88 orders · Page 1 of 2
The Tribunal allowed the appeals of the assessees. The Tribunal found that the assessees had inadvertently offered the compensation received under the BSNL VRS-2019 to tax due to a lack of awareness of the legal provisions. Following the decision of the Hon'ble ITAT Chandigarh Bench in Harish Kumar vs. ITO Ward 5(5), Chandigarh (ITA No. 42/CHD/2025), wherein compensation under the same scheme was held to be exempt under Section 10(10B), the Tribunal held that the assessees are eligible for the exemption. Since the income is not taxable, the assessees are eligible for the refund of the Tax Deducted at Source (TDS). The Tribunal respectfully followed the cited judgment and allowed all 64 appeals filed by different assessees.
The Tribunal allowed the appeals of the assessees. The Tribunal found that the assessees had inadvertently offered the compensation received under the BSNL VRS-2019 to tax due to a lack of awareness of the legal provisions. Following the decision of the Hon'ble ITAT Chandigarh Bench in Harish Kumar vs. ITO Ward 5(5), Chandigarh (ITA No. 42/CHD/2025), wherein compensation under the same scheme was held to be exempt under Section 10(10B), the Tribunal held that the assessees are eligible for the exemption. Since the income is not taxable, the assessees are eligible for the refund of the Tax Deducted at Source (TDS). The Tribunal respectfully followed the cited judgment and allowed all 64 appeals filed by different assessees.
The Tribunal allowed the appeals of the assessees. The Tribunal found that the assessees had inadvertently offered the compensation received under the BSNL VRS-2019 to tax due to a lack of awareness of the legal provisions. Following the decision of the Hon'ble ITAT Chandigarh Bench in Harish Kumar vs. ITO Ward 5(5), Chandigarh (ITA No. 42/CHD/2025), wherein compensation under the same scheme was held to be exempt under Section 10(10B), the Tribunal held that the assessees are eligible for the exemption. Since the income is not taxable, the assessees are eligible for the refund of the Tax Deducted at Source (TDS). The Tribunal respectfully followed the cited judgment and allowed all 64 appeals filed by different assessees.
The Tribunal allowed the appeals of the assessees. The Tribunal found that the assessees had inadvertently offered the compensation received under the BSNL VRS-2019 to tax due to a lack of awareness of the legal provisions. Following the decision of the Hon'ble ITAT Chandigarh Bench in Harish Kumar vs. ITO Ward 5(5), Chandigarh (ITA No. 42/CHD/2025), wherein compensation under the same scheme was held to be exempt under Section 10(10B), the Tribunal held that the assessees are eligible for the exemption. Since the income is not taxable, the assessees are eligible for the refund of the Tax Deducted at Source (TDS). The Tribunal respectfully followed the cited judgment and allowed all 64 appeals filed by different assessees.
The Tribunal allowed the appeals of the assessees. The Tribunal found that the assessees had inadvertently offered the compensation received under the BSNL VRS-2019 to tax due to a lack of awareness of the legal provisions. Following the decision of the Hon'ble ITAT Chandigarh Bench in Harish Kumar vs. ITO Ward 5(5), Chandigarh (ITA No. 42/CHD/2025), wherein compensation under the same scheme was held to be exempt under Section 10(10B), the Tribunal held that the assessees are eligible for the exemption. Since the income is not taxable, the assessees are eligible for the refund of the Tax Deducted at Source (TDS). The Tribunal respectfully followed the cited judgment and allowed all 64 appeals filed by different assessees.
The Tribunal allowed the appeals of the assessees. The Tribunal found that the assessees had inadvertently offered the compensation received under the BSNL VRS-2019 to tax due to a lack of awareness of the legal provisions. Following the decision of the Hon'ble ITAT Chandigarh Bench in Harish Kumar vs. ITO Ward 5(5), Chandigarh (ITA No. 42/CHD/2025), wherein compensation under the same scheme was held to be exempt under Section 10(10B), the Tribunal held that the assessees are eligible for the exemption. Since the income is not taxable, the assessees are eligible for the refund of the Tax Deducted at Source (TDS). The Tribunal respectfully followed the cited judgment and allowed all 64 appeals filed by different assessees.
