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Facts
The assessee filed appeals challenging reassessment proceedings and merit issues for AY 2014-15 & 2017-18. The Revenue also appealed on merit. For AY 2018-19, both parties contested the CIT(A)'s findings on deduction under Section 35(2AB). The CIT(A) quashed the reassessment proceedings for AY 2014-15 & 2017-18.
Held
For AY 2014-15 & 2017-18, the appeals were dismissed as infructuous because the reassessment proceedings were quashed. For AY 2018-19, the issue of deduction under Section 35(2AB) was restored to the Assessing Officer for fresh adjudication after ascertaining the status of approval from the prescribed authority.
Key Issues
Validity of reassessment proceedings and merit of deductions under Section 35(2AB).
Sections Cited
Section 147, Section 35(2AB)
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Income Tax Appellate Tribunal, MUMBAI BENCH “F” MUMBAI
Before: SHRI OM PRAKASH KANT & SHRI SUNIL KUMAR SINGH
As common grounds have b As common grounds have been raised in these appeals, een raised in these appeals, therefore, same were heard together and disposed off by way of this same were heard together and disposed off by way of this same were heard together and disposed off by way of this consolidated order for convenience and avoid repetition of facts. consolidated order for convenience and avoid repetition of facts. consolidated order for convenience and avoid repetition of facts.
In assessment year In assessment years 2014-15 and 2017-18, the assessee has 18, the assessee has challenged finding of Ld. CIT(A) on the validity of the reassessment challenged finding of Ld. CIT(A) on the validity of the reassessment challenged finding of Ld. CIT(A) on the validity of the reassessment proceedings as well as issue on merit, w ings as well as issue on merit, whereas hereas Revenue has challenged the order of ld CIT(A) on merit but challenged the order of ld CIT(A) on merit but in the assessment in the assessment year 2018-19, addition o addition on the merit has only been challenged been challenged both by the assessee and the Revenue. by the assessee and the Revenue.
We have heard rival submissions of parties. We have heard rival submissions of parties. We have heard rival submissions of parties. As far as assessment years 2014 2014-15 and 2017-18 are concerned concerned, before us the Ld. counsel for the assessee submitted that assessee had filed a he Ld. counsel for the assessee submitted that assessee had filed a he Ld. counsel for the assessee submitted that assessee had filed a rectification application before the Ld. CIT(A) for rectifying the rectification application before the Ld. CIT(A) for rectifying the rectification application before the Ld. CIT(A) for rectifying the impugned orders on the issue of validity of the reassessment. The impugned orders on the issue of validity of the reassessment. The impugned orders on the issue of validity of the reassessment. The Ld. counsel intimated that said rectification application of the Ld. counsel intimated that said rectification applicati Ld. counsel intimated that said rectification applicati
Jayant Agro-Organics Ltd. 3 1757 & 1758/MUM/2024 & 1757 & 1758/MUM/2024 1918, 1952 & 1915/MUM/2024 1918, 1952 & 1915/MUM/2024 assessee for quashing the reassessment proceedings u/s 147 of the assessee for quashing the reassessment proceedings u/s 147 of the assessee for quashing the reassessment proceedings u/s 147 of the Income-tax Act,1961 ( In short ‘the tax Act,1961 ( In short ‘the Act’) has been allowed by the has been allowed by the Ld. CIT(A) by way of his order dated 26.06.2024. In the Ld. CIT(A) by way of his order dated 26.06.2024. In the Ld. CIT(A) by way of his order dated 26.06.2024. In the circumstances, the assessee filed an application for withdrawing the circumstances, the assessee filed an application for with circumstances, the assessee filed an application for with appeals for AY 2014 s for AY 2014-14 and 2017-18. The relevant part of his . The relevant part of his application is reproduced as under: application is reproduced as under:
“The appellant had filed the captioned appeal before the Hon'ble The appellant had filed the captioned appeal before the Hon'ble The appellant had filed the captioned appeal before the Hon'ble Tribunal to inter alia challenge the order of the Commissioner of Tribunal to inter alia challenge the order of the Commissioner of Tribunal to inter alia challenge the order of the Commissioner of Income-tax (Appe tax (Appeals) upholding the jurisdiction of the Assessing als) upholding the jurisdiction of the Assessing Officer under section 147 of the Act. The Appellant had also filed a Officer under section 147 of the Act. The Appellant had also filed a Officer under section 147 of the Act. The Appellant had also filed a rectification application before the Commissioner of Income rectification application before the Commissioner of Income rectification application before