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



M/s Gmr Energy Trading Limited v/s Deputy Commissioner of Income Tax


Company & Directors' Information:- GMR ENERGY LIMITED [Active] CIN = U85110MH1996PLC274875

Company & Directors' Information:- H-ENERGY PRIVATE LIMITED [Active] CIN = U40300MH2007PTC175626

Company & Directors' Information:- GMR ENERGY TRADING LIMITED [Active] CIN = U31200KA2008PLC045104

Company & Directors' Information:- T AND D TRADING PRIVATE LIMITED [Active] CIN = U51909MH2003PTC142712

Company & Directors' Information:- A A ENERGY LIMITED [Active] CIN = U40100MH2005PLC157604

Company & Directors' Information:- A R L TRADING PRIVATE LIMITED [Active] CIN = U67120DL2005PTC143941

Company & Directors' Information:- K M ENERGY PRIVATE LIMITED [Active] CIN = U40300UP2014PTC067293

Company & Directors' Information:- I. B. TRADING PRIVATE LIMITED [Active] CIN = U70102MH2007PTC167894

Company & Directors' Information:- R. R. ENERGY LIMITED [Active] CIN = U40109CT2004PLC016580

Company & Directors' Information:- ENERGY INDIA CORPORATION LIMITED [Strike Off] CIN = U40101MH2008PLC181157

Company & Directors' Information:- G W TRADING PRIVATE LIMITED [Active] CIN = U51900MP2013PTC031025

Company & Directors' Information:- B & S ENERGY PRIVATE LIMITED [Active] CIN = U40108KA2008PTC048416

Company & Directors' Information:- D K O TRADING COMPANY PVT LTD [Converted to LLP and Dissolved] CIN = U51226WB1992PTC054818

Company & Directors' Information:- G-TRADING INDIA PRIVATE LIMITED [Active] CIN = U52100DL2008PTC228572

Company & Directors' Information:- A. N. TRADING PRIVATE LIMITED [Active] CIN = U51900DL2019PTC359069

Company & Directors' Information:- L G H TRADING PRIVATE LIMITED [Active] CIN = U52100MH2009PTC196493

Company & Directors' Information:- G K TRADING PVT LTD [Active] CIN = U51109WB1990PTC048559

Company & Directors' Information:- S P R TRADING PRIVATE LIMITED [Converted to LLP] CIN = U18109DL1995PTC071372

Company & Directors' Information:- S N R TRADING COMPANY PVT. LTD. [Active] CIN = U51909WB1986PTC041568

Company & Directors' Information:- M. E ENERGY PRIVATE LIMITED [Active] CIN = U51503PN1998PTC114226

Company & Directors' Information:- L. S. G. TRADING PRIVATE LIMITED [Strike Off] CIN = U51900MH1994PTC079829

Company & Directors' Information:- H C TRADING PRIVATE LIMITED [Active] CIN = U51909WB1997PTC085250

Company & Directors' Information:- H T C TRADING PVT. LTD. [Active] CIN = U51433WB1990PTC049243

Company & Directors' Information:- P P S TRADING COMPANY PRIVATE LIMITED [Amalgamated] CIN = U29120GJ1997PTC032617

Company & Directors' Information:- K ENERGY COMPANY LIMITED [Active] CIN = U40100CT2007PLC020433

Company & Directors' Information:- IN TRADING PRIVATE LIMITED [Active] CIN = U51399DL2003PTC119199

Company & Directors' Information:- D M TRADING PVT LTD [Active] CIN = U51909WB1986PTC040744

Company & Directors' Information:- B H TRADING PRIVATE LIMITED [Active] CIN = U51909MH2005PTC151768

Company & Directors' Information:- M T TRADING COMPANY PVT LTD [Amalgamated] CIN = U52110WB1991PTC051822

Company & Directors' Information:- U R ENERGY (INDIA) PRIVATE LIMITED [Active] CIN = U40108GJ2011PTC067834

Company & Directors' Information:- J K TRADING COMPANY PRIVATE LIMITED [Active] CIN = U51432AS2001PTC006676

Company & Directors' Information:- B & G ENERGY PRIVATE LIMITED [Active] CIN = U40107TN2006PTC061362

Company & Directors' Information:- H F TRADING PRIVATE LIMITED [Active] CIN = U51101MP2013PTC031441

Company & Directors' Information:- K L TRADING COMPANY PRIVATE LIMITED [Active] CIN = U74899DL1989PTC035081

Company & Directors' Information:- K T TRADING COMPANY PRIVATE LIMITED [Active] CIN = U29265MH1954PTC009417

Company & Directors' Information:- J C I ENERGY PRIVATE LIMITED [Converted to LLP] CIN = U40102KA2011PTC058550

Company & Directors' Information:- ENERGY INDIA LIMITED [Strike Off] CIN = U74899DL1998PLC096211

