Revenue Can Challenge Issue in Later Years if Earlier Non-Filing Was Due to Inadvertence: Delhi HC

PCIT Vs Samsung India Electronics Pvt. Ltd. (Delhi High Court) In , the Delhi High Court considered a preliminary objection raised by the respondent-assessee in an appeal filed by the Revenue concerning allowability of remuneration paid to expatriate employees. The respondent argued that the Income Tax Appellate Tribunal (ITAT), while deciding the present matter, had relied upon its earlier order dated 31.08.2020 for Assessment Year (AY) 2014-15 passed in the assessee’s own case. It was submitted that the Revenue, while challenging the Tribunal’s order for AY 2014-15 before the High Court ...