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14. Man Truck & Bus India Pvt Ltd vs. The Assessment Unit, Income-Tax Department & Ors.
[WRIT PETITION NO. 5437 OF 2025 Dated: 09/09/2025. (Bom) (HC)]
Penalty 270 A - Writ - Alternate remedy- No virtual hearing was given to the Petitioner as mandated by the Faceless Penalty (Amendment) Scheme, 2022: AY 2017-18
On 30th November 2017, the Petitioner had filed its return of income declaring its income as “NIL” after a set-off of the brought forward loss of ₹17.14 Crores. Thereafter, assessment proceedings were completed; and an order was passed on 24th June 2021 under section 143(3) r.w.s 144C (3) of the Act making an addition of ₹31.15 crores, on account of a Transfer Pricing Adjustment.Being aggrieved by this order, the Petitioner preferred an Appeal before the CIT (Appeals). The Petitioner had filed its Advanced Pricing Agreement Application with the CBDT as far back as on 26th March 2014, which finally culminated in the APA on
21st December 2021 during the pendency of the Appeal. The APA applied to A.Y. 2011-12 to A.Y. 2018-19. Since the APA was entered into between the Petitioner and the CBDT, under the provisions of section 92CD(1), the Petitioner filed its modified Return of Income on