Company & Directors' Information:- T S P M TRADING COMPANY PRIVATE LIMITED [Strike Off] CIN = U15400TN2009PTC070424

Company & Directors' Information:- L M TRADING COMPANY PVT LTD [Active] CIN = U24232WB1986PTC040212

Company & Directors' Information:- N E TRADING COMPANY LIMITED [Active] CIN = U51909ML2000PLC006095

Company & Directors' Information:- W W TRADING PRIVATE LIMITED [Active] CIN = U51909MH2003PTC140832

Company & Directors' Information:- J S TRADING COMPANY PVT LTD [Active] CIN = U51909WB1992PTC057003

Company & Directors' Information:- S B H TRADING COMPANY PRIVATE LIMITED [Active] CIN = U52339KA2008PTC045790

Company & Directors' Information:- M L TRADING COMPANY PVT LTD [Strike Off] CIN = U52110WB1988PTC044086

Company & Directors' Information:- S B J TRADING (INDIA) PRIVATE LIMITED [Active] CIN = U51900MH2005PTC158498

Company & Directors' Information:- INDIA ENERGY PRIVATE LIMITED. [Strike Off] CIN = U74899DL2000PTC103993

Company & Directors' Information:- M N TRADING COMPANY PRIVATE LIMITED [Active] CIN = U51505MH2004PTC146652

Company & Directors' Information:- J C R TRADING PVT LTD [Active] CIN = U51909KL1990PTC005614

Company & Directors' Information:- V G K TRADING PRIVATE LIMITED [Active] CIN = U52100KL1997PTC011691

Company & Directors' Information:- S D R TRADING PRIVATE LIMITED [Active] CIN = U51109DL2009PTC188954

Company & Directors' Information:- G L TRADING CO. PRIVATE LIMITED [Active] CIN = U51219WB1998PTC086558

Company & Directors' Information:- L J TRADING PRIVATE LIMITED [Active] CIN = U51909UP2007PTC045996

Company & Directors' Information:- C AND D TRADING COMPANY PRIVATE LIMITED [Strike Off] CIN = U51900MH1981PTC025335

Company & Directors' Information:- V ENERGY PRIVATE LIMITED [Active] CIN = U40102TG2011PTC073693

Company & Directors' Information:- Y V TRADING PRIVATE LIMITED [Strike Off] CIN = U29113MH2006PTC159994

Company & Directors' Information:- R U TRADING PRIVATE LIMITED [Active] CIN = U52390WB2009PTC136748

Company & Directors' Information:- J R P TRADING COMPANY PRIVATE LIMITED [Strike Off] CIN = U51900MH1998PTC113202

Company & Directors' Information:- P AND CO TRADING INDIA PRIVATE LIMITED [Strike Off] CIN = U18101KL1999PTC013423

Company & Directors' Information:- P A T TRADING PRIVATE LIMITED [Active] CIN = U52190WB2009PTC137537

Company & Directors' Information:- R N K TRADING CO. PRIVATE LIMITED [Active] CIN = U45202PB2006PTC029721

Company & Directors' Information:- S M M ENERGY PRIVATE LIMITED [Active] CIN = U40109TG2014PTC092679

Company & Directors' Information:- D. N. TRADING PRIVATE LIMITED [Strike Off] CIN = U52390WB2009PTC138180

Company & Directors' Information:- U AND I TRADING PRIVATE LIMITED [Strike Off] CIN = U52399DL1989PTC035654

Company & Directors' Information:- J V TRADING PRIVATE LIMITED [Strike Off] CIN = U51909DL2005PTC132481

Company & Directors' Information:- C & C ENERGY PRIVATE LIMITED [Active] CIN = U29299DL2010PTC204724

Company & Directors' Information:- K R L TRADING PRIVATE LIMITED [Active] CIN = U51109WB2008PTC128889

Company & Directors' Information:- K P TRADING & COMPANY PRIVATE LIMITED [Active] CIN = U51503AN2012PTC000169

Company & Directors' Information:- U S G ENERGY PRIVATE LIMITED [Active] CIN = U29307TZ2005PTC012414

Company & Directors' Information:- V. S. L. TRADING PRIVATE LIMITED [Active] CIN = U51909WB2009PTC139374

Company & Directors' Information:- A J TRADING PVT LTD [Active] CIN = U51491WB1988PTC045107

Company & Directors' Information:- C R TRADING CO LTD [Under Process of Striking Off] CIN = U65993WB1980PLC032526

Company & Directors' Information:- A B T ENERGY PRIVATE LIMITED [Active] CIN = U40108KA1983PTC005321

Company & Directors' Information:- S V S TRADING INDIA PRIVATE LIMITED [Strike Off] CIN = U15549TN2001PTC047343

Company & Directors' Information:- A AND P TRADING COMPANY PVT LTD [Strike Off] CIN = U52100KL1990PTC005630

Company & Directors' Information:- D B P TRADING PRIVATE LIMITED [Active] CIN = U52390GJ2010PTC060765

