PROCTER AND GUMBLE HOME PRODUCTS PRIVATE LIMITED (EARLIER PROCTER AND GUMBLE HOME PRODUCTS LIMITED) vs INCOME TAX APPEALLATE TRIBUNAL THOROUGH THE REGISTRAR

SAYYED 1. Income Tax Appellate Tribunal Through the REgistrar, Pratiksha Bhavan, 3rd and 4th floor, M.K.Road, Mumbai-400020 2. Deputy Commissioner of Income-tax Circle-2(3)(1), Mumbai, Room No.552, 5th floor, Aayakar Bhavan, Maharshi Karve Road, Mumbai-400020 3. Union of India Through Joint Secretary and Legal Adviser, Branch Secretariat, Department of Legal Affairs, Ministry of Law and Justice, 2nd floor, Aayakar Bhavan, M.K.Road, New Marine Lines, Mumbai-400020 …Respondents ______________________________________________________ Mr P J Pardiwalla Senior Advocate a/w Mr Harsh Kapadia i/by Mr Atul Jasani, for the Petitioner. Mr Abhishek Mishra, for the Respondent/Revenue. ______________________________________________________ 2 1.WP.1960.23.docx CORAM M.S. Sonak & Jitendra Jain, JJ. DATED: 24 February 2025 ORAL JUDGMENT (Per M.S.Sonak, J.) :- 1. Heard learned counsel for the parties. 2. Rule. The rule is made returnable immediately at the request of and with the consent of learned counsel for the parties. 3. The petitioner-assessee questions the impugned order dated 2 September 2022, made by the Income Tax Appellate Tribunal (ITAT) under Section 254(1) of the Income Tax Act, 1961 (t