the Commissioner of Income-tax (Appeals) and the appellant has received the order of rectification from (Appeals) and the appellant has received the order of rectification from (Appeals) and the appellant has received the order of rectification from Commissioner of Income ommissioner of Income-tax (Appeals) dated 28.06.2024 allowing the tax (Appeals) dated 28.06.2024 allowing the application application application of of of the the the appellant appellant appellant by by by quashing quashing quashing the the the reassessment reassessment reassessment proceedings u/s 147 of Income proceedings u/s 147 of Income-tax Act, 1961. Accordingly, the appellant requests that since appeal filed by the Accordingly, the appellant requests that since appeal filed by the Accordingly, the appellant requests that since appeal filed by the Appellant have becom Appellant have become infructuous, therefore the same may be treated e infructuous, therefore the same may be treated as withdrawn with liberty to refile the appeal in case, the Revenue as withdrawn with liberty to refile the appeal in case, the Revenue as withdrawn with liberty to refile the appeal in case, the Revenue challenges the order dated 28.06.2024 before the Tribunal and challenges the order dated 28.06.2024 before the Tribunal and challenges the order dated 28.06.2024 before the Tribunal and succeeds on the ground that there was no mistake in the original order succeeds on the ground that there was no mistake in the original order succeeds on the ground that there was no mistake in the original order of the Commissioner of Income Commissioner of Income-tax (Appeals).” 4.1 The Ld. counsel for the assessee he Ld. counsel for the assessee submitted that the Ld. CIT(A) that the Ld. CIT(A) has quashed the reassessment proceedings while deciding the quashed the reassessment proceedings while deciding the quashed the reassessment proceedings while deciding the rectification application. The Ld. Departmental Representative (DR) rectification application. The Ld. Departmental Representative (DR) rectification application. The Ld. Departmental Representative (DR) was asked to confirm asked to confirm whether the Revenue intends to challenge the whether the Revenue intends to challenge the said finding and matter was adjourned said finding and matter was adjourned for 10/07/2024 for 10/07/2024. However, the Ld. DR could not confirm whether any appeal was filed by the the Ld. DR could not confirm whether any appeal was filed by the the Ld. DR could not confirm whether any appeal was filed by the Revenue on this issue Revenue on this issue or intends to file therefore, in the therefore, in the circumstances, we allowe circumstances, we allowed the request of the assessee to withdraw of the assessee to withdraw these appeals being being being infructuous. infructuous. infructuous. Once, Once, Once, the the the reassessment reassessment reassessment proceedings stands quashed proceedings stands quashed by the ld CIT(A), the addition on merit the addition on merit
Jayant Agro-Organics Ltd. 4 1757 & 1758/MUM/2024 & 1757 & 1758/MUM/2024 1918, 1952 & 1915/MUM/2024 1918, 1952 & 1915/MUM/2024 also does not survive. Therefore, the appeals of also does not survive. Therefore, the appeals of both both the parties on the merit also are ren the merit also are rendered infructuous. But if the Revenue prefers dered infructuous. But if the Revenue prefers to challenge the finding of the Ld. CIT(A) to challenge the finding of the Ld. CIT(A) passed in its rectification in its rectification order dated 28.06.2024 and same is decided against the assessee order dated 28.06.2024 and same is decided against the assessee order dated 28.06.2024 and same is decided against the assessee then the appeals of the parties on the merit needs to be revived and then the appeals of the parties on the merit needs to be revive then the appeals of the parties on the merit needs to be revive to be heard in future, in future, therefore, at present we dismiss both the therefore, at present we dismiss both the appeals of the assessee and the Revenue as infructuous subject to appeals of the assessee and the Revenue as infructuous subject to appeals of the assessee and the Revenue as infructuous subject to liberty to file Miscellaneous Application for reviving the appeals liberty to file Miscellaneous Application for reviving the appeals liberty to file Miscellaneous Application for reviving the appeals challenging the grounds on merit, if hallenging the grounds on merit, if the Revenue succeeds the Revenue succeeds before the ITAT on the issue of t on the issue of the validity of the reassessment. he validity of the reassessment. Accordingly, the appeals of the assessee and the Revenue for both Accordingly, the appeals of the assessee and the Revenue for both Accordingly, the appeals of the assessee and the Revenue for both the assessment years 2014 the assessment years 2014-15 and 2017-18 are 18 are dismissed as infructuous.