Company & Directors' Information:- A & T ENERGY PRIVATE LIMITED [Strike Off] CIN = U40106GJ2012PTC070207

Company & Directors' Information:- A K TRADING COMPANY PRIVATE LIMITED [Active] CIN = U51392CH1995PTC016355

Company & Directors' Information:- G R B TRADING PRIVATE LIMITED [Active] CIN = U15142KA1998PTC023508

Company & Directors' Information:- R K AND F TRADING PRIVATE LIMITED [Active] CIN = U74999WB2020PTC239455

Company & Directors' Information:- S B TRADING PVT LTD [Under Liquidation] CIN = U10200WB1985PTC038857

Company & Directors' Information:- T S TRADING PRIVATE LIMITED [Active] CIN = U28910DL2001PTC109621

Company & Directors' Information:- K E ENERGY PRIVATE LIMITED [Strike Off] CIN = U40300TN2011PTC080288

Company & Directors' Information:- T J F TRADING PRIVATE LIMITED [Under Process of Striking Off] CIN = U52190KL2010PTC025848

Company & Directors' Information:- R N S TRADING PRIVATE LIMITED [Active] CIN = U52300MH2009PTC194233

Company & Directors' Information:- A. C. TRADING PRIVATE LIMITED [Converted to LLP] CIN = U51909WB2011PTC163103

Company & Directors' Information:- V S M TRADING PRIVATE LIMITED [Active] CIN = U51909DL2005PTC133777

Company & Directors' Information:- L. R. A. TRADING PRIVATE LIMITED [Under Process of Striking Off] CIN = U51109DL2010PTC202451

Company & Directors' Information:- L. B. L. TRADING PRIVATE LIMITED [Strike Off] CIN = U74140DL2010PTC202203

Company & Directors' Information:- S H A M TRADING PRIVATE LIMITED [Strike Off] CIN = U51420MH2001PTC131774

Company & Directors' Information:- F B TRADING PVT LTD [Active] CIN = U65921WB1988PTC045315

Company & Directors' Information:- K. R. B. TRADING PRIVATE LIMITED [Active] CIN = U51101UP2010PTC040779

Company & Directors' Information:- M Y TRADING COMPANY PRIVATE LIMITED [Strike Off] CIN = U16008UP1997PTC022161

Company & Directors' Information:- C M TRADING CO PVT LTD [Amalgamated] CIN = U51909WB1982PTC034578

Company & Directors' Information:- V A R ENERGY INDIA PRIVATE LIMITED [Strike Off] CIN = U40300TG2014PTC095926

Company & Directors' Information:- L N TRADING CO PVT LTD [Active] CIN = U29303WB1954PTC021587

Company & Directors' Information:- S M S R TRADING PRIVATE LIMITED [Strike Off] CIN = U51909WB2015PTC206593

Company & Directors' Information:- R N D TRADING COMPANY PRIVATE LIMITED [Strike Off] CIN = U51109DL2001PTC111762

Company & Directors' Information:- C & N ENERGY PRIVATE LIMITED [Strike Off] CIN = U40100KL2011PTC028837

Company & Directors' Information:- F J TRADING PRIVATE LIMITED [Active] CIN = U74999TG2020PTC142069

Company & Directors' Information:- M K D ENERGY PRIVATE LIMITED [Active] CIN = U31908UP2015PTC070501

Company & Directors' Information:- B N S TRADING PRIVATE LIMITED [Strike Off] CIN = U20299KA2006PTC039202

Company & Directors' Information:- K J TRADING CO PVT LTD [Strike Off] CIN = U52341KL1974PTC002616

Company & Directors' Information:- A D TRADING PRIVATE LIMITED [Active] CIN = U51909DL2002PTC114529

Company & Directors' Information:- U S TRADING PRIVATE LIMITED [Under Process of Striking Off] CIN = U65993MH2000PTC129562

Company & Directors' Information:- C I T L ENERGY PRIVATE LIMITED [Strike Off] CIN = U40108TG2010PTC066844

Company & Directors' Information:- C R B ENERGY PRIVATE LIMITED [Active] CIN = U40108TG2010PTC066845

Company & Directors' Information:- T. B. TRADING LIMITED [Converted to LLP] CIN = U51909WB2017PLC220095

Company & Directors' Information:- F D M TRADING INDIA PRIVATE LIMITED [Active] CIN = U74899DL1994PTC059248

Company & Directors' Information:- N R TRADING CO PVT LTD [Active] CIN = U51909WB1985PTC039045

Company & Directors' Information:- M K H TRADING PRIVATE LIMITED [Strike Off] CIN = U52100KA2011PTC061028

Company & Directors' Information:- J S ENERGY PRIVATE LIMITED [Active] CIN = U45202HP2006PTC030006

Company & Directors' Information:- G S B TRADING PRIVATE LIMITED [Strike Off] CIN = U52110TG1979PTC002524

