w w w . L a w y e r S e r v i c e s . i n



FIS Global Business Solutions India Pvt. Ltd. v/s Principal Commissioner of Income Tax-3, New Delhi & Another


Company & Directors' Information:- FIS GLOBAL BUSINESS SOLUTIONS INDIA PRIVATE LIMITED [Active] CIN = U72900DL1997PTC088532

Company & Directors' Information:- B N GLOBAL PRIVATE LIMITED [Active] CIN = U15400PB2014PTC038543

Company & Directors' Information:- E 2 E SOLUTIONS PRIVATE LIMITED [Active] CIN = U72200DL2000PTC107313

Company & Directors' Information:- K V GLOBAL PRIVATE LIMITED [Active] CIN = U24100DL2014PTC263567

Company & Directors' Information:- GLOBAL CORPORATION LIMITED [Active] CIN = L74999DL1992PLC048880

Company & Directors' Information:- E-SOLUTIONS PRIVATE LIMITED [Active] CIN = U30007TN1999PTC043325

Company & Directors' Information:- FIS SOLUTIONS (INDIA) PRIVATE LIMITED [Active] CIN = U72200PN1993PTC151736

Company & Directors' Information:- FIS SOLUTIONS (INDIA) PRIVATE LIMITED [Active] CIN = U72200DL1993PTC330116

Company & Directors' Information:- T & I GLOBAL LTD. [Active] CIN = L29130WB1991PLC050797

Company & Directors' Information:- J. H. BUSINESS (INDIA) LIMITED [Amalgamated] CIN = U24293DL1999PLC099782

Company & Directors' Information:- D S R SOLUTIONS LIMITED [Active] CIN = U72200TG1999PLC032008

Company & Directors' Information:- K G GLOBAL PRIVATE LIMITED [Active] CIN = U74999DL2000PTC104788

Company & Directors' Information:- A. V. GLOBAL CORPORATION PRIVATE LIMITED [Active] CIN = U63090DL2007PTC159315

Company & Directors' Information:- J. K. SOLUTIONS PRIVATE LIMITED [Active] CIN = U74999MH2014PTC257168

Company & Directors' Information:- GLOBAL BUSINESS SOLUTIONS LIMITED [Active] CIN = U22100KA2005PLC036141

Company & Directors' Information:- GLOBAL SOLUTIONS PRIVATE LIMITED [Active] CIN = U74899DL1988PTC031541

Company & Directors' Information:- GLOBAL BUSINESS INDIA PRIVATE LIMITED [Amalgamated] CIN = U16008DL1999PTC100758

Company & Directors' Information:- E-3 SOLUTIONS INDIA PRIVATE LIMITED [Active] CIN = U74910DL1998PTC096512

Company & Directors' Information:- A N GLOBAL LIMITED [Active] CIN = U92110MH1985PLC035269

Company & Directors' Information:- D S GLOBAL PRIVATE LIMITED [Active] CIN = U74899DL1995PTC071516

Company & Directors' Information:- G B BUSINESS LIMITED [Active] CIN = U51109WB1983PLC036744

Company & Directors' Information:- A B C GLOBAL PRIVATE LIMITED [Active] CIN = U51909PB2011PTC035103

Company & Directors' Information:- P C INDIA LIMITED [Strike Off] CIN = U33111TN1986PLC013401

Company & Directors' Information:- V A SOLUTIONS PRIVATE LIMITED [Active] CIN = U72200TG2006PTC049266

Company & Directors' Information:- D P SOLUTIONS (INDIA) PRIVATE LIMITED [Strike Off] CIN = U22221DL2000PTC107837

Company & Directors' Information:- R P BUSINESS PRIVATE LIMITED [Active] CIN = U74210AS2000PTC006302

Company & Directors' Information:- S N M BUSINESS PRIVATE LIMITED [Active] CIN = U51109WB1997PTC085308

Company & Directors' Information:- P R S BUSINESS PVT LTD [Active] CIN = U63090WB1992PTC056995

Company & Directors' Information:- N Q SOLUTIONS INDIA PRIVATE LIMITED [Active] CIN = U51909OR2009PTC011136

Company & Directors' Information:- I A T GLOBAL COMPANY PRIVATE LIMITED [Active] CIN = U24116DL1997PTC084916

Company & Directors' Information:- J D GLOBAL PRIVATE LIMITED [Active] CIN = U51909DL1997PTC091270

Company & Directors' Information:- IN-SOLUTIONS GLOBAL LIMITED [Active] CIN = U72200MH2004PLC146704

Company & Directors' Information:- IN-SOLUTIONS GLOBAL PRIVATE LIMITED [Active] CIN = U72200MH2004PTC146704

Company & Directors' Information:- M L B BUSINESS PRIVATE LIMITED [Active] CIN = U51109WB2000PTC091878

Company & Directors' Information:- GLOBAL SOLUTIONS (INDIA) PRIVATE LIMITED [Active] CIN = U72900KA1997PTC022166

Company & Directors' Information:- J F C BUSINESS LTD [Active] CIN = U17125WB1990PLC048495

