CIT v. Shri Ram Singh

306 ITR 343High Court2008#534 most cited

What is CIT v. Shri Ram Singh authority for?

The Assessing Officer cannot assess or reassess any other income under Section 147 if the original grounds for issuing the Section 148 notice are not sustained. Jurisdiction to add other income discovered during reassessment proceedings arises only if the income for which the notice was initially issued is successfully assessed or reassessed.

180

judgments rely on this decision, according to BharatTax’s citation analysis of 367,154 Indian tax judgments — from 2012 to 2026.

Also referred to as

CIT v. Shri Ram Singh · 306 ITR 343 · Section 147 · Section 148 · reassessment jurisdiction · original grounds not sustained · income escaping assessment · scope of reassessment · Jet Airways principle · Explanation 3 Section 147

Also reported as

174 Taxmann 438217 CTR 3458 DTR 118

Sections most often in play

Section 148Section 147Section 143(3)Section 142(1)Section 68Section 139(1)Section 144BSection 234B

Issues it is cited on

section 147(1)section 13(1)(c)(ii)section 148(2)section 32(1)(iia)clarificatory amendmentsection 140income escaping assessmentkelvinatorfresh tangible materialsection 234dreason to believeadditional depreciation

Judgments citing CIT v. Shri Ram Singh

Assistant Commissioner of Income Tax, Coimbatore vs. Kamatchipuram Vellingiri Jayaraman, Coimbatore

Appeal of the revenue is dismissed, where as the Cross objection of the assessee is allowed

ITA 2777/CHNY/2024[2017-18]Status: DisposedITAT Chennai29 Apr 2025AY 2017-18

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunatha

For Appellant: Ms. D.Komali Krishna, CITFor Respondent: Mr.Venkatswami, ITP &
Section 147Section 148

…an Khanna, [2002] 122 Taxman 1/255 ITR 220 (Punjab & Haryana) would, therefore, no longer hold the field. However, in so far as the second line of authority is concerned, which is reflected in the judgment of the Rajasthan High Court in Shri Ram Singh, [2008] 306 ITR 343 (Rajasthan), Explanation 3 as inserted by Parliament would not take away the basis of that decision. The view which was taken by the Rajasthan High Court was also taken in another judgment of the Punjab and Haryana High Court in CIT C.O.No.27/Chny/2025 v. Atlas Cycle Industries, [1989] 46 Taxman 315/180 ITR 319 (Punjab & Haryana). The decision i…

Saloj Dudh Utpadak Sahakari Mandali Limited, Vadodara vs. The Income Tax Officer, Ward-3(1)(4), Vadodara

In the result, the appeal of the assessee is allowed in above terms

ITA 1685/AHD/2024[2019-20]Status: DisposedITAT Ahmedabad23 Apr 2025AY 2019-20

Bench: Smt. Annapurna Gupta

For Appellant: Shri D. K. Parikh, A.RFor Respondent: Shri Prateek Sharma, Sr. DR
Section 147Section 148Section 148ASection 250(6)Section 80PSection 80P(2)

…tion 148 of the Act did not survive, the AO could not have made any other disallowance. Reliance was placed on the following decision in this regard: (i) Soyala Gram Sewa Sahakari Samiti Ltd. vs. The ITO ITA No. 1116/JP/2024 (ii) CIT vs Shri Ram Singh (2008) 306 ITR 343 (Raj) (iii) Excel Commodity And Derivative Pvt. Ltd. vs. UOI POT/132/2022 IA No. GA/1/2022 (iv) CIT vs. Jet Airways (I) Ltd. (2011) 331 ITR 236 (Bom) (HC) (v) Ranbaxy Laboratories Ltd. vs. CIT (2011) 336 ITR 136 (Delhi High Court) Saloj Dudh Utpadak Sahakari Mandali Ltd. vs. ITO Asst.Year –2019-20 7. Our attention in this regard was first drawn t…

Moorthy, Salem vs. ACIT, Circle-2, Salem

Appeal of the assessee is allowed

ITA 490/CHNY/2025[2011-12]Status: DisposedITAT Chennai23 Apr 2025AY 2011-12

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunatha

For Appellant: Mr.T.S.Lakshmi VenkatramanFor Respondent: Ms. Anitha, Addl.CIT
Section 143(3)Section 147Section 148