Company & Directors' Information:- T V G ENERGY PRIVATE LIMITED [Strike Off] CIN = U52100UP2014PTC066243

Company & Directors' Information:- C N TRADING PRIVATE LIMITED [Active] CIN = U91200UP1998PTC023690

Company & Directors' Information:- C P M TRADING COMPANY PVT LTD [Active] CIN = U51909KL1992PTC006517

Company & Directors' Information:- S R TRADING PRIVATE LIMITED [Under Process of Striking Off] CIN = U74899DL1996PTC082994

Company & Directors' Information:- THE INDIA TRADING CORPORATION PVT LTD [Strike Off] CIN = U51900WB1930PTC018891

Company & Directors' Information:- P N C TRADING CO PVT LTD [Active] CIN = U74999WB1961PTC025286

Company & Directors' Information:- G G ENERGY PRIVATE LIMITED [Strike Off] CIN = U74899DL1994PTC058590

Company & Directors' Information:- G T E TRADING COMPANY PRIVATE LIMITED [Strike Off] CIN = U52203CH1996PTC018873

Company & Directors' Information:- A. L. A TRADING PRIVATE LIMITED [Active] CIN = U51909WB2010PTC145269

Company & Directors' Information:- S V G S TRADING PRIVATE LIMITED [Strike Off] CIN = U51432TN2006PTC059766

Company & Directors' Information:- P J M TRADING (INDIA) PRIVATE LIMITED [Active] CIN = U51900MH2005PTC158475

Company & Directors' Information:- V G ENERGY PRIVATE LIMITED [Strike Off] CIN = U40100MH2005PTC156544

Company & Directors' Information:- D R R ENERGY PRIVATE LIMITED [Active] CIN = U40102TN2009PTC073741

Company & Directors' Information:- Q - ENERGY PRIVATE LIMITED [Strike Off] CIN = U74920WB2012FTC182047

Company & Directors' Information:- K P TRADING CO PVT LTD [Active] CIN = U51909WB1980PTC032804

Company & Directors' Information:- S A N I L TRADING PRIVATE LIMITED [Strike Off] CIN = U51909WB2003PTC096166

Company & Directors' Information:- M V TRADING COMPANY PRIVATE LIMITED [Strike Off] CIN = U51229CH1995PTC016293

Company & Directors' Information:- J P TRADING PVT LTD [Strike Off] CIN = U74899DL1978PTC008976

Company & Directors' Information:- U AND I TRADING COMPANY PRIVATE LIMITED [Strike Off] CIN = U51109DL1982PTC013848

Company & Directors' Information:- D S TRADING PRIVATE LIMITED [Strike Off] CIN = U74950MH1997PTC106883

Company & Directors' Information:- A N M TRADING PRIVATE LIMITED [Active] CIN = U36999MH2000PTC124380

Company & Directors' Information:- R. K. B. L. TRADING CO. PRIVATE LIMITED [Strike Off] CIN = U51498UP2008PTC035444

Company & Directors' Information:- P S F TRADING PRIVATE LIMITED [Active] CIN = U70100MH2001PTC132895

Company & Directors' Information:- H G TRADING COMPANY PRIVATE LIMITED [Strike Off] CIN = U51909DL2005PTC142359

Company & Directors' Information:- V U TRADING PRIVATE LIMITED [Converted to LLP] CIN = U51909MH2005PTC154698

Company & Directors' Information:- F. N. TRADING COMPANY PRIVATE LIMITED [Strike Off] CIN = U52520TG1997PTC026240

Company & Directors' Information:- Y G TRADING COMPANY PRIVATE LIMITED [Strike Off] CIN = U51909DL2004PTC126325

Company & Directors' Information:- T C E TRADING PRIVATE LIMITED [Strike Off] CIN = U51909MN2014PTC008375

Company & Directors' Information:- H R ENERGY PRIVATE LIMITED [Strike Off] CIN = U40101RJ2003PTC018712

Company & Directors' Information:- C M S TRADING PRIVATE LIMITED [Strike Off] CIN = U52100TN2010PTC075065

Company & Directors' Information:- N S M TRADING COMPANY PRIVATE LIMITED [Active] CIN = U52100TN2013PTC093966

Company & Directors' Information:- E W TRADING PRIVATE LIMITED [Strike Off] CIN = U51900TN2009PTC072688

Company & Directors' Information:- A L R TRADING PRIVATE LIMITED [Active] CIN = U52100MH2011PTC217069

Company & Directors' Information:- A. M. M. TRADING PRIVATE LIMITED [Active] CIN = U52190MH2009PTC192160

Company & Directors' Information:- O & B TRADING COMPANY PRIVATE LIMITED [Strike Off] CIN = U52399MH2009PTC191669

Company & Directors' Information:- S D D TRADING PRIVATE LIMITED [Active] CIN = U51101MH2011PTC216846

