Neelam Cable Manufacturing Co. v. ACIT

63 ITD 1Income Tax Appellate Tribunal1997#4066 most cited

What is Neelam Cable Manufacturing Co. v. ACIT authority for?

Expenses incurred for services rendered in relation to a let-out property are deductible when computing the annual value of the property under Section 23 of the Income-tax Act, 1961.

29

judgments rely on this decision, according to BharatTax’s citation analysis of 366,339 Indian tax judgments — from 2016 to 2026.

Also referred to as

Neelam Cable Manufacturing Co. v. ACIT · 63 ITD 1 · Section 23 · Section 24 · deduction · service charges · security services · annual value · house property · let out property

Sections most often in play

Section 1961Section 12ASection 12A(1)(ac)Section 12ABSection 143(3)Section 1963Section 40(a)(i)Section 43B

Issues it is cited on

admission of additional evidencerule 46afirst appealreasonable causeappeal before the tribunalcompanydocumentinterestopportunity of being heardbusinesssection 143(3)india

Judgments citing Neelam Cable Manufacturing Co. v. ACIT

Hasbro Sa, Switzerland vs. Deputy Commissioner of Income Tax (International Tax), Circle 1(1)(1), Delhi, New Delhi

In the result, appeal filed by the assessee is allowed with above directions for statistical purposes

ITA 2842/DEL/2025[2020-21]Status: DisposedITAT Delhi21 Jan 2026AY 2020-21

Bench: Shri Ramit Kochar & Shri Raj Kumar Chauhan

Section 139(4)Section 143(1)Section 154Section 199Section 250

…Delhi have also held in the case Of Electra (Jaipur) (R) Lid v. IAC (1988) 26 ITD 236 that if the evidence is genuine, reliable, proves the assessee's case, then the assessee should not be denied the opportunity. Similarly it was held in Dwarka Prasad v. ITO 63 ITD 1 (TM) that additional evidence if in the interest of justice, and renders assistance to the authority in passing order, may be admitted. Other similar rulings are 68 TTJ 722, 231 ITR 1, 21 SOT 218, 293 [TR 53, 94 ITO 79 etc. In View of the guidance available in the afore-cited judicial pronouncements, I hold that the additional evidence as mentioned…

Pokharna Educational Trust, Shirur vs. CIT Exemption, Pune

In the result, both the appeals filed by the assessee are allowed for statistical purposes

ITA 44/PUN/2025[-]Status: DisposedITAT Pune27 Mar 2025

Bench: Shri R. K. Panda & Shri Vinay Bhamore

For Appellant: Shri Suhas Bora and Ms. Sampada IngaleFor Respondent: Shri Ajay Kumar Keshari, CIT
Section 12ASection 12A(1)(ac)Section 2Section 80G

…t. Keshav Mills Co. Ltd. v. CIT [56 ITR 365 (SC)] - The Hon'ble Supreme Court ruled that an appellate authority does not exceed its jurisdiction by admitting additional evidence if it is necessary for complete and effective adjudication. Dwarka Prasad v. ITO [63 ITD 1 (Patna) (TM)] - It was held that additional evidence should be admitted when it is crucial for rendering substantial justice. 4. Prayer: In view of the above, the appellant respectfully prays that Your Honour may kindly: Allow the admission of the additional evidence listed above under Rule 29 of the Income Tax (Appellate Tribunal) Rules, 1963. Cons…

Pokharna Educational Trust, Shirur vs. CIT Exemption, Pune

In the result, both the appeals filed by the assessee are allowed for statistical purposes

ITA 43/PUN/2025[-]Status: DisposedITAT Pune27 Mar 2025

Bench: Shri R. K. Panda & Shri Vinay Bhamore

For Appellant: Shri Suhas Bora and Ms. Sampada IngaleFor Respondent: Shri Ajay Kumar Keshari, CIT
Section 12ASection 12A(1)(ac)Section 2Section 80G

…t. Keshav Mills Co. Ltd. v. CIT [56 ITR 365 (SC)] - The Hon'ble Supreme Court ruled that an appellate authority does not exceed its jurisdiction by admitting additional evidence if it is necessary for complete and effective adjudication. Dwarka Prasad v. ITO [63 ITD 1 (Patna) (TM)] - It was held that additional evidence should be admitted when it is crucial for rendering substantial justice. 4. Prayer: In view of the above, the appellant respectfully prays that Your Honour may kindly: Allow the admission of the additional evidence listed above under Rule 29 of the Income Tax (Appellate Tribunal) Rules, 1963. Cons…

