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

Judgment text excerpt

SAYYED Digitally signed by SAYYED SAEED SAEED ALI 1 1.WP.1960.23.docx ALI AHMED ALI AHMED Date: 2025.02.25 Revati ALI 14:06:53 +0530 IN THE HIGH COURT OF JUDICATURE AT BOMBAY ORDINARY ORIGINAL CIVIL JURISDICTION WRIT PETITION NO. 1960 OF 2023 Procter and Gamble Home Products Private Limited, (Earlier, Procter and Gamble Home Products Limited) P & G Plaza, Cardinal Gracias Road, Chakala, Andheri (East), Mumbai-400099 …Petitioner Versus 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 (the Act), for the assessment year 2004-05. 4. The conspectus of facts in which the above challenge arises is set out briefly hereafter: a) The petitioner is engaged in t