Company & Directors' Information:- B N G GLOBAL INDIA LIMITED [Active] CIN = U52590DL2011PLC225377

Company & Directors' Information:- A TO Z BUSINESS (INDIA) PRIVATE LIMITED [Under Process of Striking Off] CIN = U51909TZ2008PTC014261

Company & Directors' Information:- N K COMPANY (GLOBAL) PRIVATE LIMITED [Active] CIN = U52390WB2010PTC153624

Company & Directors' Information:- K B K GLOBAL PRIVATE LIMITED [Active] CIN = U24296DL2016PTC290487

Company & Directors' Information:- I. S. SOLUTIONS PRIVATE LIMITED [Active] CIN = U30007TG1997PTC028047

Company & Directors' Information:- GLOBAL E-SOLUTIONS LIMITED [Strike Off] CIN = U45201TN1994PLC028155

Company & Directors' Information:- S V BUSINESS PVT LTD [Active] CIN = U27310WB1984PTC038146

Company & Directors' Information:- R R BUSINESS PRIVATE LIMITED [Active] CIN = U74999WB2007PTC176588

Company & Directors' Information:- L T SOLUTIONS PRIVATE LIMITED [Strike Off] CIN = U72200TG2000PTC033248

Company & Directors' Information:- M R BUSINESS PRIVATE LIMITED [Active] CIN = U51109WB1994PTC064165

Company & Directors' Information:- M & D GLOBAL PRIVATE LIMITED [Active] CIN = U31101UP1974PTC003937

Company & Directors' Information:- J C BUSINESS PRIVATE LIMITED [Active] CIN = U55101AS2009PTC008974

Company & Directors' Information:- V R GLOBAL PRIVATE LIMITED [Active] CIN = U45200WB2007PTC120797

Company & Directors' Information:- D & B BUSINESS PRIVATE LIMITED [Active] CIN = U51909PB2010PTC033901

Company & Directors' Information:- L D SOLUTIONS PRIVATE LIMITED [Active] CIN = U51109DL2015PTC286921

Company & Directors' Information:- THE INDIA COMPANY PRIVATE LIMITED [Active] CIN = U74999TN1919PTC000911

Company & Directors' Information:- A S SOLUTIONS PRIVATE LIMITED [Active] CIN = U74140DL2010PTC202208

Company & Directors' Information:- M M GLOBAL PRIVATE LIMITED [Strike Off] CIN = U29120WB1986PTC041280

Company & Directors' Information:- R V GLOBAL PRIVATE LIMITED [Active] CIN = U74990MH2009PTC195301

Company & Directors' Information:- M M C GLOBAL INDIA PRIVATE LIMITED [Strike Off] CIN = U11200MH2010PTC206910

Company & Directors' Information:- S R GLOBAL PRIVATE LIMITED [Strike Off] CIN = U51109WB1997PTC084553

Company & Directors' Information:- H V GLOBAL PRIVATE LIMITED [Active] CIN = U18101DL2000PTC103960

Company & Directors' Information:- R P GLOBAL PRIVATE LIMITED [Strike Off] CIN = U74990MH2009PTC193409

Company & Directors' Information:- M S GLOBAL PRIVATE LIMITED [Active] CIN = U70100MH2008PTC213273

Company & Directors' Information:- R S V GLOBAL LIMITED [Strike Off] CIN = U51909DL1994PLC059032

Company & Directors' Information:- I S P SOLUTIONS INDIA PRIVATE LIMITED [Active] CIN = U72200TZ2001PTC009755

Company & Directors' Information:- S P E-SOLUTIONS PRIVATE LIMITED [Active] CIN = U72300DL2006PTC155569

Company & Directors' Information:- P N S BUSINESS PRIVATE LIMITED [Active] CIN = U74140WB2005PTC101643

Company & Directors' Information:- M S BUSINESS PRIVATE LIMITED [Active] CIN = U51909MH1997PTC111137

Company & Directors' Information:- J S B BUSINESS PVT LTD [Active] CIN = U27109WB1996PTC078319

Company & Directors' Information:- R S BUSINESS SOLUTIONS PRIVATE LIMITED [Active] CIN = U74140DL2006PTC150819

Company & Directors' Information:- T X G SOLUTIONS PRIVATE LIMITED [Converted to LLP and Dissolved] CIN = U72200DL2006PTC150671

Company & Directors' Information:- H D SOLUTIONS PRIVATE LIMITED [Active] CIN = U72900DL2009PTC194392

Company & Directors' Information:- N B GLOBAL (INDIA) PRIVATE LIMITED [Active] CIN = U15122UP2012PTC051614

Company & Directors' Information:- H & K SOLUTIONS PRIVATE LIMITED [Active] CIN = U63040GJ2009PTC059027

Company & Directors' Information:- A V S BUSINESS PRIVATE LIMITED [Strike Off] CIN = U31908UP2010PTC040437

Company & Directors' Information:- F A S T SOLUTIONS (INDIA) PRIVATE LIMITED [Active] CIN = U22100MH1989PTC052935