The Tribunal allowed the appeals of the assessees. The Tribunal found that the assessees had inadvertently offered the compensation received under the BSNL VRS-2019 to tax due to a lack of awareness of the legal provisions. Following the decision of the Hon'ble ITAT Chandigarh Bench in Harish Kumar vs. ITO Ward 5(5), Chandigarh (ITA No. 42/CHD/2025), wherein compensation under the same scheme was held to be exempt under Section 10(10B), the Tribunal held that the assessees are eligible for the exemption. Since the income is not taxable, the assessees are eligible for the refund of the Tax Deducted at Source (TDS). The Tribunal respectfully followed the cited judgment and allowed all 64 appeals filed by different assessees.
The Tribunal allowed the appeals of the assessees. The Tribunal found that the assessees had inadvertently offered the compensation received under the BSNL VRS-2019 to tax due to a lack of awareness of the legal provisions. Following the decision of the Hon'ble ITAT Chandigarh Bench in Harish Kumar vs. ITO Ward 5(5), Chandigarh (ITA No. 42/CHD/2025), wherein compensation under the same scheme was held to be exempt under Section 10(10B), the Tribunal held that the assessees are eligible for the exemption. Since the income is not taxable, the assessees are eligible for the refund of the Tax Deducted at Source (TDS). The Tribunal respectfully followed the cited judgment and allowed all 64 appeals filed by different assessees.
The Tribunal allowed the appeals of the assessees. The Tribunal found that the assessees had inadvertently offered the compensation received under the BSNL VRS-2019 to tax due to a lack of awareness of the legal provisions. Following the decision of the Hon'ble ITAT Chandigarh Bench in Harish Kumar vs. ITO Ward 5(5), Chandigarh (ITA No. 42/CHD/2025), wherein compensation under the same scheme was held to be exempt under Section 10(10B), the Tribunal held that the assessees are eligible for the exemption. Since the income is not taxable, the assessees are eligible for the refund of the Tax Deducted at Source (TDS). The Tribunal respectfully followed the cited judgment and allowed all 64 appeals filed by different assessees.
The Tribunal allowed the appeals of the assessees. The Tribunal found that the assessees had inadvertently offered the compensation received under the BSNL VRS-2019 to tax due to a lack of awareness of the legal provisions. Following the decision of the Hon'ble ITAT Chandigarh Bench in Harish Kumar vs. ITO Ward 5(5), Chandigarh (ITA No. 42/CHD/2025), wherein compensation under the same scheme was held to be exempt under Section 10(10B), the Tribunal held that the assessees are eligible for the exemption. Since the income is not taxable, the assessees are eligible for the refund of the Tax Deducted at Source (TDS). The Tribunal respectfully followed the cited judgment and allowed all 64 appeals filed by different assessees.
The Tribunal allowed the appeals of the assessees. The Tribunal found that the assessees had inadvertently offered the compensation received under the BSNL VRS-2019 to tax due to a lack of awareness of the legal provisions. Following the decision of the Hon'ble ITAT Chandigarh Bench in Harish Kumar vs. ITO Ward 5(5), Chandigarh (ITA No. 42/CHD/2025), wherein compensation under the same scheme was held to be exempt under Section 10(10B), the Tribunal held that the assessees are eligible for the exemption. Since the income is not taxable, the assessees are eligible for the refund of the Tax Deducted at Source (TDS). The Tribunal respectfully followed the cited judgment and allowed all 64 appeals filed by different assessees.
The Tribunal allowed the appeals of the assessees. The Tribunal found that the assessees had inadvertently offered the compensation received under the BSNL VRS-2019 to tax due to a lack of awareness of the legal provisions. Following the decision of the Hon'ble ITAT Chandigarh Bench in Harish Kumar vs. ITO Ward 5(5), Chandigarh (ITA No. 42/CHD/2025), wherein compensation under the same scheme was held to be exempt under Section 10(10B), the Tribunal held that the assessees are eligible for the exemption. Since the income is not taxable, the assessees are eligible for the refund of the Tax Deducted at Source (TDS). The Tribunal respectfully followed the cited judgment and allowed all 64 appeals filed by different assessees.
