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Showing contexts for: essel in The Pr.Commissioner Of Income Tax-6 vs Essel Corporate Resources P.Ltd. on 11 December, 2025Matching Fragments
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Order dated 11TH December 2025 ITXA no. 3292 of 2018 PCIT vs. Essel Corporate 1835/MUM/2017 filed by the Assessee and Appeal No. 3364/MUM/2017 filed by the Revenue. By the impugned order, the Assessee's Appeal was partly allowed for statistical purposes whilst the Revenue's Appeal was dismissed.
3. Prior thereto, in exercise of the power under Section 263 of the Act, the PCIT had considered and recorded his findings on four grounds of
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Order dated 11TH December 2025 ITXA no. 3292 of 2018 PCIT vs. Essel Corporate appeal that were raised before him from the Assessment Order dated 30 th March 2016 (AO) passed under Section 143(3) of the Act. As already stated above, for the purposes of the present Income Tax Appeal, we are called upon to consider ground no. 3 raised in the said appeal which related to the disallowance of Rs.2,09,73,983/- by the ITO under Section 14A of the Act r/w. Rule 8D of the Rules. After considering the arguments of both parties, the PCIT recorded a finding in favour of the Assessee and allowed the said ground of appeal no. 3. The reasons for allowing this ground of appeal found favour with the Tribunal as can be seen from the impugned order. Accordingly, by the said order dated 10 th February 2017, the PCIT had partly allowed the Appeal filed by the Assessee.
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Order dated 11TH December 2025 ITXA no. 3292 of 2018 PCIT vs. Essel Corporate
5. Per contra, Mr. Jay Bhansali, learned Counsel for the Respondent - Assessee submitted that the present Appeal does not raise any substantial question of law inasmuch as the PCIT has recorded detailed findings on the issue relating to the disallowance under Section 14A r/w. Rule 8D and thereafter set aside the AO. The Tribunal has confirmed the said order passed by the PCIT.
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Order dated 11TH December 2025 ITXA no. 3292 of 2018 PCIT vs. Essel Corporate disallowance claimed by the Assessee and both the PCIT and the Tribunal, have found that the working made by the ITO was done mechanically, without justification and contrary to the provisions of the Act.