…an Khanna, [2002] 122 Taxman 1/255 ITR 220 (Punjab & Haryana) would, therefore, no longer hold the field. However, in so far as the second line of authority is concerned, which is reflected in the judgment of the Rajasthan High Court in Shri Ram Singh, [2008] 306 ITR 343 (Rajasthan), Explanation 3 as inserted by Parliament would not take away the basis of that decision. The view which was taken by the Rajasthan High Court was also taken in another judgment of the Punjab and Haryana High Court in CIT v. Atlas Cycle Industries, [1989] 46 Taxman 315/180 ITR 319 6 (Punjab & Haryana). The decision in Atlas Cycle Indu…

Sunil Hanamant Naikwad, Belgaum vs. Income Tax Officer, Ward - 2, Belagavi

The appeal is ALLOWED as above

ITA 220/PAN/2024[2012-13]Status: DisposedITAT Panaji22 Apr 2025AY 2012-13

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshaliassessment Year : 2012-13 Sunil Hanmantsa Naikwad 1156, Saraf Galli, Shahapur, Belgaum Pan:Abeph0397N . . . . . . . Appellant V/S Income Tax Officer, Ward-2, Belgaum. . . . . . . . Respondent

For Appellant: Mr JD Kalpavruksha [‘Ld. AR’]For Respondent: Mr Ravindra Hattalli [‘Ld. DR’]
Section 139Section 143(3)Section 147Section 250Section 4

…gs, the impugned addition of other income cannot be sustained in law. To drive home this contention the appellant relied upon catena of judicial precedents including ‘CIT Vs Jet Airways (I) Ltd.’ [2010, 195 Taxman 117 (Bom)], and ‘CIT Vs Shri Ram Singh [2008, 217 CTR 345 (Raj)], Per contra, the Ld. DR relied upon the order of tax authorities below. We have heard the rival party’s submission on legal ground 5. (Ground No 3) and perused the material placed on records and considered the facts in the light of settled position of law. We note that, the information relating to financial/share 6. transactions entered…

Shri Salasar Balaji Developers Pvt. Ltd, Jaipur vs. Income Tax Officer, Ward 2(2), Jaipur

In the result, the appeal of the assessee is allowed

ITA 1186/JPR/2024[2012-13]Status: DisposedITAT Jaipur02 Apr 2025AY 2012-13

Bench: Shri Gagan Goyal & Shri Narinder Kumar

For Appellant: Mr. Saurav Harsh, Adv., Ld. ARFor Respondent: Mr. Manoj Kumar, JCIT, Ld. DR
Section 132Section 143(3)Section 148Section 250Section 68Section 69C

…s been supported by the background which led to the insertion of the Explanation 3 to section 147. The Parliament must be regarded as being aware of the interpretation placed on the words 'and also', by the Rajasthan High Court in CIT v. Shri Ram Singh [2008] 306 ITR 343. The Parliament has not taken away the basis of that decision. While it is open to the Parliament, having regard to the plenitude of its legislative powers to do so, the provisions of section 147(1), as they stood after the amendment of 1-4-1989, continue to hold the field. [Para 17] The question of law would, accordingly, stand answered against…

Valmik Thapar vs. Principal Commissioner of Income Tax 18

Appeal is allowed and the additions made by the AO in the

ITA/182/2021HC Delhi25 Mar 2025

Bench: HON'BLE MR. JUSTICE VIBHU BAKHRU,HON'BLE MR. JUSTICE TEJAS KARIA

Section 143(3)Section 147Section 148Section 260ASection 54Section 54E

…ITA No.182/2021 Page 1 of 17 $~16 * IN THE HIGH COURT OF DELHI AT NEW DELHI % Date of Decision: 25.03.2025 + ITA 182/2021 VALMIK THAPAR .....Appellant Through: Mr. Salil Aggarwal, Sr. Adv. with Mr. Madhur Aggarwal, Mr. Uma Shankar & Mr. Mahir Aggarwal, Advs. Versus PRINCIPAL COMMISSIONER OF INCOME TAX 18.....Respondent Through: Mr. Debesh Panda, Ms. Zehra Khan, Mr. Vikramaditya Singh, Mr. Kanishk, Ms. Nivedita, Ms. Anavntta & Ms. Yashika, Advs. CORAM: HON'BLE MR. JUSTICE VIBHU BAKHRU HON'BLE MR. JUSTICE TEJAS KARIA V…

Alok Kumar Jain, Pearl Pleasure vs. ACIT Cir-6, Jaipur, New Cerntral Revenue Building, Bhagwan Dass Road, Rajasthan

ITA 1191/JPR/2024[2016-17]Status: DisposedITAT Jaipur24 Mar 2025AY 2016-17

Bench: Him.

For Appellant: Sh. Prakul Khurana, Adv. &For Respondent: Mrs. Anita Rinesh, JCIT-Sr. DR
Section 10(38)Section 147Section 148Section 250Section 68Section 69A

…Legal Basis Argument in Brief P.B. Reference No Reference is invited to Explanation to Section 147 of the Act and following case laws: Commissioner of Income-tax-5, Mumbai v. Jet Airways (I) Ltd. [2010] 195 Taxman 117 (Bombay) CIT vs Shri Ram Singh [ 2008 ] 306 ITR 343. (Raj) M/s. S V Jadhav VS. The Income Tax Officer Ward 1, SanglI WRIT PETITION NO.3345 OF 2024, Bombay High Court A. Rejoinder on written synopsis filed by department on 16.01.2025 vide letter no. S.NO. JCIT(DR)/ITAT/JPR/2024-25/1005 Para Argument by department in their written Rejoinder by the Assessee-Appellant submission filed during hearing…

Ashok Kumar Jain, Kota vs. ITO WD-2(1), Kota

In the result, the appeal of the assessee is allowed for statistical purpose

ITA 1225/JPR/2024[2015-16]Status: DisposedITAT Jaipur18 Mar 2025AY 2015-16
For Appellant: Sh. Mahendra Gargieya, Adv.& Sh. Devang Gargieya, AdvFor Respondent: Sh. Gautam Singh Choudhary, JCIT
Section 147Section 250Section 253(3)Section 5

…e believed to have been escaped, has not been made, no addition of any other income could be made u/s 147 of Act, more so when prescribed legal procedure was not followed. 2.2 2.2.1 Supporting Case Laws: CIT vs. Shri Ram Singh (2008) 217 CTR (Raj) 345: (2008) 306 ITR 343 (Raj) (DC 1-6). The Rajasthan High Court construed the words used by Parliament in s.147 particularly the words that the AO may assess or reassess such income and also any other income chargeable to tax which has escaped assessment and which comes to his notice subsequently in the course of proceedings under s.147. The Hon'ble Court held as follo…

Shree Auro Iron Limited, Jaipur vs. Principal Commissioner of Income Tax-I, Jaipur

In the result, this appeal of the assessee is allowed

ITA 788/JPR/2024[2016-17]Status: DisposedITAT Jaipur12 Mar 2025AY 2016-17
For Appellant: Shri Pravin Saraswant, CAFor Respondent: Mrs. Alka Gautam, CIT DR
Section 142(1)Section 143Section 145ASection 147Section 148Section 151Section 263Section 48

…nsequently, we answer the first part of question in affirmative in favour of revenue and the second part of the question against the revenue." We also quote the case of Hon'ble jurisdictional High Court of Rajasthan in the case of CIT vs Shri Ram Singh [2008] 306 ITR 343 (Raj.) wherein it was held that :- “32. The result of the aforesaid discussion is, that the question framed, in the order dated. 23rd May, 2006, is required to be, and is, answered in the manner, that the Tribunal was not justified in holding, that the proceedings for reassessment under section 148/147 were initiated by the AO, on non-existing fa…

Income Tax Officer, Jaipur vs. Kedia Builders and Colonizers Private Limited, Jaipur

In the result, all appeals of the revenue are stands dismissed

ITA 901/JPR/2024[2014-15]Status: DisposedITAT Jaipur11 Mar 2025AY 2014-15

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Sh. Sidharth RankaFor Respondent: Mrs. Anita Rinesh, JCIT-DR
Section 143(3)Section 147

…he Ld. AO had no jurisdiction to make any other addition i.e. to go beyond the Kedia Builders and Colonizers Pvt. Ltd., Jaipur jurisdiction assumed by issue of notice u/s 148 of the Act. The Hon'ble jurisdictional Rajasthan High Court in the case of Ram Singh 306 ITR 343 has held as under- “28. If considered on that principle, leaving apart for the moment, the aspect of interpretation of the word "and" as "or", the existence of the word "also" is of a great significance, being of conjunctive nature, and leaves no manner of doubt in our opinion, that it is only when, in proceedings under section 147 the AO, asses…

Income Tax Officer, Jaipur vs. Kedia Builders and Colonizers Private Limited, Jaipur

In the result, all appeals of the revenue are stands dismissed

ITA 875/JPR/2024[2016-17]Status: DisposedITAT Jaipur11 Mar 2025AY 2016-17
For Appellant: Sh. Sidharth RankaFor Respondent: Mrs. Anita Rinesh, JCIT-DR
Section 143(3)Section 147

…make any other addition i.e. to go beyond the 11 ITA No. 872 & others/JP/2024 Kedia Builders and Colonizers Pvt. Ltd., Jaipur jurisdiction assumed by issue of notice u/s 148 of the Act. The Hon’ble jurisdictional Rajasthan High Court in the case of Ram Singh 306 ITR 343 has held as under- “28. If considered on that principle, leaving apart for the moment, the aspect of interpretation of the word "and" as "or", the existence of the word "also" is of a great significance, being of conjunctive nature, and leaves no manner of doubt in our opinion, that it is only when, in proceedings under section 147 the AO, asses…

Income Tax Officer, Jaipur vs. Kedia Builders and Colonizers Private Limited, Jaipur

ITA 873/JPR/2024[2013-14]Status: DisposedITAT Jaipur11 Mar 2025AY 2013-14
For Appellant: Sh. Sidharth RankaFor Respondent: Mrs. Anita Rinesh, JCIT-DR
Section 143(3)Section 147

…efore issue of notice u/s 148 of the Act, then the Ld. AO had no jurisdiction to make any other addition i.e. to go beyond the jurisdiction assumed by issue of notice u/s 148 of the Act. The Hon'ble jurisdictional Rajasthan High Court in the case of Ram Singh 306 ITR 343 has held as under- “28. If considered on that principle, leaving apart for the moment, the aspect of interpretation of the word "and" as "or", the existence of the word "also" is of a great significance, being of conjunctive nature, and leaves no manner of doubt in our opinion, that it is only when, in proceedings under section 147 the AO, assess…

Income Tax Officer, Jaipur vs. Kedia Builders and Colonizers Private Limited, Jaipur

In the result, all appeals of the revenue are stands dismissed

ITA 872/JPR/2024[2012-13]Status: DisposedITAT Jaipur11 Mar 2025AY 2012-13
For Appellant: Sh. Sidharth RankaFor Respondent: Mrs. Anita Rinesh, JCIT-DR
Section 143(3)Section 147

…make any other addition i.e. to go beyond the 12 ITA No. 872 & others/JP/2024 Kedia Builders and Colonizers Pvt. Ltd., Jaipur jurisdiction assumed by issue of notice u/s 148 of the Act. The Hon'ble jurisdictional Rajasthan High Court in the case of Ram Singh 306 ITR 343 has held as under- “28. If considered on that principle, leaving apart for the moment, the aspect of interpretation of the word "and" as "or", the existence of the word "also" is of a great significance, being of conjunctive nature, and leaves no manner of doubt in our opinion, that it is only when, in proceedings under section 147 the AO, assess…

Kailash Chand, Jaipur vs. ITO Ward, Behror

In the result, the appeal of the assessee is allowed

ITA 565/JPR/2024[2012-13]Status: DisposedITAT Jaipur10 Mar 2025AY 2012-13

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Judicial Member)

For Appellant: Sh. Mahendra Gargieya, Adv. &For Respondent: Sh. Dinesh Badgujar, Addl. CIT
Section 142(1)Section 144Section 144BSection 147Section 148Section 234A

…e income believed to have been escaped, has not been made, no addition of any other income could be made u/s 147, more so when prescribed legal procedure was not followed. 2.2 Supporting Case Laws: 2.2.1 CIT vs. Shri Ram Singh (2008) 217 CTR (Raj) 345: (2008) 306 ITR 343 (Raj) (DC 1-6). The Rajasthan High Court construed the words used by Parliament in s. 147 particularly the words that the AO may assess or reassess such income and also any other income chargeable to tax which has escaped assessment and which comes to his notice subsequently in the course of the proceedings under s. 147. The Hon’ble Court held as…

Soyala Gram Sewa Sahakari Samiti Limited, Tonk vs. ITO, Tonk

In the result, appeal of the assessee is allowed

ITA 1116/JPR/2024[2015-16]Status: DisposedITAT Jaipur08 Jan 2025AY 2015-16

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI GAGAN GOYAL (Accountant Member)

For Appellant: Shri Mukesh Khandelwal (CA)For Respondent: Shri Gautam Singh Choudhary, JCIT
Section 147Section 250Section 253(3)Section 80A(5)Section 80P

…s framed for issue of notice u/s 148 the 8 Soyala Gram Sewa Sahakari Samiti Ltd., Tonk. ld. AO was not entitled to make other disturbances in the ITR. The appellant relies on following judicial pronouncements in this regard :- 1. CIT vs Shri Ram Singh [2008] 306 ITR 343 (Raj.) – Relevant Para no. 29 and 32 at case law APB 8. 2. CIT vs. Jet Airways (I) Ltd. (2011) 331 ITR 236 (Bom)(HC) – Relevant para no. 16 and 17 at case law APB 17 3. Ranbaxy Laboratories Ltd. - vs. CIT (2011) 336 ITR 136 (Delhi High Court) - Relevant para no. 21 at case law APB 28. 4. ITO v Bidbhanjan Investment & Trading CO (P ) Ltd ( 2011) 5…

Damji J Gala, Khandilkar Road vs. ITO 19(1)(4), Tardeo Road

In the result the appeal filed by the assessee stands partly

ITA 3407/MUM/2024[2010-11]Status: DisposedITAT Mumbai16 Dec 2024AY 2010-11

Bench: Smt Beena Pillai & Shri Prabhash Shankar

Section 147Section 148Section 2Section 2(47)

…income in respect of any other issue though the reasons for such issue had not been included in the reasons recorded under section 148(2). 14. The second line of precedent is reflected in a judgment of the Rajasthan High Court in CIT v. Shri Ram Singh [2008] 306 ITR 343 . The Rajasthan High Court construed the words used by Parliament in section 147 particularly the words that the Assessing Officer 'may assess or reassess such income and also any other income chargeable to tax which has escaped assessment and which comes to his notice subsequently in the course of the proceedings' under section 147. The Rajastha…

Lakhmi Chand Yadav, Faridabad vs. ITO, Ward-1(4), Faridabad

In the result, the appeal filed by the revenue is dismissed and the substantial questions of law are answered against the revenue

ITA 516/DEL/2020[2011-12]Status: DisposedITAT Delhi03 Dec 2024AY 2011-12

Bench: Sh. Satbeer Singh Godara & Sh. M. Balaganeshita No. 516/Del/2020 : Asstt. Year : 2011-12 Lakhmi Chand Yadav, Vs Income Tax Officer, Village Mirzapur Hardet Haveli Ward-1(4), Mujehri, Faridabad, Haryana-121004 Faridabad-121001 (Appellant) (Respondent) Pan No. Aaepy4744P Assessee By : Sh. M. K. Gupta, Ca Revenue By : Sh. B. S. Anand, Sr. Dr Date Of Hearing: 25.11.2024 Date Of Pronouncement: 03.12.2024 Order Per Satbeer Singh Godara: This Assessee’S Appeal For Assessment Year 2011-12, Arises Against The Order Of Cit(A), Faridabad Dated 28.11.2019 In Case No. 10339/2018-19 In Proceedings U/S 143(3)/147 Of The Income Tax Act, 1961 (In Short “The Act”).

For Appellant: Sh. M. K. Gupta, CAFor Respondent: Sh. B. S. Anand, Sr. Dr
Section 133ASection 143Section 143(3)Section 147Section 148Section 260A

…s and the decision in Majinder Singh Kang referred by the revenue was taken note of in Mohmed Juned Dadani and it was held that the explanatory memorandum to Explanation 3 to Section 147 of the Act was not brought to the notice of the High Court in the (2008) 306 ITR 343 (Raj) (2011) 331 ITR 236 (Bom) (2011) 336 ITR 136 (2018) 99 taxmann.com 312 (SC) (2022) 138 taxmann.com 296 (Bombay) (2013) 355 ITR 172 (Guj.) (2012) 344 ITR 641 (Chattisgarh) (2008) 306 ITR 343 (Raj) (2017) 394 ITR 733 (Mad) (2016) 387 ITR 416 (Del) (2003) 259 ITR 19 (SC) (2017) 291 CTR 272 (P&H) ITAT NO. 143 OF 2021 said decision. It is further…