The Tribunal allowed the appeals of the assessees. The Tribunal found that the assessees had inadvertently offered the compensation received under the BSNL VRS-2019 to tax due to a lack of awareness of the legal provisions. Following the decision of the Hon'ble ITAT Chandigarh Bench in Harish Kumar vs. ITO Ward 5(5), Chandigarh (ITA No. 42/CHD/2025), wherein compensation under the same scheme was held to be exempt under Section 10(10B), the Tribunal held that the assessees are eligible for the exemption. Since the income is not taxable, the assessees are eligible for the refund of the Tax Deducted at Source (TDS). The Tribunal respectfully followed the cited judgment and allowed all 64 appeals filed by different assessees.
The Tribunal allowed the appeals of the assessees. The Tribunal found that the assessees had inadvertently offered the compensation received under the BSNL VRS-2019 to tax due to a lack of awareness of the legal provisions. Following the decision of the Hon'ble ITAT Chandigarh Bench in Harish Kumar vs. ITO Ward 5(5), Chandigarh (ITA No. 42/CHD/2025), wherein compensation under the same scheme was held to be exempt under Section 10(10B), the Tribunal held that the assessees are eligible for the exemption. Since the income is not taxable, the assessees are eligible for the refund of the Tax Deducted at Source (TDS). The Tribunal respectfully followed the cited judgment and allowed all 64 appeals filed by different assessees.
The Tribunal allowed the appeals of the assessees. The Tribunal found that the assessees had inadvertently offered the compensation received under the BSNL VRS-2019 to tax due to a lack of awareness of the legal provisions. Following the decision of the Hon'ble ITAT Chandigarh Bench in Harish Kumar vs. ITO Ward 5(5), Chandigarh (ITA No. 42/CHD/2025), wherein compensation under the same scheme was held to be exempt under Section 10(10B), the Tribunal held that the assessees are eligible for the exemption. Since the income is not taxable, the assessees are eligible for the refund of the Tax Deducted at Source (TDS). The Tribunal respectfully followed the cited judgment and allowed all 64 appeals filed by different assessees.
The Tribunal allowed the appeals of the assessees. The Tribunal found that the assessees had inadvertently offered the compensation received under the BSNL VRS-2019 to tax due to a lack of awareness of the legal provisions. Following the decision of the Hon'ble ITAT Chandigarh Bench in Harish Kumar vs. ITO Ward 5(5), Chandigarh (ITA No. 42/CHD/2025), wherein compensation under the same scheme was held to be exempt under Section 10(10B), the Tribunal held that the assessees are eligible for the exemption. Since the income is not taxable, the assessees are eligible for the refund of the Tax Deducted at Source (TDS). The Tribunal respectfully followed the cited judgment and allowed all 64 appeals filed by different assessees.
The Tribunal allowed the appeals of the assessees. The Tribunal found that the assessees had inadvertently offered the compensation received under the BSNL VRS-2019 to tax due to a lack of awareness of the legal provisions. Following the decision of the Hon'ble ITAT Chandigarh Bench in Harish Kumar vs. ITO Ward 5(5), Chandigarh (ITA No. 42/CHD/2025), wherein compensation under the same scheme was held to be exempt under Section 10(10B), the Tribunal held that the assessees are eligible for the exemption. Since the income is not taxable, the assessees are eligible for the refund of the Tax Deducted at Source (TDS). The Tribunal respectfully followed the cited judgment and allowed all 64 appeals filed by different assessees.
The Tribunal allowed the appeals of the assessees. The Tribunal found that the assessees had inadvertently offered the compensation received under the BSNL VRS-2019 to tax due to a lack of awareness of the legal provisions. Following the decision of the Hon'ble ITAT Chandigarh Bench in Harish Kumar vs. ITO Ward 5(5), Chandigarh (ITA No. 42/CHD/2025), wherein compensation under the same scheme was held to be exempt under Section 10(10B), the Tribunal held that the assessees are eligible for the exemption. Since the income is not taxable, the assessees are eligible for the refund of the Tax Deducted at Source (TDS). The Tribunal respectfully followed the cited judgment and allowed all 64 appeals filed by different assessees.
The Tribunal allowed the appeals of the assessees. The Tribunal found that the assessees had inadvertently offered the compensation received under the BSNL VRS-2019 to tax due to a lack of awareness of the legal provisions. Following the decision of the Hon'ble ITAT Chandigarh Bench in Harish Kumar vs. ITO Ward 5(5), Chandigarh (ITA No. 42/CHD/2025), wherein compensation under the same scheme was held to be exempt under Section 10(10B), the Tribunal held that the assessees are eligible for the exemption. Since the income is not taxable, the assessees are eligible for the refund of the Tax Deducted at Source (TDS). The Tribunal respectfully followed the cited judgment and allowed all 64 appeals filed by different assessees.