Company & Directors' Information:- N AND S SOLUTIONS PRIVATE LIMITED [Active] CIN = U74210KA1999PTC025555

Company & Directors' Information:- U-TO SOLUTIONS (INDIA) PRIVATE LIMITED [Active] CIN = U72100MH2000PTC130052

Company & Directors' Information:- Z D SOLUTIONS PRIVATE LIMITED [Strike Off] CIN = U72900TN2007PTC062584

Company & Directors' Information:- O AND M SOLUTIONS PRIVATE LIMITED [Active] CIN = U74210OR2005PTC008166

Company & Directors' Information:- A C BUSINESS PRIVATE LIMITED [Strike Off] CIN = U45208MH2009PTC197088

Company & Directors' Information:- R P A S SOLUTIONS PRIVATE LIMITED [Active] CIN = U72200TG2008PTC057538

Company & Directors' Information:- J A J GLOBAL BUSINESS PRIVATE LIMITED [Strike Off] CIN = U24232KA2012PTC065587

Company & Directors' Information:- G L F SOLUTIONS PRIVATE LIMITED [Strike Off] CIN = U67190KL2013PTC035455

Company & Directors' Information:- S P SOLUTIONS PRIVATE LIMITED [Amalgamated] CIN = U72200DL2011PTC213318

Company & Directors' Information:- V K BUSINESS PVT LTD [Active] CIN = U21012WB1996PTC079121

Company & Directors' Information:- S. S. G. SOLUTIONS PRIVATE LIMITED [Active] CIN = U72200TG1996PTC023719

Company & Directors' Information:- INDIA CORPORATION PRIVATE LIMITED [Active] CIN = U65990MH1941PTC003461

Company & Directors' Information:- I T SOLUTIONS INDIA PRIVATE LIMITED [Active] CIN = U72200DL1996PTC076426

Company & Directors' Information:- K P BUSINESS SOLUTIONS PRIVATE LIMITED [Active] CIN = U67190MH2008PTC180357

Company & Directors' Information:- S P A BUSINESS PVT LTD [Strike Off] CIN = U29296WB1990PTC050043

Company & Directors' Information:- D R V BUSINESS SOLUTIONS PRIVATE LIMITED [Strike Off] CIN = U72200KA2011PTC060623

Company & Directors' Information:- A R G BUSINESS SOLUTIONS PRIVATE LIMITED [Converted to LLP] CIN = U74140DL2008PTC182604

Company & Directors' Information:- S S R BUSINESS SOLUTIONS PVT LTD [Strike Off] CIN = U74140WB2006PTC109483

Company & Directors' Information:- K B SOLUTIONS PRIVATE LIMITED [Strike Off] CIN = U74140PB2011PTC035055

Company & Directors' Information:- M B BUSINESS SOLUTIONS PRIVATE LIMITED [Strike Off] CIN = U51391TN2006PTC058586

Company & Directors' Information:- A D BUSINESS PRIVATE LIMITED [Active] CIN = U74900MH2008PTC178245

Company & Directors' Information:- G AND G BUSINESS SOLUTIONS PRIVATE LIMITED [Active] CIN = U74999TG2011PTC075549

Company & Directors' Information:- A V R BUSINESS PRIVATE LIMITED [Active] CIN = U74992UP2008PTC034629

Company & Directors' Information:- H A SOLUTIONS (INDIA) PRIVATE LIMITED [Active] CIN = U72900DL2000PTC104116

Company & Directors' Information:- B AND E BUSINESS SOLUTIONS PRIVATE LIMITED [Active] CIN = U74140DL2004PTC127141

Company & Directors' Information:- C K BUSINESS PRIVATE LIMITED [Under Process of Striking Off] CIN = U51399DL2003PTC118289

Company & Directors' Information:- C AND D BUSINESS INDIA PRIVATE LIMITED [Strike Off] CIN = U52300KA2010PTC053211

Company & Directors' Information:- V. J. L. SOLUTIONS PRIVATE LIMITED [Active] CIN = U74999UP2018PTC109127

Company & Directors' Information:- 1 TO 5 SOLUTIONS PRIVATE LIMITED [Not available for efiling] CIN = U74999AS2020PTC020427

Company & Directors' Information:- C P H BUSINESS SOLUTIONS PRIVATE LIMITED [Strike Off] CIN = U72200KA1998PTC023742

Company & Directors' Information:- C AND C SOLUTIONS (INDIA) LIMITED [Strike Off] CIN = U93000PY1995PLC001144

Company & Directors' Information:- D E BUSINESS SOLUTIONS LIMITED [Strike Off] CIN = U72900MH1999PLC122852

Company & Directors' Information:- AMP SOLUTIONS LIMITED [Active] CIN = U80302CH2001PLC024420

Company & Directors' Information:- D V M SOLUTIONS LIMITED [Converted to LLP] CIN = U74140DL1999PLC102362

Company & Directors' Information:- T S SOLUTIONS PRIVATE LIMITED [Active] CIN = U72200UP2000PTC025406

