Income Tax Officer Ward-2, Chitradurga V. M/s The Hiriyur Urban Co-operative Bank Limited , Chitradurga

ITA 2042/BANG/2018

• Counselvise Citation: [2019] 117 COUNSELVISE.COM (IT) 6026 (ITAT-BANGALORE)
• Duration Of Justice: 10 month(s) 16 day(s)
• Appeal Type: Income Tax (Transfer Pricing) Appeal
• Pronouncement Date: 01-05-2019
• Appeal Filed By: Department
• Order Result: Dismissed
• Bench Allotted: C
• Assessment Year: 2014-2015
• Appeal Filed On: 15-06-2018
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: M NARSIMHA RAJU
• Keywords: Tax effect

Judgement Text

IN THE INCOME TAX APPELLATE TRIBUNAL BANGALORE BENCH C BEFORE SHRI N. V. VASUDEVANV, JUDICIAL MEMBER AND SHRI A. K. GARODIA, ACCOUNTANT MEMBER I.T.A. NOS. 2040 TO 2042/BANG/2018 (ASSESSMENT YEARS : 2012 13 TO 2014 - 15) THE INCOME TAX OFFICER, WARD - 2, APPELLANT CHITRADURGA. VS. M/S. THE HIRIYUR URBAN CO OPERATIVE BANK LIMITED, NEHRU CIRCLE, MAIN ROAD, HIRIYUR, CHITRADURGA DISTRICT. PAN AAAAT3575E RESPONDENT ASSESSEE BY : SHRI SURESH MUTHUKRISHNAN, C. A. RE VENUE BY : S HRI M. NARSIMHA RAJU, JC IT ( DR ) DATE OF HEARING : 01.08.2018 DATE OF PRONOUNCEMENT : 0 3.08.2018 O R D E R PER SHRI A. K. GARODIA, A.M. : ALL THESE THREE APPEALS ARE FILED BY THE REVENUE FO R A. Y. 2012 13, 2014 15. THESE APPEALS ARE DIRECTED AGAINST THREE SEPARATE O RDERS OF THE CIT (A) DAVANGERE, DATED 22.02.2018 FOR A. Y. 2012 13 & 2 013 14 AND DATED 27.02.2018 FOR A. Y. 2014 15. ALL THESE APPEALS W ERE HEARD TOGETHER AND ARE BEING DISPOSED OF BY THIS COMMON ORDER FOR THE SAKE OF CONVENIENCE. 2. AT THE VERY OUTSET, IT WAS SUBMITTED BY HE LEARN ED AR OF THE ASSESSEE THAT IN EACH OF THESE APPEALS, THE TAX EFFECT IS BELOW RS. 20 LACS AND THEREFORE, AS PER THE CBDT INSTRUCTIONS AS PER CIRCULAR NO. 3/2018 DA TED 11.07.2018, THESE APPEALS OF THE REVENUE ARE NOT MAINTAINABLE. LEARN ED DR OF THE REVENUE HAD NOTHING TO SAY. 3. WE HAVE CONSIDERED THE SUBMISSIONS OF THE LEARNE D AR OF THE ASSESSEE AND WE ALSO FIND THAT IN EACH OF THESE APPEALS, THE TAX EFFECT IS BELOW RS. 20 LACS 2 ITA NOS. 2040 TO 2042/BANG/2018 AND THEREFORE, AS PER THE CBDT INSTRUCTIONS AS PER CIRCULAR NO. 3/2018 DATED 11.07.2018, THESE APPEALS OF THE REVENUE ARE NOT MA INTAINABLE. ACCORDINGLY, THESE THREE APPEALS OF THE REVENUE ARE DISMISSED BE CAUSE OF LOW TAX EFFECT. 4. IN THE RESULT, ALL THREE APPEALS OF THE REVENUE ARE DISMISSED. ORDER PRONOUNCED IN THE OPEN COURT ON THE DA TE MENTIONED ON THE CAPTION PAGE. SD/- SD/- (N. V. VASUDEVAN) (A. K. GARODIA) JUDICIAL MEMBER ACCOUNTANT MEMBER BANGALORE, DATED: 03.08.2018. MS* COPY TO: 1. APPELLANT 4. CIT(A) 2. RESPONDENT 5. DR, ITAT, BANGALORE 3. CIT 6. GUARD FILE BY ORDER SENIOR PRIVATE SECRETARY, INCOME TAX APPELLATE TRIBUNAL, BANGALORE.