.03.2024. The assessee’s original return declared him as a resident, a fact that was accepted in the assessment order.…

Legal Issues

• 1. Whether the assessee is an 'eligible assessee' under section 144C(15)(b)(ii) of the Income Tax Act, 1961.

Judgment Outcome

Decided in favour of Assessee.

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