19, both the parties are aggrieved 5. In assessment year 2018 In assessment year 2018-19, both the parties are aggrie with the finding of the Ld. CIT(A) in respect of deduction u/s with the finding of the Ld. CIT(A) in respect of deduction u/s with the finding of the Ld. CIT(A) in respect of deduction u/s 35(2AB) of the Act. The facts in brief qua the issue in dispute are 35(2AB) of the Act. The facts in brief qua the issue in dispute are 35(2AB) of the Act. The facts in brief qua the issue in dispute are that during assessment proceedings, the Assessing Officer observed that during assessment proceedings, the Assessing Officer observed that during assessment proceedings, the Assessing Officer observed claim of weighed deduction deduction u/s 35(2AB) of the Act at t u/s 35(2AB) of the Act at the rate of 150% of expense, both capital and revenue , incurred on in house 150% of expense, both capital and revenue , incurred on in house 150% of expense, both capital and revenue , incurred on in house research and development during the financial year 2017-18, which research and development during the financial year 2017 research and development during the financial year 2017 amounted to Rs.4,02,56,307/ Rs.4,02,56,307/-. The detail of the deduction claimed The detail of the deduction claimed is reproduced as under: is reproduced as under:
R & D Revenue Rs.2,66,14,538/- Rs.3,99,21,807/- (150%)
Jayant Agro-Organics Ltd. 5 1757 & 1758/MUM/2024 & 1757 & 1758/MUM/2024 1918, 1952 & 1915/MUM/2024 1918, 1952 & 1915/MUM/2024
R & D Capital Rs.2,23,000/- Rs.3,34,500/- (150%). (150%). Total Rs.2,68,37,538/- Rs.4,02,56,307/- (150%) Less:-Amount debited to Profit & Loss A/c Amount debited to Profit & Loss A/c Rs.2,66,14,538/- Claimed u/s 35(2AB) Claimed u/s 35(2AB)- weighted deduction Rs.1, 36,41 ,769/- - Total claim u/s 35(2AB) Total claim u/s 35(2AB)- Rs.(2,66,14,538 + 1,36,41,769) Rs.(2,66,14,538 + 1,36,41,769) Rs.4,02,56,307/- 5.1 For claiming deduction u/s 35(2AB) of the Act, the For claiming deduction u/s 35(2AB) of the Act, the For claiming deduction u/s 35(2AB) of the Act, the CBDT has prescribed Rule 6 under Income ule 6 under Income-tax Rules, 1962. The Rules 6(4) tax Rules, 1962. The Rules 6(4) prescribe that a company is required to prescribe that a company is required to file an application in form file an application in form no. 3CK to Department of Scientific and Industrial Research i.e. no. 3CK to Department of Scientific and Industrial Research no. 3CK to Department of Scientific and Industrial Research prescribed authority. Fu . Further, the Rule 6(7A) prescribes rther, the Rule 6(7A) prescribes following requirement:
“(7A)Approval (7A)Approval of of expenditure expenditure incurred incurred on on in-house in house research research and and development facility development facility by a company under sub-section (2AB) of section 35 section (2AB) of section 35 shall be subject to the following conditions, namely : shall be subject to the following conditions, namely :- (a)The facility should not relate purely to market research, sales promotion, The facility should not relate purely to market research, sales promotion, The facility should not relate purely to market research, sales promotion, quality control, quality control, testing, commercial production, style changes, routine data testing, commercial production, style changes, routine data collection or activities of a like nature; collection or activities of a like nature; (b)The prescribed authority shall furnish electronically its report, The prescribed authority shall furnish electronically its report,- The prescribed authority shall furnish electronically its report, (i)in relation to the approv (i)in relation to the approval of in-house research and development facility in house research and development facility in Part A of Form No.3CL; Part A of Form No.3CL; (ii)quantifying (ii)quantifying the the expenditure expenditure incurred incurred on on in-house in house research research and and development facility by the company during the previous year and eligible development facility by the company during the previous year and eligible development facility by the company during the previous year and eligible for weighted deduction under sub for weighted deduction under sub-section (2AB) of section 35 of the Act in (2AB) of section 35 of the Act in Part B of Form No.3CL; Part B of Form No.3CL; (ba)The report in Form No.3CL referred to in clause (b) shall be furnished (ba)The report in Form No.3CL referred to in clause (b) shall be furnished (ba)The report in Form No.3CL referred to in clause (b) shall be furnished electronically electronically electronically by by by the the the prescribed prescribed prescribed authority authority authority to to to the the the Principal Principal Principal Chief Chief Chief Commissioner of Income Commissioner of Income-tax or Chief Commissioner of Income tax or Chief Commissioner of Income-tax or Principal Director General of Income Principal Director General of Income-tax or Director General of Income tax or Director General of Income-tax having jurisdiction over such company within one hundred and twenty having jurisdiction over such company within one hundred and twenty having jurisdiction over such company within one hundred and twenty days,- (i)of the grant of the approval, in a case referred to in sub (i)of the grant of the approval, in a case referred to in sub-clause (i) of clause clause (i) of clause (b);