Company & Directors' Information:- R R SOLUTIONS PRIVATE LIMITED [Active] CIN = U45309BR2008PTC013387

Company & Directors' Information:- B A SOLUTIONS INDIA PRIVATE LIMITED [Active] CIN = U74999DL2006PTC155492

Company & Directors' Information:- BUSINESS CORPN PRIVATE LIMITED [Strike Off] CIN = U15429UP1945PTC001335

Company & Directors' Information:- C A AND S SOLUTIONS PRIVATE LIMITED [Active] CIN = U72200AP2000PTC034546

Company & Directors' Information:- R A SOLUTIONS PRIVATE LIMITED [Active] CIN = U51101MH2013PTC249132

Company & Directors' Information:- R T W SOLUTIONS PRIVATE LIMITED [Active] CIN = U72200MH2004PTC145773

Company & Directors' Information:- I 2 S BUSINESS SOLUTIONS INDIA PRIVATE LIMITED [Strike Off] CIN = U72200TZ2005PTC011985

Company & Directors' Information:- A E T SOLUTIONS PRIVATE LIMITED [Strike Off] CIN = U72200TG2004PTC036640

Company & Directors' Information:- K N P SOLUTIONS PRIVATE LIMITED [Strike Off] CIN = U72300TG2011PTC076036

Company & Directors' Information:- I SOLUTIONS(INDIA) PRIVATE LIMITED [Strike Off] CIN = U72900TN2004PTC052692

Company & Directors' Information:- M M BUSINESS PVT LTD [Strike Off] CIN = U51909WB2005PTC106884

Company & Directors' Information:- L K BUSINESS PVT LTD [Active] CIN = U45202WB1985PTC038604

Company & Directors' Information:- T. S. GLOBAL (INDIA) BUSINESS PRIVATE LIMITED [Active] CIN = U74999DL2016PTC303396

Company & Directors' Information:- R V I T SOLUTIONS PRIVATE LIMITED [Strike Off] CIN = U72200DL2005PTC137434

Company & Directors' Information:- R M T SOLUTIONS INDIA PRIVATE LIMITED [Strike Off] CIN = U74210KA2011PTC056861

Company & Directors' Information:- E M C SOLUTIONS PRIVATE LIMITED [Strike Off] CIN = U72200KA1996PTC020112

Company & Directors' Information:- R I SOLUTIONS PRIVATE LIMITED [Strike Off] CIN = U52392WB1999PTC088640

Company & Directors' Information:- T R BUSINESS SOLUTIONS PRIVATE LIMITED [Active] CIN = U74999TN2012PTC088097

Company & Directors' Information:- L S SOLUTIONS PRIVATE LIMITED [Active] CIN = U67190DL2020PTC371664

Company & Directors' Information:- 9 I SOLUTIONS PVT LTD [Strike Off] CIN = U72200TG2005PTC048565

Company & Directors' Information:- S G SOLUTIONS PRIVATE LIMITED [Active] CIN = U74999BR2008PTC013392

Company & Directors' Information:- K P N SOLUTIONS PRIVATE LIMITED [Strike Off] CIN = U74900KA2011PTC057705

Company & Directors' Information:- BUSINESS SOLUTIONS PRIVATE LIMITED [Active] CIN = U74910WB1999PTC090820

Company & Directors' Information:- V N SOLUTIONS PRIVATE LIMITED [Strike Off] CIN = U74900DL2009PTC195421

Company & Directors' Information:- C L BUSINESS PRIVATE LIMITED [Active] CIN = U93000WB2014PTC202032

Company & Directors' Information:- R. K. SOLUTIONS PRIVATE LIMITED [Active] CIN = U74140DL2007PTC161367

Company & Directors' Information:- J K B SOLUTIONS INDIA PRIVATE LIMITED [Strike Off] CIN = U74900DL2015PTC284162

Company & Directors' Information:- S R SOLUTIONS PRIVATE LIMITED [Active] CIN = U72200HR2000PTC055629

Company & Directors' Information:- B E SOLUTIONS PRIVATE LIMITED [Active] CIN = U72200KA2005PTC037127

Company & Directors' Information:- G R K SOLUTIONS PRIVATE LIMITED [Strike Off] CIN = U72900TG2002PTC039029

Company & Directors' Information:- A. P. V. BUSINESS PRIVATE LIMITED [Strike Off] CIN = U14299RJ2017PTC058759

Company & Directors' Information:- G N SOLUTIONS PRIVATE LIMITED [Active] CIN = U65993PN2008PTC132031

Company & Directors' Information:- J .S .SOLUTIONS PRIVATE LIMITED [Active] CIN = U72900PB2007PTC030855

Company & Directors' Information:- R Z BUSINESS AND SOLUTIONS PRIVATE LIMITED [Strike Off] CIN = U72300MH2013PTC248460

Company & Directors' Information:- TAX-O-TAX SOLUTIONS PRIVATE LIMITED [Strike Off] CIN = U74120PN2004PTC020069