Pr. Commissioner of Income Tax -7 vs. Sunlight Tour and Travels Pvt. Ltd

ITA/222/2022HC Delhi12 Nov 2024

Bench: HON'BLE MR. JUSTICE VIBHU BAKHRU,HON'BLE DR. JUSTICE SWARANA KANTA SHARMA

Section 139Section 143(3)Section 147Section 148Section 260A

…cts of the said decision: “13. Similar contention was raised before the Division Bench of the Bombay High Court in the case of Jet Airways (2011) 331 ITR 236 (Bom). The court referred to the interpretation by the Rajasthan High Court in Ram Singh (2008) 306 ITR 343 (Raj) wherein it was observed as under (page 246): "It is only when, in proceedings under section 147 the Assessing Officer, assesses or reassesses any income chargeable to tax which has escaped assessment for any assessment year, with respect to which he had 'reason to believe' to be so, then only, in addition, he can also put to tax, th…

Amros Engineering Pvt Ltd, Jaipur vs. ITO WD 4(4), Jpr, Jaipur

ITA 823/JPR/2024[2013-14]Status: DisposedITAT Jaipur09 Sept 2024AY 2013-14

Bench: SHRI SANDEEP GOSAIN (Judicial Member)

For Appellant: Shri S.L. Jain, AdvFor Respondent: Smt. Monisha Choudhary, Addl. CIT-DR
Section 134A

…P Ltd. Vs ITO (ITA No. 90/JP/2020)wherein the court relied on the decision of 1.Hon’ble supreme court (Bankipur Club Ltd. vs. CIT (1971) 82 ITR 831 (SC)) 2. Hon’ble Rajasthan High Court in the case of Commissioner of Income-tax v. Shri Ram Singh (Raj-HC)2008, 306 ITR 343 3. Hon’ble Bombay High Court in the case of CIT Vs Jet airways (I.) Ltd. 331 ITR 236 (Bom) 2.6 On the other hand ld DR appearing on behalf of the revenue relied on the orders passed by the revenue authorities. It was submitted that no such objection was taken at any stage by the appellant before the AO or before It was also 5 AMROS ENGINEERING P…

Thayappa Balakrishna, Bangalore vs. The Principal Commissioner of Income Tax, Bengaluru-1, Bengaluru

In the result, the appeal filed by the assessee stands allowed

ITA 1027/BANG/2024[2014-15]Status: DisposedITAT Bangalore22 Aug 2024AY 2014-15

Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahuassessment Year : 2014-15 Shri Thayappa Balakrishna, No. 987, 11Th Main, The Principal 1St Block, Commissioner Of 3Rd Stage, Income-Tax, Basaveshwaranagar, Bengaluru – 1. Vs. Bangalore – 560 079. Pan: Abdpb4893N Appellant Respondent : Shri Ravi Shankar .S.V, Assessee By Advocate Revenue By : Shri D.K. Mishra, Cit-Dr

For Respondent: Shri Ravi Shankar .S.V
Section 143(3)Section 147Section 148Section 263

…IN THE INCOME TAX APPELLATE TRIBUNAL ‘A’ BENCH : BANGALORE BEFORE SMT. BEENA PILLAI, JUDICIAL MEMBER AND SHRI LAXMI PRASAD SAHU, ACCOUNTANT MEMBER Assessment Year : 2014-15 Shri Thayappa Balakrishna, No. 987, 11th Main, The Principal 1st Block, Commissioner of 3rd Stage, Income-tax, Basaveshwaranagar, Bengaluru – 1. Vs. Bangalore – 560 079. PAN: ABDPB4893N APPELLANT RESPONDENT : Shri Ravi Shankar .S.V, Assessee by Advocate Revenue by : Shri D.K. Mishra, CIT-DR Date of Hearing : 22-07-2024 Date of Pronouncement : 22-08-2024 ORDER PER BEENA PILLAI, JUDICIAL MEMBER Present appeal arises out of order dated 29.03.2…