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This appeal concerns Assessment Year (AY) 2006-07. Via the instant appeal, the appellant/revenue seeks to assail the order dated 23.08.2013 passed by the Income Tax Appellate Tribunal [in short, "Tribunal"].Since there was a difference of opinion between the judges who comprised the division bench concerning the answers to the questions of law framed on 29.04.2014, the matter was referred to a third judge. In the first instance, the bench which rendered the decision consisted of Hon'ble Mr Justice S. Muralidhar (as he then was) and Hon'ble Ms Justice Prathiba M. Singh. 2.1 A perusal of the decision dated 17.11.2017 discloses that while Hon'ble Mr Justice S. Muralidhar answered both questions in favour of the respondent/assessee, Hon'ble Ms Justice Prathiba M. Singh took a converse view, i.e., answered the questions in favour of the appellant/revenue. The record also discloses that via the order dated 27.04.2018, the division bench stated the points of law on which they had differed while rendering their respective decisions on 17.11.2017. The relevant part of the order dated 27.04.2018 is thus extracted hereafter: A further point of law on which we have differed, and which is required to be answered by Sanjiv Khanna, J. is whether question (ii) requires to be re-framed and answered as stated by Prathiba M. Singh, J. in para 64 of her opinion? Background To render a view on the aspects adverted to in the order dated 27.04.2018, it would be necessary to capture, broadly, the backdrop in which the instant appeal was instituted in this Court. 4.1 The respondent/assessee in the AY in issue entered into transactions with certain group companies, reference to whom is made hereafter. Qua the transactions executed between the respondent/assessee and its group companies, remittances were made. However, the respondent/assessee made remittances without deducting tax at source [in short, "TAS"]. The Assessing Officer (AO) took umbrage and disallowed the deductions claimed by the respondent/assessee. The AO ordered the disallowance under Section 40(a)(i) of the Income Tax Act, 1961 [in short, "the Act"]. Mitsubishi Corporation [MC (Japan)] Japan 5,01,55,844 2 MC Metal Services Asia [MC Metal Thailand 24,09,32,203 (Thailand)] 3 Metal One Asia P. Ltd. [Metal One Singapore 10,06,99,115 (Singapore)] 4 Metal One Corporation [Metal One (Japan)] Japan 57,91,87,712 5 Mc.Tubular Inc. [Tubular (USA)] USA 11,60,956 6 Petro Diamond Corporation [Petro (Japan)] Japan 16,34,096 7 Miteni [Miteni (Japan)] Japan 51,84,250.