Company & Directors' Information:- M & N TRADING PRIVATE LIMITED [Strike Off] CIN = U51101MH2012PTC226366

Company & Directors' Information:- C 3 TRADING PRIVATE LIMITED [Strike Off] CIN = U51101MH2013PTC239343

Company & Directors' Information:- H. R. TRADING CO PRIVATE LIMITED [Strike Off] CIN = U51900MH2008PTC187303

Company & Directors' Information:- J R J R ENERGY PRIVATE LIMITED [Strike Off] CIN = U40100MH2005PTC153641

Company & Directors' Information:- R M ENERGY PRIVATE LIMITED [Strike Off] CIN = U40108MH2003PTC142881

Company & Directors' Information:- N M P M TRADING PRIVATE LIMITED [Strike Off] CIN = U67190MH2011PTC223812

Company & Directors' Information:- I S K TRADING COMPANY PRIVATE LIMITED [Strike Off] CIN = U51102MH2005PTC156676

Company & Directors' Information:- R T TRADING COMPANY PRIVATE LIMITED [Strike Off] CIN = U51909MH2004PTC144712

Company & Directors' Information:- A F TRADING PRIVATE LIMITED [Active] CIN = U51909MH2004PTC145877

Company & Directors' Information:- B A TRADING COMPANY PVT LIMITED [Strike Off] CIN = U51909MH2005PTC157017

Company & Directors' Information:- M G S H TRADING PRIVATE LIMITED [Strike Off] CIN = U51909MH2010PTC202602

Company & Directors' Information:- T R S TRADING PRIVATE LIMITED [Strike Off] CIN = U51909TN2005PTC057425

Company & Directors' Information:- S V E ENERGY PRIVATE LIMITED [Active] CIN = U40100TN2009PTC073738

Company & Directors' Information:- L V S ENERGY PRIVATE LIMITED [Under Process of Striking Off] CIN = U40101TG2010PTC068290

Company & Directors' Information:- A. S. R. ENERGY PRIVATE LIMITED [Strike Off] CIN = U40105TG2008PTC056907

Company & Directors' Information:- S S E ENERGY (INDIA) PRIVATE LIMITED [Strike Off] CIN = U40108TG2014PTC093709

Company & Directors' Information:- K & H ENERGY PRIVATE LIMITED [Strike Off] CIN = U40109AP2012PTC079162

Company & Directors' Information:- P & S ENERGY PRIVATE LIMITED [Strike Off] CIN = U40109TG2011PTC072632

Company & Directors' Information:- V V G TRADING COMPANY PRIVATE LIMITED [Active] CIN = U51101UP2013PTC055642

Company & Directors' Information:- F & S TRADING PRIVATE LIMITED [Active] CIN = U51101UP2016PTC076033

Company & Directors' Information:- S P P TRADING PRIVATE LIMITED [Strike Off] CIN = U72900TN2011PTC081006

Company & Directors' Information:- C J TRADING PRIVATE LIMITED [Active] CIN = U74999UP2011PTC047020

Company & Directors' Information:- P D TRADING COMPANY PVT LTD [Active] CIN = U51101WB1988PTC045612

Company & Directors' Information:- G R B S TRADING PRIVATE LIMITED [Strike Off] CIN = U51101WB2013PTC195208

Company & Directors' Information:- L D TRADING (INDIA) PVT LTD [Active] CIN = U51909WB1977PTC031291

Company & Directors' Information:- P A ENERGY PRIVATE LIMITED [Strike Off] CIN = U40100HP2006PTC030328

Company & Directors' Information:- S & G ENERGY PRIVATE LIMITED [Strike Off] CIN = U31101CH2010PTC032133

Company & Directors' Information:- N V TRADING COMPANY PRIVATE LIMITED [Active] CIN = U74899DL1989PTC038507

Company & Directors' Information:- A V N TRADING PRIVATE LIMITED [Active] CIN = U74899DL1993PTC055186

Company & Directors' Information:- A T TRADING COMPANY PRIVATE LIMITED [Strike Off] CIN = U51909DL2003PTC120282

Company & Directors' Information:- R S O TRADING COMPANY PVT LTD [Strike Off] CIN = U51909DL2001PTC111180

Company & Directors' Information:- S K K TRADING PRIVATE LIMITED [Strike Off] CIN = U51909DL2004PTC129251

Company & Directors' Information:- D H TRADING PRIVATE LIMITED [Strike Off] CIN = U51909DL2009PTC193683

Company & Directors' Information:- N B TRADING COMPANY PRIVATE LIMITED [Strike Off] CIN = U51909DL2010PTC206948

Company & Directors' Information:- D S K INDIA TRADING PRIVATE LIMITED [Under Process of Striking Off] CIN = U51909DL2013PTC261249

Company & Directors' Information:- P M S ENERGY INDIA PRIVATE LIMITED [Active] CIN = U74999DL2012PTC236645