Ellora Construction Private Limited, Aurangabad vs. DCIT, Circle-1, Aurangabad

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 2163/PUN/2024[2018-19]Status: DisposedITAT Pune05 Mar 2025AY 2018-19

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2018-19 Ellora Construction Private Limited Dcit, Circle 1, Cidco Road, Azad Chowk, Vs. Aurangabad Aurangabad-431001 Pan: Aawca7578C (Appellant) (Respondent) Assessee By : Shri Suhas P Bora & Sampada Ingale Department By : Shri Ramnath P Murkunde Date Of Hearing : 04-03-2025 Date Of Pronouncement : 05-03-2025 O R D E R

For Appellant: Shri Suhas P Bora and Sampada IngaleFor Respondent: Shri Ramnath P Murkunde
Section 143(2)Section 36(1)(vii)

…Keshav Mills Co. Ltd. v. CIT [56 ITR 365 (SC)] - The Hon'ble Supreme Court ruled that an appellate authority does not exceed its jurisdiction by admitting additional evidence if it is necessary for complete and effective adjudication.  Dwarka Prasad v. ITO [63 ITD 1 (Patna) (TM)] - It was held that additional evidence should be admitted when it is crucial for rendering substantial justice. 4. Prayer: In view of the above, the appellant respectfully prays that Your Honour may kindly:  Allow the admission of the additional evidence listed above under Rule 29 of the Income Tax (Appellate Tribunal) Rules, 1963. …

Techman Buildwell Private Lmited, New Delhi vs. DCIT, Circle-25(2), New Delhi

The appeals of the assessee are partly allowed with the consequences following as per the

ITA 737/DEL/2020[2012-13]Status: DisposedITAT Delhi13 Jun 2024AY 2012-13

Bench: Shri Gs Pannu & Shri Anubhav Sharma

For Appellant: Shri Arta Trana Panda, AdvFor Respondent: Shri Amit Katoch, Sr. DR
Section 143(3)Section 43BSection 68

…d advance the cause of justice. Reliance is placed on following decisions; Smt. Prabhavati S Shah v. CIT (1998) 231 ITR 1 (Bom), CIT v. K Ravindranthan Nair (2004) 265 ITR 217 (Ker), Dwarika Prasad v. ITO (1997) 63 ITD 1 (Pat-TM). Abhay Kumar Shroff (1997) 63 ITD 144 (Pat-TM) and Electra (Jaipur) Ltd v. IAC 26 ITD 236 (Del). 6. It comes up that the appellant is a flagship company of the Techman group of companies and has developed various residential and commercial projects in Agra, Faridabad, Ghaziabad, Mathura, Modinagar and New Delhi. Appellant claims that the business of real estate requires substantia…

Techman Buildwell (P) Ltd., New Delhi vs. ACIT, New Delhi

The appeals of the assessee are partly allowed with the consequences following as per the

ITA 1618/DEL/2017[2011-12]Status: DisposedITAT Delhi13 Jun 2024AY 2011-12

Bench: Shri Gs Pannu & Shri Anubhav Sharma

For Appellant: Shri Arta Trana Panda, AdvFor Respondent: Shri Amit Katoch, Sr. DR
Section 143(3)Section 43BSection 68

…d advance the cause of justice. Reliance is placed on following decisions; Smt. Prabhavati S Shah v. CIT (1998) 231 ITR 1 (Bom), CIT v. K Ravindranthan Nair (2004) 265 ITR 217 (Ker), Dwarika Prasad v. ITO (1997) 63 ITD 1 (Pat-TM). Abhay Kumar Shroff (1997) 63 ITD 144 (Pat-TM) and Electra (Jaipur) Ltd v. IAC 26 ITD 236 (Del). 6. It comes up that the appellant is a flagship company of the Techman group of companies and has developed various residential and commercial projects in Agra, Faridabad, Ghaziabad, Mathura, Modinagar and New Delhi. Appellant claims that the business of real estate requires substantia…

Deputy Commissioner of Income Tax 12(2)(2), Mumbai vs. Group M Media (India) Private Limited, Mumbai

In the result the appeal filed by the revenue and cross objection filed by the assessee are stand dismissed

ITA 3087/MUM/2019[2011-12]Status: DisposedITAT Mumbai31 Oct 2023AY 2011-12

Bench: Aby T Varkey & Shri Amarjit Singhco No. 137/Mum/2021 (A.Y. 2011-12) Group M Media (India) Vs. Dcit-12(2)(2) Pvt. Ltd. Room No. 145, 1 St Floor, 8Th Floor, Commerz Aayakar Bhavan, International Business M.K. Road, Park, Oberoi Garden Mumbai-400020 City, Off Western Express Highway, Goregaon (E), