Case Law Details
ITO Vs Bharat Auto Tech Private Limited (ITAT Hyderabad)
Introduction: In the realm of income tax disputes, the recent case between the Income Tax Officer (ITO) and Bharat Auto Tech Private Limited, as adjudicated by the Income Tax Appellate Tribunal (ITAT) in Hyderabad, stands out as a complex and significant legal battle. At the heart of the matter is the order issued by the Commissioner of Income Tax (Appeals) [CIT(A)], National Faceless Appeal Centre (NFAC), Delhi, dated 22nd March 2023. The appeal filed by the Revenue challenges this order, which invoked proceedings under section 144 r.w.s. 142(1) of the Income Tax Act, 1961.
Detailed Analysis:
1. Background and Timeline: The appeal filed by the Revenue faced a significant hurdle—being barred by limitation due to a 40-day delay. To proceed, a condonation petition was submitted, citing reasons for the delay. Despite this delay, the ITAT deemed it appropriate to admit the appeal for a comprehensive hearing.
2. Grounds Raised by Revenue: The core grievances of the Revenue were outlined in two crucial grounds:
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