Company & Directors' Information:- V P TRADING PRIVATE LIMITED [Strike Off] CIN = U51311DL1998PTC096692

Company & Directors' Information:- R S L TRADING COMPANY PRIVATE LIMITED [Converted to LLP] CIN = U51311DL2002PTC115846

Company & Directors' Information:- V. K. S. TRADING PRIVATE LIMITED [Active] CIN = U51391DL2013PTC253989

Company & Directors' Information:- A B K S TRADING PRIVATE LIMITED [Active] CIN = U51395DL2004PTC124676

Company & Directors' Information:- R. H. M. TRADING PRIVATE LIMITED [Strike Off] CIN = U74900DL2009PTC189283

Company & Directors' Information:- D M ENERGY PRIVATE LIMITED [Strike Off] CIN = U40107DL2010PTC199110

Company & Directors' Information:- S K S ENERGY PRIVATE LIMITED [Strike Off] CIN = U40108DL2003PTC119741

Company & Directors' Information:- C P ENERGY PRIVATE LIMITED [Strike Off] CIN = U40109DL2010PTC204395

Company & Directors' Information:- 3 A S ENERGY PRIVATE LIMITED [Strike Off] CIN = U40300DL2013PTC250263

Company & Directors' Information:- T K TRADING PRIVATE LIMITED [Strike Off] CIN = U52300DL2011PTC224440

Company & Directors' Information:- N & Y TRADING PRIVATE LIMITED [Under Process of Striking Off] CIN = U52590DL2015PTC280124

Company & Directors' Information:- N A TRADING PRIVATE LIMITED [Strike Off] CIN = U85100DL2011PTC218986

Company & Directors' Information:- P & R TRADING PRIVATE LIMITED [Strike Off] CIN = U51909BR2013PTC019940

Company & Directors' Information:- A AND M TRADING CO PVT LTD [Strike Off] CIN = U27109AP1988PTC008440

Company & Directors' Information:- I S R ENERGY PRIVATE LIMITED [Under Process of Striking off] CIN = U40103AP2012PTC084585

Company & Directors' Information:- T AND F ENERGY PRIVATE LIMITED [Active] CIN = U40100MP2011PTC026065

Company & Directors' Information:- B B TRADING PRIVATE LIMITED [Strike Off] CIN = U74900HR2014PTC051539

Company & Directors' Information:- V V ENERGY PRIVATE LIMITED [Active] CIN = U40101KA2008PTC046429

Company & Directors' Information:- E P C ENERGY PRIVATE LIMITED [Strike Off] CIN = U40107KA2010PTC053645

Company & Directors' Information:- H D P TRADING PRIVATE LIMITED [Strike Off] CIN = U51101GJ2015PTC084637

Company & Directors' Information:- R K P TRADING COMPANY PRIVATE LIMITED [Active] CIN = U51109GJ2011PTC067760

Company & Directors' Information:- R J ENERGY PRIVATE LIMITED [Active] CIN = U40100GJ2009PTC056990

Company & Directors' Information:- I ENERGY PRIVATE LIMITED [Active] CIN = U40100GJ2009PTC058473

Company & Directors' Information:- TRADING CORPN PVT LTD [Active] CIN = U67120KL1942PTC001187

Company & Directors' Information:- G O N TRADING PVT. LTD. [Strike Off] CIN = U51909GJ1986PTC008700

Company & Directors' Information:- B D S TRADING PRIVATE LIMITED [Strike Off] CIN = U51909GJ1988PTC010531

Company & Directors' Information:- B C P TRADING COMPANY INDIA PRIVATE LIMITED [Strike Off] CIN = U51109AS1996PTC004917

Company & Directors' Information:- T S V TRADING PRIVATE LIMITED [Strike Off] CIN = U01130DL1997PTC087349

Company & Directors' Information:- I. D. TRADING PRIVATE LIMITED [Strike Off] CIN = U52100MH2007PTC172346

Company & Directors' Information:- K. M. K. TRADING CO. PRIVATE LIMITED [Strike Off] CIN = U52100MH2007PTC173912

Company & Directors' Information:- J D TRADING COMPANY PRIVATE LIMITED [Strike Off] CIN = U51900MH1965PTC013396

Company & Directors' Information:- G S B D TRADING PRIVATE LIMITED [Strike Off] CIN = U51109MH2008PTC187094

Company & Directors' Information:- E G TRADING PRIVATE LIMITED [Strike Off] CIN = U52520TG2006PTC049739

Company & Directors' Information:- C S TRADING CO PVT LTD [Strike Off] CIN = U51311WB1956PTC023150

    ITA No. 2065/Bang of 2018

    Decided On, 20 November 2018

    At, Income Tax Appellate Tribunal Bangalore

    By, THE HONOURABLE MR. N.V. VASUDEVAN
    By, VICE PRESIDENT & THE HONOURABLE MR. INTURI RAMA RAO
    By, ACCOUNTANT MEMBER

    For the Appellant: Sunil Jain, CA. For the Respondent: Dr. P.V. Pradeep Kumar, Addl CIT(DR).



