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2. The factual background in which the aforesaid substantial questions of law arise for consideration in this appeal need mention. The assessee is a public limited company and is engaged in numerous business and industrial activity including computer software development and exports and computer hardware manufacture and sale. The assessee filed its return of income on 30.11.2006 for Assessment Year 2006-07. A draft order of assessment was passed on 31.12.2009. The assessee thereupon filed objections before Dispute Resolution Panel, which upheld the order of the Assessing Officer by an order dated 27.09.2010. On the basis of directions issued by before Dispute Resolution Panel, the Assessing Officer passed a final order of assessment on 28.10.2010. The assessee thereupon filed an appeal, before the Income Tax Appellate Tribunal (hereinafter referred to as 'the tribunal' for short).