The Tribunal allowed the appeals of the assessees. The Tribunal found that the assessees had inadvertently offered the compensation received under the BSNL VRS-2019 to tax due to a lack of awareness of the legal provisions. Following the decision of the Hon'ble ITAT Chandigarh Bench in Harish Kumar vs. ITO Ward 5(5), Chandigarh (ITA No. 42/CHD/2025), wherein compensation under the same scheme was held to be exempt under Section 10(10B), the Tribunal held that the assessees are eligible for the exemption. Since the income is not taxable, the assessees are eligible for the refund of the Tax Deducted at Source (TDS). The Tribunal respectfully followed the cited judgment and allowed all 64 appeals filed by different assessees.
The Tribunal allowed the appeals of the assessees. The Tribunal found that the assessees had inadvertently offered the compensation received under the BSNL VRS-2019 to tax due to a lack of awareness of the legal provisions. Following the decision of the Hon'ble ITAT Chandigarh Bench in Harish Kumar vs. ITO Ward 5(5), Chandigarh (ITA No. 42/CHD/2025), wherein compensation under the same scheme was held to be exempt under Section 10(10B), the Tribunal held that the assessees are eligible for the exemption. Since the income is not taxable, the assessees are eligible for the refund of the Tax Deducted at Source (TDS). The Tribunal respectfully followed the cited judgment and allowed all 64 appeals filed by different assessees.
The Tribunal allowed the appeals of the assessees. The Tribunal found that the assessees had inadvertently offered the compensation received under the BSNL VRS-2019 to tax due to a lack of awareness of the legal provisions. Following the decision of the Hon'ble ITAT Chandigarh Bench in Harish Kumar vs. ITO Ward 5(5), Chandigarh (ITA No. 42/CHD/2025), wherein compensation under the same scheme was held to be exempt under Section 10(10B), the Tribunal held that the assessees are eligible for the exemption. Since the income is not taxable, the assessees are eligible for the refund of the Tax Deducted at Source (TDS). The Tribunal respectfully followed the cited judgment and allowed all 64 appeals filed by different assessees.
The Tribunal allowed the appeals of the assessees. The Tribunal found that the assessees had inadvertently offered the compensation received under the BSNL VRS-2019 to tax due to a lack of awareness of the legal provisions. Following the decision of the Hon'ble ITAT Chandigarh Bench in Harish Kumar vs. ITO Ward 5(5), Chandigarh (ITA No. 42/CHD/2025), wherein compensation under the same scheme was held to be exempt under Section 10(10B), the Tribunal held that the assessees are eligible for the exemption. Since the income is not taxable, the assessees are eligible for the refund of the Tax Deducted at Source (TDS). The Tribunal respectfully followed the cited judgment and allowed all 64 appeals filed by different assessees.
The Tribunal allowed the appeals of the assessees. The Tribunal found that the assessees had inadvertently offered the compensation received under the BSNL VRS-2019 to tax due to a lack of awareness of the legal provisions. Following the decision of the Hon'ble ITAT Chandigarh Bench in Harish Kumar vs. ITO Ward 5(5), Chandigarh (ITA No. 42/CHD/2025), wherein compensation under the same scheme was held to be exempt under Section 10(10B), the Tribunal held that the assessees are eligible for the exemption. Since the income is not taxable, the assessees are eligible for the refund of the Tax Deducted at Source (TDS). The Tribunal respectfully followed the cited judgment and allowed all 64 appeals filed by different assessees.
The Tribunal allowed the appeals of the assessees. The Tribunal found that the assessees had inadvertently offered the compensation received under the BSNL VRS-2019 to tax due to a lack of awareness of the legal provisions. Following the decision of the Hon'ble ITAT Chandigarh Bench in Harish Kumar vs. ITO Ward 5(5), Chandigarh (ITA No. 42/CHD/2025), wherein compensation under the same scheme was held to be exempt under Section 10(10B), the Tribunal held that the assessees are eligible for the exemption. Since the income is not taxable, the assessees are eligible for the refund of the Tax Deducted at Source (TDS). The Tribunal respectfully followed the cited judgment and allowed all 64 appeals filed by different assessees.