Jayant Agro-Organics Ltd. 6 1757 & 1758/MUM/2024 & 1757 & 1758/MUM/2024 1918, 1952 & 1915/MUM/2024 1918, 1952 & 1915/MUM/2024
(ii)of the submission of the audit report, in a case referred to in sub submission of the audit report, in a case referred to in sub submission of the audit report, in a case referred to in sub- clause (ii) of clause(b); clause (ii) of clause(b); (c)The company shall maintain a separate account for each The company shall maintain a separate account for each The company shall maintain a separate account for each approved facility; which shall be audited annually and a approved facility; which shall be audited annually and a approved facility; which shall be audited annually and a report of audit in Form No.3CLA shall be furnished electronically to the audit in Form No.3CLA shall be furnished electronically to the audit in Form No.3CLA shall be furnished electronically to the Secretary, Department of Scientific and Industrial Research on or Secretary, Department of Scientific and Industrial Research on or Secretary, Department of Scientific and Industrial Research on or before the due date specified in Explanation 2 to sub before the due date specified in Explanation 2 to sub before the due date specified in Explanation 2 to sub-section (1) of section 139 of the Act for furnishing the retur section 139 of the Act for furnishing the return of income, for each n of income, for each succeeding year. succeeding year. Explanation. - For the purposes of this sub-rule the expression "audited" rule the expression "audited" means the audit of accounts by an accountant, as defined in the means the audit of accounts by an accountant, as defined in the means the audit of accounts by an accountant, as defined in the Explanation below sub Explanation below sub-section (2) of section 288 of the Income section (2) of section 288 of the Income-tax Act, 1961; (d)Assets acquired in respect of development of scientific research and Assets acquired in respect of development of scientific research and Assets acquired in respect of development of scientific research and development facility shall not be disposed of without the approval of the development facility shall not be disposed of without the approval of the development facility shall not be disposed of without the approval of the Secretary, Department of Scientific and Industrial Resear Secretary, Department of Scientific and Industrial Research. ch. (8) For the purposes of this rule, the Principal Director General of Income For the purposes of this rule, the Principal Director General of Income For the purposes of this rule, the Principal Director General of Income-tax (Systems) shall specify the procedures, formats and standards for ensuring (Systems) shall specify the procedures, formats and standards for ensuring (Systems) shall specify the procedures, formats and standards for ensuring secure capture and transmission of data, and shall also be responsible for secure capture and transmission of data, and shall also be responsible for secure capture and transmission of data, and shall also be responsible for the day-to-day adminis day administration in relation to furnishing the information in the tration in relation to furnishing the information in the manner so specified. manner so specified.” ( emphasis supplied by us) ( emphasis supplied by us) 5.2 The clause (b)(ii) of Rule 6(7A) has been introduced by Income The clause (b)(ii) of Rule 6(7A) has been introduced by Income The clause (b)(ii) of Rule 6(7A) has been introduced by Income- tax (Tenth Amendment Amendment ) Rules, 2016 w.e.f. 1.7.2016, which is ) Rules, 2016 w.e.f. 1.7.2016, which is effective for year under consideration. effective for year under consideration. rules, firstly, the assessee was required to 5.3 Thus as per rules, assessee was required to furnish an application in form No. 3CK n application in form No. 3CK. Secondly, the assessee was , the assessee was required to submit a audit report in Form No. 3CLA to the required to submit a audit report in Form No. required to submit a audit report in Form No. Secretary, Department of Scientific and Industrial research on or Secretary, Department of Scientific and Industrial research on or Secretary, Department of Scientific and Industrial research on or before the date of filing of filing of return of income u/s 139(1) of the Act for return of income u/s 139(1) of the Act for succeeding year. Thirdly Thirdly, the prescribed authority was required to the prescribed authority was required to issue report in form No. 3CL to the Pr issue report in form No. 3CL to the Principal Chief Commissioner of incipal Chief Commissioner of Income-tax or Chief Commissioner of Income tax or Chief Commissioner of Income-tax or Principal tax or Principal
Jayant Agro-Organics Ltd. 7 1757 & 1758/MUM/2024 & 1757 & 1758/MUM/2024 1918, 1952 & 1915/MUM/2024 1918, 1952 & 1915/MUM/2024 Director General of Income Director General of Income-tax or Director General of Income tax or Director General of Income-tax having jurisdiction over the having jurisdiction over the company, for approval of research for approval of research facility within 120 days from grant of facility within 120 days from grant of approval under clause (b)(i) of approval under clause (b)(i) of rule 6(7A) and for qualifying expenditure , within 120 days of rule 6(7A) and for qualifying expenditure , within 120 days of rule 6(7A) and for qualifying expenditure , within 120 days of submission of audit report. submission of audit report.
