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Income Tax Appellate Tribunal - Mumbai

Daimler Chrysler Ag ( Now Known As ... vs Department Of Income Tax on 25 July, 2012

                                   ITA No.3560 of 2011 Daimler Chrysler AG Mumbai D Bench




            IN THE INCOME TAX APPELLATE TRIBUNAL
                       "D" Bench, Mumbai

      Before Shri B. Ramakotaiah, Accountant Member and
               Shri Amit Shukla, Judicial Member

                      ITA No.3560/Mum/2011
                      (Assessment year: 2004-05)

DDIT (IT) 1(2), 119 Scindia     Vs. Diamler Chrysler AG (now
House, Ballard Pier,                known as Diamler AG), C/o
Mumbai 400 038                      S.R. Batliboi & Co. CAS 18th
                                    Floor, Express Towers,
                                    Nariman Point,
                                    Mumbai 400021
(Appellant)                         (Respondent)

                     Department by: Shri Ritesh Misra, DR
                     Assessee by:   Shri Jitendra Suvagia

                     Date of Hearing:       25/07/2012
                     Date of Pronouncement: 31/07/2012

                              ORDER

Per B. Ramakotaiah, A.M.

This is a Revenue appeal against the order of the CIT (A)-10 Mumbai, dated 21-02-2011. Assessee was incorporated in Germany and is in the business of manufacturing and selling automobile and its parts. It has filed return of income declaring income at `7,23,24,070/- which was assessed at `8,32,79,870/- vide the order under section 143(3) dated 18.12.2006. AO levied penalty on the additions made in the assessment order. The ITAT has deleted the quantum and therefore, question of levey of penalty under section 271(1)(c) for concealment of income or furnishing of inaccurate particulars of income does not arise. The CIT (A) cancelled the penalty on the above reasons as the disallowance itself is deleted.

2. Both the Counsels agreed that the Revenue appeal cannot survive as the quantum itself on which the penalty was levied was Page 1 of 2 ITA No.3560 of 2011 Daimler Chrysler AG Mumbai D Bench deleted by the ITAT. Accordingly we uphold the order of the CIT (A) and dismiss the Revenue appeal.

3. In the result the appeal filed by the Revenue is dismissed.

Order pronounced in the open court on 31st July, 2012.

                 Sd/-                                  Sd/-
            (Amit Shukla)                        (B. Ramakotaiah)
           Judicial Member                      Accountant Member


Mumbai, dated 31st July, 2012.

Vnodan/sps

Copy to:

     1.   The   Appellant
     2.   The   Respondent
     3.   The   concerned CIT(A)
     4.   The   concerned CIT
     5.   The   DR, "D " Bench, ITAT, Mumbai

                                  By Order



                            Assistant Registrar
                       Income Tax Appellate Tribunal,
                         Mumbai Benches, MUMBAI




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