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The Commissioner Of Income Tax vs M/S.Hi Tech Arai Limited on 1 September, 2009

4.3 At the outset, the Ld.Counsel for the assessee stated that neither the AO nor the DRP has considered this issue independently and the ld.Counsel argued that the Hon'ble Madras High Court in the case of CIT v. Hi Tech Ara Ltd. reported in [2010] 321 ITR 477 (Madras) [01.09.2009], has categorically held that, once the incorrect decision of earlier years, cannot ITA No.652/Chny/2016 :- 6 -:

Commissioner Of Income Tax Ltu vs M/S Everest Kanto Cylinder Ltd. on 28 October, 2020

2.4 We noted that this issue is covered by the decision of the Hon'ble Bombay High Court in the case of CIT v. Everest Kanto Cylinder Ltd. (378 ITR 57) (Bombay HC), wherein, the Libor + 200 bps point is accepted at the bench mark and hence, respectfully following the same, we upheld the order of the AO/TPO. This issue of the assessee is dismissed.
Supreme Court - Daily Orders Cites 0 - Cited by 11 - Full Document

M/S. Honeywell Automation India Ltd.,, ... vs Deputy Commissioner Of Income-Tax,, ... on 19 July, 2019

has relaxed condition in regard to number of days of employment of new employees. Once, one has interpreted the provision and held the same as retrospective, no contrary decision was pointed out by the Revenue before us. Respectfully following the decision of the Hon'ble High Court of Karnataka in the case of Texas Instruments India (P.) Ltd. (supra), we in principle allow the claim of the assessee, but subject to verification by the AO. The AO will carry out the verification in terms of amendment bringing the provisions of Sec.80JJAA of the Act, and then will consider the eligibility of claim of deduction. Accordingly, appeal is allowed, but for verification purpose remanded back.
Income Tax Appellate Tribunal - Pune Cites 11 - Cited by 1 - Full Document
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