The Tribunal allowed the appeals of the assessees. The Tribunal found that the assessees had inadvertently offered the compensation received under the BSNL VRS-2019 to tax due to a lack of awareness of the legal provisions. Following the decision of the Hon'ble ITAT Chandigarh Bench in Harish Kumar vs. ITO Ward 5(5), Chandigarh (ITA No. 42/CHD/2025), wherein compensation under the same scheme was held to be exempt under Section 10(10B), the Tribunal held that the assessees are eligible for the exemption. Since the income is not taxable, the assessees are eligible for the refund of the Tax Deducted at Source (TDS). The Tribunal respectfully followed the cited judgment and allowed all 64 appeals filed by different assessees.
The Tribunal allowed the appeals of the assessees. The Tribunal found that the assessees had inadvertently offered the compensation received under the BSNL VRS-2019 to tax due to a lack of awareness of the legal provisions. Following the decision of the Hon'ble ITAT Chandigarh Bench in Harish Kumar vs. ITO Ward 5(5), Chandigarh (ITA No. 42/CHD/2025), wherein compensation under the same scheme was held to be exempt under Section 10(10B), the Tribunal held that the assessees are eligible for the exemption. Since the income is not taxable, the assessees are eligible for the refund of the Tax Deducted at Source (TDS). The Tribunal respectfully followed the cited judgment and allowed all 64 appeals filed by different assessees.
The Tribunal allowed the appeals of the assessees. The Tribunal found that the assessees had inadvertently offered the compensation received under the BSNL VRS-2019 to tax due to a lack of awareness of the legal provisions. Following the decision of the Hon'ble ITAT Chandigarh Bench in Harish Kumar vs. ITO Ward 5(5), Chandigarh (ITA No. 42/CHD/2025), wherein compensation under the same scheme was held to be exempt under Section 10(10B), the Tribunal held that the assessees are eligible for the exemption. Since the income is not taxable, the assessees are eligible for the refund of the Tax Deducted at Source (TDS). The Tribunal respectfully followed the cited judgment and allowed all 64 appeals filed by different assessees.
The Tribunal allowed the appeals of the assessees. The Tribunal found that the assessees had inadvertently offered the compensation received under the BSNL VRS-2019 to tax due to a lack of awareness of the legal provisions. Following the decision of the Hon'ble ITAT Chandigarh Bench in Harish Kumar vs. ITO Ward 5(5), Chandigarh (ITA No. 42/CHD/2025), wherein compensation under the same scheme was held to be exempt under Section 10(10B), the Tribunal held that the assessees are eligible for the exemption. Since the income is not taxable, the assessees are eligible for the refund of the Tax Deducted at Source (TDS). The Tribunal respectfully followed the cited judgment and allowed all 64 appeals filed by different assessees.
The Tribunal allowed the appeals of the assessees. The Tribunal found that the assessees had inadvertently offered the compensation received under the BSNL VRS-2019 to tax due to a lack of awareness of the legal provisions. Following the decision of the Hon'ble ITAT Chandigarh Bench in Harish Kumar vs. ITO Ward 5(5), Chandigarh (ITA No. 42/CHD/2025), wherein compensation under the same scheme was held to be exempt under Section 10(10B), the Tribunal held that the assessees are eligible for the exemption. Since the income is not taxable, the assessees are eligible for the refund of the Tax Deducted at Source (TDS). The Tribunal respectfully followed the cited judgment and allowed all 64 appeals filed by different assessees.
The Tribunal allowed the appeals of the assessees. The Tribunal found that the assessees had inadvertently offered the compensation received under the BSNL VRS-2019 to tax due to a lack of awareness of the legal provisions. Following the decision of the Hon'ble ITAT Chandigarh Bench in Harish Kumar vs. ITO Ward 5(5), Chandigarh (ITA No. 42/CHD/2025), wherein compensation under the same scheme was held to be exempt under Section 10(10B), the Tribunal held that the assessees are eligible for the exemption. Since the income is not taxable, the assessees are eligible for the refund of the Tax Deducted at Source (TDS). The Tribunal respectfully followed the cited judgment and allowed all 64 appeals filed by different assessees.
