that notice which is quashed by the Income Tax Appellate Tribunal (ITAT)
and the order of the ITAT has been upheld by the High Court ... order, which was against the assessee, it preferred further appeal to
the ITAT. In the appeal before the ITAT, the assessee raised additional
ground questioning
which were dismissed. However, further appeals
before the Income Tax Appellate Tribunal (ITAT) were allowed and
the ITAT held that the expenditure ... treated as the revenue
expenditure. Against the order of the ITAT, the Department went
in appeal before the High Court of Allahabad which has allowed
Income Tax
Appellate Tribunal (hereinafter referred to as the ‘ITAT’) in the case of
Sedco Forex International Inc. dismissed the appeal of the assessee ... mobilisation charges
were concerned. In the case of Transocean Offshore Inc., the ITAT
upheld the view taken by the assessee and directed
challenged the same in appeal before the ITAT in which the Revenue
succeeded. The ITAT reversed the orders of the CIT(A) and restored that ... Assessing Officer. The ITAT observed that they found ample force
in the contention of the Revenue to the effect that the machinery had
outlived
SIKRI, J.
1. By the impugned order, learned Income Tax Appellate Tribunal
(ITAT) has affirmed the order of the Commissioner of Income
Tax(Appeals ... addition was
deleted.
ITA 783/2007 Page 4 of 13
5. The ITAT found that these are the findings of facts recorded
against
the impugned order dated 2nd July, 2010 passed by the ITAT. The
following substantial questions of law are being raised for our
consideration ... 2011 Page 1 of 16
" (a) Whether ITAT was correct in law and
on facts in deleting the
additions/disallowance made
persuade this Court to refer the matter back to the ITAT
and decide this issue afresh in the light of the objections filed ... alternative and main focus of attack
on the findings of ITAT rested on question of law no.3, we will first deal
with that question
well as by the
Department with the Income-Tax Appellate Tribunal (ITAT). A Special Bench
was constituted wherein these appeals were taken up alongwith appeals ... question and tax due had not been deducted at
source?
5. The ITAT decided appeals of all the assessees by a common judgment dated
passed by the Income-Tax appellate Tribunal (hereinafter referred
to as the ITAT), 5 appeals are filed by the assessee and 12 appeals ... Singapore Company and his order
has been affirmed by the ITAT as well. Insofar as assessment year 2000-
01 is concerned, against the declared income
reopened and by common order of CIT (A) as well as ITAT , the
validity of notice of reopening the assessment has been upheld.
Therefore ... relying upon the reasons given by the CIT
(A) as well as ITAT in conforming the authority of the notice under
Section 147 read with