Company & Directors' Information:- SOLUTIONS @ PANORAMA TRAVEL PRIVATE LIMITED [Strike Off] CIN = U63040MH2010PTC199347

Company & Directors' Information:- A & J BUSINESS SOLUTIONS PRIVATE LIMITED [Active] CIN = U74900PN2015PTC155484

Company & Directors' Information:- A.N.D SOLUTIONS PRIVATE LIMITED [Active] CIN = U74999MH2013PTC244625

Company & Directors' Information:- A M GLOBAL PRIVATE LIMITED [Active] CIN = U74999MH2015PTC261061

Company & Directors' Information:- J V B BUSINESS PRIVATE LIMITED [Active] CIN = U74999MH2016PTC282145

Company & Directors' Information:- V & M SOLUTIONS PRIVATE LIMITED [Active] CIN = U74999PN2014PTC150848

Company & Directors' Information:- G K SOLUTIONS PRIVATE LIMITED [Active] CIN = U72900MH2004PTC149891

Company & Directors' Information:- G K A SOLUTIONS PRIVATE LIMITED [Active] CIN = U72900MH2004PTC150210

Company & Directors' Information:- K & S BUSINESS SOLUTIONS PRIVATE LIMITED [Active] CIN = U74120MH2013PTC246122

Company & Directors' Information:- H. R. SOLUTIONS INDIA PRIVATE LIMITED [Strike Off] CIN = U74120TG2012PTC081581

Company & Directors' Information:- U & C BUSINESS CORPORATION PRIVATE LIMITED [Strike Off] CIN = U51909TG2014PTC095129

Company & Directors' Information:- K R K BUSINESS SOLUTIONS PRIVATE LIMITED [Active] CIN = U72300TG2012PTC085156

Company & Directors' Information:- A R M G BUSINESS PRIVATE LIMITED [Strike Off] CIN = U51909UP2013PTC055405

Company & Directors' Information:- A & J GLOBAL SOLUTIONS PRIVATE LIMITED [Active] CIN = U74900TG2014PTC096042

Company & Directors' Information:- L S A GLOBAL INDIA PRIVATE LIMITED [Under Process of Striking Off] CIN = U74900TG2015PTC098308

Company & Directors' Information:- E-TAX SOLUTIONS PRIVATE LIMITED [Active] CIN = U74900TG2015PTC099401

Company & Directors' Information:- U K BUSINESS PRIVATE LIMITED [Active] CIN = U74999UP2016PTC086597

Company & Directors' Information:- S A E-SOLUTIONS PRIVATE LIMITED [Active] CIN = U72200WB2012PTC181964

Company & Directors' Information:- K. S. E-SOLUTIONS PRIVATE LIMITED [Strike Off] CIN = U74999WB2012PTC185025

Company & Directors' Information:- O S SOLUTIONS PRIVATE LIMITED [Strike Off] CIN = U93000JK2012PTC003733

Company & Directors' Information:- R L GLOBAL INDIA PRIVATE LIMITED [Strike Off] CIN = U52300HP2014PTC000764

Company & Directors' Information:- B AND P SOLUTIONS PRIVATE LIMITED [Active] CIN = U24100CH2015PTC035482

Company & Directors' Information:- A T SOLUTIONS PRIVATE LIMITED [Strike Off] CIN = U72900CH2009PTC031621

Company & Directors' Information:- R AND D SOLUTIONS PRIVATE LIMITED [Strike Off] CIN = U52392CH2010PTC032232

Company & Directors' Information:- G S L SOLUTIONS PRIVATE LIMITED [Strike Off] CIN = U72300DL2007PTC164747

Company & Directors' Information:- F K SOLUTIONS PRIVATE LIMITED [Strike Off] CIN = U72900DL2008PTC186101

Company & Directors' Information:- B. R. SOLUTIONS PRIVATE LIMITED [Active] CIN = U74140DL2002PTC116699

Company & Directors' Information:- G. M. S E-SOLUTIONS PRIVATE LIMITED [Strike Off] CIN = U74140DL2012PTC235662

Company & Directors' Information:- A N S SOLUTIONS PRIVATE LIMITED [Strike Off] CIN = U74140DL2012PTC245060

Company & Directors' Information:- S & T SOLUTIONS PRIVATE LIMITED [Strike Off] CIN = U74140DL2013PTC247089

Company & Directors' Information:- A & A BUSINESS SOLUTIONS PRIVATE LIMITED [Active] CIN = U74140DL2013PTC262803

Company & Directors' Information:- M A SOLUTIONS PRIVATE LIMITED [Active] CIN = U74140DL2014PTC265618

Company & Directors' Information:- S A N SOLUTIONS PRIVATE LIMITED [Active] CIN = U74999DL2002PTC117534

Company & Directors' Information:- F T R BUSINESS SOLUTIONS PRIVATE LIMITED [Active] CIN = U74999DL2013PTC254967

Company & Directors' Information:- L M BUSINESS SOLUTIONS PRIVATE LIMITED [Under Process of Striking Off] CIN = U74999DL2015PTC278623