Judgment Text

Inturi Rama Rao, AM:

1. This is an appeal filed by the assessee directed against the order of the ld. Commissioner of Income-tax (Appeals)-3, Bengaluru, dated 16/05/2018 for the assessment year 2015-16.

2. Briefly, the facts of the case are as under: The assessee is a company incorporated under the provisions of the Companies Act 1956. It is engaged in the business of trading in electricity power. The return of income for the assessment year 2015-16 was filed on 30th September 2015 declaring income under normal provisions after set off of brought forward business loss of Rs.7,33,43,364/- and returning book profits under section 115 JB of the Income-tax Act, 1961 [hereinafter referred to as 'the Act' for short] of Rs.50,17,461/-. The return of income was taken for scrutiny assessment and the assessment was completed accepting the returned income. However, during the course of assessment proceedings, the assessee, vide letter dated 11/11/2016 submitted a revised computation of business profits under section 115 JB. The difference between the returned book profits and the revised statement is an account of claim for deduction of the amount of loss brought forward and unabsorbed depreciation whichever is less as per books of account. This claim was not considered by the Assessing Officer.

3. Being aggrieved, an appeal was preferred before the ld.CIT(A) who, vide impugned order, had not allowed the claim placing reliance on the decision of the Hon'ble Supreme Court in the case of Goetze (India) Ltd. vs CIT (284 ITR 323)(SC).

4. Being aggrieved, the assessee is before us raising the following grounds of appeal:

5. The issue in the present appeal is whether the claim made during assessment proceedings can be considered by AO when no such claim was made in return of income, is covered by the decision of the co-ordinate bench of Delhi in the case of The Kangra Co- operative Bank Ltd. vs. JCIT in ITA No.840/Del/2013 & 1432/Del/2012 dated 16/10/2015 (authored by the Hon'ble Accountant Member), in favour of assessee, wherein it has been held as follows:

"5.4 We heard the rival submissions and perused the material on record. The Assessing Officer disallowed this claim for deduction of bonus paid of Rs.19,49,792/- which was disallowed for the assessment year 2009-10 on payment basis during the year under appeal on the ground that the claims were not made by filing the revised return of income. The reasoning of the Assessing Officer cannot stand the test of the law laid down by several High Courts. The Hon'ble Gujarat High Court in the case of CIT Vs. Mitesh Impex, 225 Taxman 168 (Gujarat) after review of entire law on the income, held as follows:

"30. In what manner and to what extent, a ground, a legal contention or a fresh claim can be made at an appellate stage are vexed questions and have occupied the minds of the Courts in numerous occasions.

31. In the case of Jute Corpn. of India Ltd. v. CIT [1991] 187 ITR 688 the Supreme Court noted with approval observation of the Court in the case of CIT v. Kanpur Coal Syndicate [1964] 53 ITR 225 to the effect that "The Appellate Assistant Commissioner, therefore, has plenary powers in disposing of appeal. The scope of his power is co-terminus with that of the Income-tax Officer. He can do what the Income-tax Officer can do and also direct him to do what he has failed to do." It was observed that there was no reason why the appellate authority cannot modify the assessment order on an additional ground even if not raised before the Income- tax Officer. The Act does not place any restriction or limitation on the exercise of appellate power. It was observed that:--

"The above observations are squarely applicable to the interpretation of section 251(1)(a) of the Act. The declaration of law is clear that the power of the Appellate Assistant Commissioner is co-terminus with that of the Income-tax ITA No. Officer, if that be so, there appears to be no reason as to why the appellate authority cannot modify the assessment order on an additional ground even if not raised before the Income-tax Officer. No exception could be taken to this view as the Act does not place any restriction or limitation on the exercise of appellate power. Even otherwise an Appellate Authority while hearing appeal against the order of a subordinate authority has all the powers which the original authority may have in deciding the question before it subject to the restrictions or limitations if any prescribed by the statutory provisions. In the absence of any statutory provision the Appellate Authority is vested with all the plenary powers which the subordinate authority may have in the matter. There appears to be no good reason and none was placed before us to justify curtailment of the power of the Appellate Assistant Commissioner in entertaining an additional ground raised by the assessee in seeking modification of the order of assessment passed by the Income-tax Officer."

32. In case of National Thermal Power Co. Ltd. v. CIT [1998] 229 ITR 383 (SC) when the question of law was raised for the first time before the Tribunal though facts were already on record, the Supreme Court observed that there is no reason why the assessee should be prevented from raising such a question before the Tribunal for the first time so long as the relevant facts are on record in respect of the item concerned. There is no reason to restrict the power of the Tribunal in such appeal only to decide the grounds which arise from the order of Commissioner (Appeals). The Tribunal should not be prevented from considering the questions of law arising in assessment proceedings although not raised earlier.

