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Sical Iron Ore Terminal (Mangalore) ... vs Acit, Chennai on 15 June, 2017

Ld. AR further relied on the decision of ITAT, Bench 'C', Chennai in the case of Sical Logistics Ltd. Vs. ACIT reported in 127 ITD 5 ITA No.972/Del./2010 187 (Chennai)(TM) where it has been held that entire annual accounts were before the Assessing Officer and the annual accounts can be the basis to make enquiries into various aspects wherever the Assessing Officer feels necessary to do so. The Assessing Officer has also not made summary assessments and had enquired into various details. The Assessing Officer did not feel it necessary to call for details in respect of matters the Commissioner of Income Tax deemed necessary to call. The Third Member noted that it is a matter of perception which varies from person to person and it is who is the Assessing Officer the adjudicator as well as investigator and therefore it is his perception which counts and not that of Commissioner of Income Tax.
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