Company & Directors' Information:- I G SOLUTIONS PRIVATE LIMITED [Active] CIN = U70109DL2012PTC244223

Company & Directors' Information:- S N R SOLUTIONS PRIVATE LIMITED [Active] CIN = U72100DL2011PTC216142

Company & Directors' Information:- P G I T SOLUTIONS PRIVATE LIMITED [Active] CIN = U72200DL2005PTC139469

Company & Directors' Information:- H R SOLUTIONS PRIVATE LIMITED [Strike Off] CIN = U74899DL1995PTC073143

Company & Directors' Information:- A 2 Z SOLUTIONS PRIVATE LIMITED [Strike Off] CIN = U74899DL2001PTC109658

Company & Directors' Information:- A P D SOLUTIONS PRIVATE LIMITED [Strike Off] CIN = U74900DL2013PTC249969

Company & Directors' Information:- R N BUSINESS SOLUTIONS PRIVATE LIMITED [Active] CIN = U74900DL2013PTC254975

Company & Directors' Information:- A N TAX SOLUTIONS PRIVATE LIMITED [Strike Off] CIN = U74900DL2013PTC256159

Company & Directors' Information:- GLOBAL TAX SOLUTIONS PRIVATE LIMITED [Strike Off] CIN = U74900DL2013PTC257765

Company & Directors' Information:- V R A A P SOLUTIONS PRIVATE LIMITED [Strike Off] CIN = U74950DL2014PTC271337

Company & Directors' Information:- D N GLOBAL SOLUTIONS PRIVATE LIMITED [Active] CIN = U63000DL2012PTC238872

Company & Directors' Information:- 7 O 3 BUSINESS SOLUTIONS PRIVATE LIMITED [Active] CIN = U74140HR2012PTC046085

Company & Directors' Information:- R - N - A E - SOLUTIONS PRIVATE LIMITED [Strike Off] CIN = U74900KA2008PTC045680

Company & Directors' Information:- V SOLUTIONS PRIVATE LIMITED [Strike Off] CIN = U72200KA2010PTC052832

Company & Directors' Information:- G R GLOBAL PRIVATE LIMITED [Active] CIN = U70102KA2013PTC069586

Company & Directors' Information:- N R L SOLUTIONS PRIVATE LIMITED [Strike Off] CIN = U72900KA2013PTC069148

Company & Directors' Information:- S V SOLUTIONS PRIVATE LIMITED [Strike Off] CIN = U74140GJ2007PTC051390

Company & Directors' Information:- H. E. GLOBAL PRIVATE LIMITED [Active] CIN = U72901GJ2016PTC092866

Company & Directors' Information:- N. D. GLOBAL SOLUTIONS PRIVATE LIMITED [Active] CIN = U74999GA2019PTC013951

Company & Directors' Information:- A & A SOLUTIONS PRIVATE LIMITED [Strike Off] CIN = U72200PN2008PTC131887

Company & Directors' Information:- T N B SOLUTIONS PRIVATE LIMITED [Active] CIN = U72900MH2007GAT171606

Company & Directors' Information:- H F SOLUTIONS PRIVATE LIMITED [Strike Off] CIN = U72300DL2007PTC168577

Company & Directors' Information:- K V M SOLUTIONS PRIVATE LIMITED [Strike Off] CIN = U72900DL2008PTC180136

Company & Directors' Information:- A R C O N SOLUTIONS PRIVATE LIMITED [Strike Off] CIN = U72200KL2007PTC020421

Company & Directors' Information:- T & T SOLUTIONS PRIVATE LIMITED [Strike Off] CIN = U72900GJ2007PTC051103

    W.P.(C). No. 12277 of 2018, C.M. Appl. No. 47539 of 2018

    Decided On, 16 November 2018

    At, High Court of Delhi

    By, THE HONOURABLE MR. JUSTICE S. RAVINDRA BHAT & THE HONOURABLE MR. JUSTICE PRATEEK JALAN

    For the Petitioner: Piyush Kaushik, Tanveer Zaki, Advocates. For the Respondents: Sanjay Kumar, Advocate.



Judgment Text

S. Ravindra Bhat, J.

(Open Court)

1. Issue notice. Sh. Sanjay Kumar, Advocate accepts notice. With parties’ consent, the writ petition was heard finally.

2. The assessee in its writ petition challenges a notice issued under Section 148 of the Income Tax Act (hereafter “the Act”) for Assessment Year 2011-12, complaining that the original return [which had declared Rs. 49,67,00,907/- and subsequently revised to Rs. 49,23,54,662/-] was assessed under scrutiny under Section 143(3) read with Section 144C of the Act on 31.12.2015, at Rs. 61,92,17,179/-. The impugned reassessment notice in this case was issued on 31.03.2018; subsequently, the Assessing Officer [hereafter referred to as “the AO”] furnished the “reasons for reopening the case.....” to the assessee. Those reasons inter alia states as follows :

“Reasons for reopening the case of M/s. FIS Global Business Solutions (India) Pvt. Ltd. (PAN-AAACH2815H) for the FY 2010-11 relevant to AY 2011-12:

1. Brief details of the Assessee:

The assessee company is engaged in the business of software development and outsourcing services. The assessee company filed its retum of income on 291 L2111 declaring total income at Rs. 49,67,00,970/-. Subsequently. the assessee company revised its return of income on 22.03.2013 declaring total income at Rs.49,23,54,6621-. The assessment u/s 143(3) was completed on 31.12.2015 at an income of Rs. 61,92,17,1791-.

