relying upon the Hon'ble Delhi High Court judgment in
Centrica India Offshore Pvt. Ltd.', grossly erred in concluding that by
seconding ... facts between the case of the
present assessee and the case in Centrica India Offshore Pvt. Ltd. and
the broad principles laid down
opinion that
decision of Hon'ble Supreme Court in case of Centrica India
Offshore Pvt.Ltd., squarely covers issue against assessee ... upon observations of Hon'ble Delhi High Court in case of
Centrica India offshore Pvt.Ltd., reported in (2014) 364 ITR 336.
He submitted
jurisdictional Hon'ble Delhi High
Court in the case of Centrica India Offshore (P.) Ltd. vs. CIT [2014] 364 ITR 336
drawing parity between ... Trib).
d) Hon'ble Delhi High Court in the case of Centrica Indian Offshore (P)
Ltd. [2014] 41 taxamnn.com 300 (Delhi
case of
7
ITA No. 7805/Del./2017
& 2580/Del/2018
Centrica India Offshore Private Limited (2014) 44 taxmann.com
300. The Assessing Officer ... Delhi High Court in the case of Centrica India offshore private
limited (supra).
3.13 The assessee raised objection before the Learned DRP. The
Learned
provisions of section 195
will not apply.
27. Distinguishing the decision of Centrica India Offshore India Ltd
[supra], the ld. counsel for the assessee vehemently ... stated that the
decision in the case of Centrica India Offshore India Ltd was based
upon entirely different set of facts wherein in that case
decision rendered by Hon'ble Delhi High
Court in case of Centrica India Offshore P. Ltd. vs. CIT (2014)
364 ITR 336 (Delhi) proceeded ... decision of Hon'ble Delhi High Court passed in case of
Centrica India Offshore P. Ltd. (supra) and also relied upon the
decisions rendered
judgment of the Hon'ble Supreme Court in the case of Centrica India
Offshore India Pvt Ltd without appreciating the fact that the said ... decision of Hon'ble Delhi High Court in the
case of Centrica Offshore Pvt. Ltd. vs CIT bearing WP(C) No.6807/2012
provisions of
section 195 will not apply.
27. Distinguishing the decision of Centrica India Offshore India Ltd
[supra], the ld. counsel for the assessee vehemently ... stated that the
decision in the case of Centrica India Offshore India Ltd was based
upon entirely different set of facts wherein in that case
decision of the Hon'ble Delhi High
Court in case of Centrica India Offshore (P.) Ltd. Vs. CIT , [2014]
364 ITR 336 will ... decision of the Hon'ble
Jurisdictional High Court in case of Centrica India Offshore (P.)
Ltd. Vs. CIT (supra) relied upon by the departmental
taxation 17 ITR (T) 341 Chennai (2012)
dated 09/02/2012
(iii) Centrica India offshore private limited, Delhi High Court
ruling