The Tribunal allowed the appeals of the assessees. The Tribunal found that the assessees had inadvertently offered the compensation received under the BSNL VRS-2019 to tax due to a lack of awareness of the legal provisions. Following the decision of the Hon'ble ITAT Chandigarh Bench in Harish Kumar vs. ITO Ward 5(5), Chandigarh (ITA No. 42/CHD/2025), wherein compensation under the same scheme was held to be exempt under Section 10(10B), the Tribunal held that the assessees are eligible for the exemption. Since the income is not taxable, the assessees are eligible for the refund of the Tax Deducted at Source (TDS). The Tribunal respectfully followed the cited judgment and allowed all 64 appeals filed by different assessees.
The Tribunal condoned the delay in filing the appeal, citing a liberal approach for bonafide reasons. The Tribunal found that the CIT(A) had passed an ex-parte order without providing an opportunity of being heard to the assessee and had not decided all grounds of appeal on merits.
The Tribunal condoned the delay of 294 days, considering the reasons provided by the assessee as sufficient cause. The matter was remanded back to the CIT(A) to decide the appeal afresh on its merits.
The Tribunal found that the Assessing Officer made additions without proper opportunity for the assessee to produce supporting documents. The CIT(A) also failed to consider additional documents. Therefore, the matter was restored to the AO for a de novo assessment, with a direction to provide an opportunity of being heard.
The Tribunal found that both the Assessing Officer and CIT(A) orders were ex-parte and the CIT(A) did not decide all grounds. Therefore, the case was restored to the Assessing Officer for de-novo assessment with an opportunity for the assessee to be heard.
The Tribunal found that the CIT(A) dismissed the appeals without properly considering the delay. The matter was remanded to the CIT(A) with a direction for the assessee to file a condonation application or explain the lack of delay.
The Tribunal found that the CIT(A) dismissed the appeals without properly considering the delay. The matter was remanded to the CIT(A) with a direction for the assessee to file a condonation application or explain the lack of delay.
The Tribunal condoned the delay in filing the appeals before the CIT(A) after considering the medical grounds and the death of the assessee's parents as sufficient cause. The matter was then remanded to the Assessing Officer for fresh assessment.
The Tribunal found that the CIT(A) dismissed the appeals without properly considering the delay. The matter was remanded to the CIT(A) with a direction for the assessee to file a condonation application or explain the lack of delay.
The Tribunal condoned the delay in filing the appeals before the CIT(A) after considering the medical grounds and the death of the assessee's parents as sufficient cause. The matter was then remanded to the Assessing Officer for fresh assessment.
The Tribunal condoned the delay in filing the appeals before the CIT(A) after considering the medical grounds and the death of the assessee's parents as sufficient cause. The matter was then remanded to the Assessing Officer for fresh assessment.
The Tribunal found that both the Assessing Officer and the CIT(A) passed orders ex-parte and that the CIT(A) did not decide all grounds on merits. Therefore, the case was restored to the Assessing Officer for de-novo assessment.
The Tribunal noted that both the Assessing Officer's and CIT(A)'s orders were ex-parte, and the CIT(A) had not decided all grounds. The matter was restored to the Assessing Officer for de-novo assessment, subject to the assessee depositing Rs. 10,000/- to PMNRF.
The Tribunal found that both the Assessing Officer and CIT(A) failed to consider the assessee's documents and did not provide a proper opportunity for being heard. Therefore, the matter was restored to the Assessing Officer for a fresh assessment.
The Tribunal held that the assessee was not given a reasonable opportunity of being heard and that the case should be remitted back to the CIT(E) for a fresh decision. The assessee was directed to substantiate its case with cogent documents.
The Tribunal rejected the AO's redrafted balance sheet and the assessee's claimed opening cash balance due to inconsistencies and lack of evidence. The case was remitted back to the AO for de novo consideration.
The ITAT condoned the delay of 702 days, setting aside the CIT(Appeals) order. The matter was remitted back to the CIT(Appeals) to provide the assessee with another opportunity to be heard.
The Tribunal held that after the amendment to Section 80AC, filing the return within the due date is mandatory for claiming deductions under Chapter VI-A. Therefore, the PCIT's order disallowing the deduction was upheld.
The Tribunal found substance in the Revenue's submission regarding the dubious nature of the sale deed and the assessee's failure to establish a nexus between the cash receipts and bank deposits. The matter was therefore remitted back to the Assessing Officer for fresh adjudication.