2. Income escaping assessment:

An audit objection was received in this office in which it was stated that in the computation of income the assessee claimed and was allowed deduction of Rs.1,37,73,528/- on account of Forex gain on Certegy (Interest Income). Forex gain on interest income, being revenue nature was not an allowable deduction.

The issue is considered and on perusal of the assessment folder pertaining to2011-12 it was noticed that in the computation of income, the assessee has deducted Rs.,37,73,528/- on account of Forex gain on certegy. Further, of Rs. 1,37 ,73,52gl-. Rs. 1,40,50,4221- was an account of Foreign Exchange fluctuation gain on loan balance receivable from Certegy and Rs. 2,76,894/- was on account of Foreign Exchange fluctuation loss on Interest income on loan advanced to Certegy.

Foreign Exchange fluctuation loss of Rs. 2,76,8941- on Interest income on loan advanced to Certegy is an allowable expense being revenue in nature.

The issue of Foreign Exchange fluctuation gain of Rs.1,40,50.422/- on loan balance receivable from Certegy needs to be view in the light of applicable Accounting Standards issued by The Institute of Chartered Accountants of India (ICAI). In this respect it is imperative to note that Accounting Standard II titled 'Effects of Changes in Exchange Rates' acknowledges that forex gain is to be recorded as income. The relevant portion of the AS 11 issued by the ICAI which is applicable in this case is being reproduce below for the ready reference:

'Recognition of Exchange Diffrences

13. Exchange differences arising on the settlement of monetary items or on reporting enterprise's monetary items at rates different from those at which they were initially recorded during the period, or reported in previous financial statements, should be recognised as income or cts expenses in the period in which they arise, with the exception of exchange differences dealt with in accordance with paragraph 15.'

The aforesaid ASII was relied upon by the Hon'ble Supreme Court in Commissioner of Income Tax, Delhi vs. woodward Governer India pvt. Ltd. (2009) 13 SCC I;(2009) 312 ITR 254 (SC) I wherein the Hon'ble Court observed that under the said accounting standard "exchange differences arising on foreign currency transactions have to be recognised as income or as expense in the period in which they arise, except as stated in para 10 and para II which deals with exchange differences arising on the payment of liabilities incurred for" the purpose of acquiring fixed assets, which topic falls under section 43A of the 1961 Act!’

Further, the Hon'ble Supreme court in Sutlej cotton Mills Ltd. vs CIT [(1979) I 16 ITR 1 (SC)I observed as under:

'The law may, therefore, now be taken to be well settled that where profit or loss arises to an assessee on account of appreciation or depreciation in the value of foreign currency held by it, on conversion into another currency, such profit or loss would ordinarily be a trading profit or loss if the foreign currency is held by the assessee on revenue account or as a trading asset or as a part of circulating capital embarked in the business. But, if on the other hand, the foreign currency is held as a capital asset or as fixed capital, such profit or loss would be of capital nature.'

There is, thus. a clear requirement that the forex gain be recorded specifically as income in the financial statements. However, a perusal on the same reveals that the assessee has failed to make fair disclosure in terms of the requirements of AS 1 I and as such concealed information from the at the time of assessment.

On the above facts, I have reasons to believe that an income amounting to Rs.1,40,50,4221- has escaped assessment. In view of the above, the provisions of clause (c) of explanation 2 of section 147 are applicable to the facts of this case and this is a fit case to be reopened u/s 147 of the Act for reassessment. In this case a return of income was filed for the year under consideration and regular assessment u/s 143(3) was made on 31.12.2015. Since 4 years from the end of the relevant year has expired in this case, the requirements to initiate proceeding u/s 747 of the Act are reason to believe that income for the year under consideration has escaped assessment because of failure on the part of the assessee to disclose fully and truly all material facts necessary for his assessment for the assessment year under consideration. It is pertinent to mention here that reasons to believe that income has escaped assessment for the year under consideration have been recorded above. I have carefully considered the assessment records containing the submissions made by the assessee in response to various notices issued during the assessment proceedings and have noted that the assessee has not fully and truly disclosed all the material facts necessary for his assessment for the year under consideration. Attention in this regard is drawn to Explanation 1 to Section 147 of the Act which is being reproduced for ready reference.

"Explanation I - Production before the Assessing Officer of account books or other evidence from which material evidence could with due diligence have been discovered by the Assessing Officer will not necessarily amount to a disclosure within the meaning of the proviso."

