TNS INDIA PRIVATE LIMITED Vs. UNION OF INDIA

JUDGEMENT

(1.) The challenge in these two writ petitions are the consequential orders dtd. 20/4/2018 issued by the respondent No.3/The Deputy Commissioner of Income Tax-2 under Sec. 254 read with Sec. 143 of the Income Tax Act, 1961, (for short the "Act") for the assessment year 2006-2007 and the impugned rectification order dtd. 12/10/2018 issued by the respondent No.2/The Assistant Commissioner of Income Tax under Sec. 154 of the Act for the same assessment year. For convenience, W.P.No.853 of 2019 is taken up, so far as the facts are concerned.

(2.) Heard Mr.Deepak Chopra, learned counsel appearing on behalf of Mr.Narendar Chetty, learned counsel for the petitioner and Ms. K. Mamata Choudary, learned counsel for the respondent-Department.

(3.) The whole dispute in the two writ petitions originates from an order passed by the Income Tax Appellate Tribunal (for short the "Tribunal") in ITA No.108/Hyd/2011 for the assessment year 2006-2007. The Tribunal vide order dtd. 27/6/2014 had partly allowed an appeal of the petitioner/assesse.