5.4 The Assessing Officer 5.4 The Assessing Officer disallowed the claim of the assessee for disallowed the claim of the assessee for the reason that said Form 3CLA was filed beyond the due date of the reason that said Form 3CLA was filed beyond the due date of the reason that said Form 3CLA was filed beyond the due date of filing of the return of income. The relevant finding of the Assessing filing of the return of income. The relevant finding of the Assessing filing of the return of income. The relevant finding of the Assessing Officer is reproduced as under: Officer is reproduced as under:
“3.5 The submissions of the assessee have been examined but found 3.5 The submissions of the assessee have been examined but found 3.5 The submissions of the assessee have been examined but found not tenable. As seen from the above that the provision of Section not tenable. As seen from the above that the provision of Section not tenable. As seen from the above that the provision of Section 35(2AB)(3) of the Act 35(2AB)(3) of the Act, is very specific in regard to allowability of , is very specific in regard to allowability of deduction. There exists no exclusion or exception clause. As per the deduction. There exists no exclusion or exception clause. As per the deduction. There exists no exclusion or exception clause. As per the said provisions of Income said provisions of Income-tax Act, 1961 read with Rule 6(7)(c) of the tax Act, 1961 read with Rule 6(7)(c) of the Income-tax Rules, 1962, to avail the deduction u/s.35(2AB), the tax Rules, 1962, to avail the deduction u/s.35(2AB), the tax Rules, 1962, to avail the deduction u/s.35(2AB), the assessee is required to furnish Form No.3CLA (applicable from the see is required to furnish Form No.3CLA (applicable from the see is required to furnish Form No.3CLA (applicable from the Assessment year:2017 Assessment year:2017-18) electronically to the Secretary, Department 18) electronically to the Secretary, Department of Scientific and Industrial Research on or before the due date of Scientific and Industrial Research on or before the due date of Scientific and Industrial Research on or before the due date specified in Explanation 2 to sub specified in Explanation 2 to sub-section (1) of section 139 o section (1) of section 139 of the Act i.e. on or before due date of filing return of income. As the assessee i.e. on or before due date of filing return of income. As the assessee i.e. on or before due date of filing return of income. As the assessee has filed the said Form only on 18/03/2021 and hence the deduction has filed the said Form only on 18/03/2021 and hence the deduction has filed the said Form only on 18/03/2021 and hence the deduction claimed u/s.35(2AB) is not allowable. In the scenario, the assessee is claimed u/s.35(2AB) is not allowable. In the scenario, the assessee is claimed u/s.35(2AB) is not allowable. In the scenario, the assessee is found not eligible for deduction of R found not eligible for deduction of Rs.4,02,56,307/- i.e. ( Rs.2,66, i.e. ( Rs.2,66, 14,538/- debited to Profit & Loss A/c and Rs. 1,36,41,769/ debited to Profit & Loss A/c and Rs. 1,36,41,769/- weighted debited to Profit & Loss A/c and Rs. 1,36,41,769/ deduction) under section 35(2AB) of the Income deduction) under section 35(2AB) of the Income-tax Act, 1961, in the tax Act, 1961, in the light of provision of sub light of provision of sub-sections 2 & 3 of Section 35(2AB) of the Act sections 2 & 3 of Section 35(2AB) of the Act read with Rule read with Rule 6(7)(c) of the Income-tax Rules, and accordingly, this tax Rules, and accordingly, this claim of deduction is disallowed. claim of deduction is disallowed.” 