The expression 'necessarily' means inevitably or as a matter of compelling inference. The obligation to disclose primary facts lies on the assessee. The assessee has to disclose fully and truly all material facts. The import of Explanation I was noticed in a judgement 3 Info tech Ltd. v. Assistant Commissioner of Income Tax (2010) 329 ITR 257 (Bom) in the following observations:

" ... In other words. an assessee cannot rest content merely with the production of account books or other evidence during the course of the assessment proceedings and challenge the reopening of the assessment on the ground that if the Assessing Officer were to initiate a line of enquiry he could with due diligence have arrived at material evidence. The primary obligation to disclose is on the assessee and the burden of making a full and true disclosure of material facts does not shift to the Assessing Officer. The assessee has to disclose fully and truly all material facts. Producing voluminous records before the Assessing Officer does not absolve the assessee of the obligation to disclose and the assessee, therefore, cannot be heard to say that if the Assessing officer were to conduct a further enquiry. he would come into possession of material evidence with the exercise of due diligence. An assessee cannot throw reams of paper at the Assessing Officer and rest content in the belief that the officer better beware or ignore the hidden crevices in the pointed material at his peril. .. "

Full and true disclosures must mean what the statute says. These disclosures cannot be garbled or hidden in the crevices of the documentary material which has been filed by the assessee with the Assessing Officer. The assessee must act with candour and the disclosure must be full and true. A full disclosure is a disclosure of all material facts which does not contain any hidden material or suppression of fact. A true disclosure is a disclosure which is truthful in all respects. Just as the power of the Revenue to reopen an assessment beyond a period of four years is restricted by the conditions precedent spelt out in the proviso to Section 747, equally an assessee who seeks the benefit of the proviso to Section 147 must make a full and true disclosure of all primary facts. The assessee in the present case has wrongly claimed deduction of Rs. 1.40,50.4221- on a/c of Forex Gain on Certegy which is not an allowable expense. All the necessary facts on the basis of which the claims to a deduction are founded must be disclosed. As the assesse failed to do so, reopening of the assessment is to be done on the ground that assessee has not disclosed fully and truly all material facts necessary for the assessment.”

3. It is urged that the Revenue is doing no more than re-visiting the merits of the original scrutiny assessment which it was especially barred from conducting afresh. Learned counsel relied upon the previous Division Bench’s judgment in Carlton Overseas Pvt. Ltd. v. Income Tax officer & Ors., (2009) 318 ITR 295 and Torrent Power S.E.C. Ltd. v. Assistant Commissioner of Income-Tax (2017) 392 ITR 330 (Guj), to contend that the rulings in Commissioner of Income Tax v. Kelvinator of India Ltd., 320 ITR 561 authorises review of the completed scrutiny only and only if tangible material is made available to the revenue. It is emphasised that these rulings of Carlton and Torrent (supra) have stated that a subsequent audit objection or audit reports of the Income Tax Department does not constitute objective material.

4. Learned counsel for the Revenue argued that the re-assessment notice in this case is valid and that, the amount claimed on account of forex gain, could not have been an allowable expenditure, being revenue in nature. It was further stated that an accounting standard AS 11 required disclosure of such gains, as a revenue item and not as one falling in the capital stream.

5. Carlton (supra) emphasises that reliance by the Revenue upon an audit report, cannot be considered as tangible material. The relevant extracts of that decision are as follows:

“8. Ms. Prem Lata Bansal, learned counsel appearing for the Revenue has contended that audit party can on factual basis ask for reassessment and which has, therefore, been done in the present case. It is, however, admitted by her that a mere change of opinion does not permit action under section 147/148 of the Act.

9. We find that the arguments on behalf of the petitioner are well founded and it must succeed. The audit report merely gives an opinion with regard to the non-availability of the deduction both under section 80-IA was not deducted from the profits of the business while computing deduction under section 80HHC. Clearly, therefore, there was no new or fresh material before the Assessing Officer except the opinion of the Revenue audit party.

10. Since it is

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settled law that mere change of opinion cannot form the basis for issuing of a notice under section 147/148 of the Act, therefore, we do not propose to burden out judgment with the said judgments. In fact, as stated above, counsel for the Revenue does not dispute this principle of law.” 6. This Court is of the opinion that Carlton (supra) concludes the issue in the present case; the audit objection merely is an information. As reiterated in Kelvinator (supra) by the Supreme Court, change of opinion is impermissible. The Revenue was clearly barred by provisions of Section 147/148 of the Act. 7. In the present case, the reassessment notice is solely based on an audit opinion. Having regard to the fact that the assessee’s challenge to the previous year’s re-assessment orders was successful - in FIS Global Business Solutions India Pvt. Ltd. v. ACIT 2018 (408) ITR 75 (Del), the reassessment proceedings are unsustainable. 8. In view of the above discussion, the impugned re-assessment notice dated 31.03.2018, cannot be sustained. It is hereby quashed; all consequential proceedings issued and conducted pursuant to the said re-assessment notice are also hereby quashed. 9. The writ petition is disposed of in the above terms. Pending application also stands disposed of.
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