33. In case of Goetze (India) Ltd. (supra) the Supreme Court distinguished the judgment in the case of National Thermal Power Co. Ltd. (supra) on the ground that the same pertained to the power of the Tribunal under section 254 of the Act to entertain a point of law for the first time and commented that such decision does not relate to the power of the assessing officer to entertain a claim for deduction otherwise than by filing a revised return. In the process the Supreme Court recognized that a new claim could not be entertained by the assessing officer without the assessee revising the return. While doing so it was clarified that:--

"4. . . However, we make it clear that the issue in this case is limited to the power of the assessing authority and does not impinge on the power ITA Nos. 840/Del/2013 & 1432/Del/2012 of the Income-tax Appellate Tribunal under section 254 of the Income-tax Act, 1961. There shall be no order as to costs."

34. In the case of CIT v. Jai Parabolic Springs Ltd. [2008] 306 ITR 42/172 Taxman 258 (Delhi), the Delhi High Court held that there is no prohibition on the powers of the Tribunal to entertain an additional ground which according to the Tribunal arose in the matter and for just decision of the case.

35. In case of CIT v. Pruthvi Brokers & Shareholders (P.) Ltd. [2012] 349 ITR 336/208 Taxman 498/23 taxmann.com 23 (Bom.) the Bombay High Court considered the issue at considerable length and held that Commissioner (Appeals) as well as the Tribunal have the jurisdiction to consider the additional claim and not merely additional legal submissions. The appellate authorities have discretion to permit such additional claims. Such claims need not be those which became available on account of change of circumstances of law but which were even available when the return was filed.

36. The Delhi High Court once again in recent judgment in the case of CIT v. Sam Global Securities Ltd. [2014] 360 ITR 682/[2013] 38 taxmann.com 129 observed that the Courts have taken a pragmatic view and not a technical one as to what is required to be determined in taxable income. In that sense assessment proceedings are not adversarial in nature. With these observations Court confirmed the view of the Tribunal reversing the decision of the assessing officer rejecting the claim of the assessee on the ground that no revised return was filed.

37. In case of CIT v. Cellulose Products of India Ltd. [1985] 151 ITR 499 (Guj.), Full Bench of this Court held that merely because a ground has not been raised though it could have been raised in support of the relief sought in the appeal, it cannot be said that such ground cannot be raised before the Tribunal. Such ground can be raised provided it falls within the contours of the subject matter of the appeal.

38. It thus becomes clear that the decision of the Supreme Court in the case of Goetze (India) Ltd. (supra) is confined to the powers of the assessing officer and accepting a claim without revised return. This is what Supreme Court observed in the said judgment while distinguishing the judgment in the case of National Thermal Power Co. Ltd.(supra) and that is how various High Courts have viewed the dictum of the decision in the case of Goetze (India) Ltd.(supra). When it comes to the power of Appellate Commissioner or the Tribunal, the Courts have recognized their jurisdiction to entertain a new ground or a legal contention. A ground would have a reference to an argument touching a question of fact or a ITA Nos. 840/Del/2013 & 1432/Del/2012 question of law or mixed question of law or facts. A legal contention would ordinarily be a pure question of law without raising any dispute about the facts. Not only such additional ground or contention, the Courts have also, as noted above, recognized the powers of the Appellate Commissioner and the Tribunal to entertain a new claim for the first time though not made before the assessing officer. Income-tax proceedings are not strictly speaking adversarial in nature and the intention of the Revenue would be to tax real income.

39. This is primarily on the premise that if a claim though available in law is not made either inadvertently or on account of erroneous belief of complex legal position, such claim cannot be shut out for all times to come, merely because it is raised for the first time before the appellate authority without resorting to revising the return before the assessing officer."

5.5 Thus, in the above cases, it has been held that new claims can always be made at any stage of appellate proceedings. The law laid down by Hon'ble Apex Court in the c

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ase of Goetz India Ltd (supra) is not applicable to the claim made either before Commissioner of Income Tax (Appeals) or Income Tax Appellate Tribunal. In the light of above pronouncement, the Hon'ble Gujarat High Court after reviewing the entire case law on this issue had clearly laid down "there is no bar to entertain new claim either by Commissioner of Income Tax (Appeals) or Income Tax Appellate Tribunal". Accordingly, respectfully following the above Rulings, we direct the Assessing Officer to allow this claim after due verification, whether the bonus has been paid during the previous year under consideration, and whether the interest claim of Rs. 2,55,233/- is tax free or not. Accordingly, this ground of appeal is set aside to the file of the Assessing Officer to allow the claim, in the aforesaid terms." Respectfully following the above decision, we remit this issue back to the file of the ld.CIT(A) to adjudicate the claim in accordance with law after affording due opportunity of being heard to the assessee. 6. In the result, the appeal filed by the assessee is treated as allowed for statistical purposes.
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