5.6 On further appeal, the Ld. CIT(A) observed that Form On further appeal, the Ld. CIT(A) observed that Form On further appeal, the Ld. CIT(A) observed that Form No. 3CL was to be issued by the prescribed authority within prescribed was to be issued by the prescribed authority within was to be issued by the prescribed authority within period granting its approval. Though granting its approval. Though the Ld. CIT(A) allowed the the Ld. CIT(A) allowed the claim of weighted deduction however directed the Assessing Officer claim of weighted deduction however directed the Assessing Officer claim of weighted deduction however directed the Assessing Officer to withdraw the claim if to withdraw the claim if the prescribed authority deny the prescribed authority deny the Jayant Agro-Organics Ltd. 8 1757 & 1758/MUM/2024 & 1757 & 1758/MUM/2024 1918, 1952 & 1915/MUM/2024 1918, 1952 & 1915/MUM/2024 expenditure claimed by the assessee or quantify at at lesser amount. The Revenue is aggrieved with the dir The Revenue is aggrieved with the direction to allow the weighted ection to allow the weighted deduction u/s 35(2AB) of the Act whereas assessee is aggrieved deduction u/s 35(2AB) of the Act whereas assessee is aggrieved deduction u/s 35(2AB) of the Act whereas assessee is aggrieved with the direction given for reduction in the claim in case the with the direction given for reduction in the claim in case the with the direction given for reduction in the claim in case the expenditure is accordingly modified by the prescribed authority. expenditure is accordingly modified by the prescribed authority. expenditure is accordingly modified by the prescribed authority.
5.7 During the course of the heari During the course of the hearing, the Ld. counsel for the ng, the Ld. counsel for the assessee was asked to provide current status of the Form No. 3CL assessee was asked to provide current status of the Form No. 3CL assessee was asked to provide current status of the Form No. 3CL for determining amount of expenditure approved by the prescribed amount of expenditure approved by the prescribed amount of expenditure approved by the prescribed authority for weighted deduction. However, the Ld. Counsel for the authority for weighted deduction. However, the Ld. Counsel for the authority for weighted deduction. However, the Ld. Counsel for the assessee submitted that till da assessee submitted that till date no such form no. 3CL no. 3CL was issued by the prescribed authority by the prescribed authority for quantifying the expenditure for for quantifying the expenditure for deduction u/s 35(2AB) of the Act deduction u/s 35(2AB) of the Act. In our opinion, it is for the . In our opinion, it is for the assessee to explain as why said approval has been withheld by the assessee to explain as why said approval has been withheld by the assessee to explain as why said approval has been withheld by the , the Ld. counsel for the assessee could prescribed authority. Since prescribed authority. Since, the Ld. counsel for the assessee could not file a convincing reply, reply, therefore, we feel it appropriate to restore therefore, we feel it appropriate to restore this issue back to the file of the Assessing Officer with the direction this issue back to the file of the Assessing Officer with the direction this issue back to the file of the Assessing Officer with the direction to find out the status of the proceedings before the prescribed to find out the status of the proceedings before the pr to find out the status of the proceedings before the pr authority for approval of expenditure incurred on the scientific rity for approval of expenditure incurred on the scientific rity for approval of expenditure incurred on the scientific research by the assessee by the assessee and then decide the issue and then decide the issue of deduction u/s 35(2AB) of the Act u/s 35(2AB) of the Act in accordance with law. The grounds raised in accordance with law. The grounds raised by the assessee and the Revenue are accordingly allowed for by the assessee and the Revenue are accordingly allowed for by the assessee and the Revenue are accordingly allowed for statistical purposes.
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In the result, the appeals of the assessee and the Revenue for In the result, the appeals of the assessee and the Revenue for In the result, the appeals of the assessee and the Revenue for assessment year 2014 assessment year 2014-15 and 2017-18 are dismissed whereas the 18 are dismissed whereas the appeals for assessment year 2018 for assessment year 2018-19 are allowed for statistical allowed for statistical purposes.
Order pronounced in the open Court o Order pronounced in the open Court on 19/08/2024. /08/2024.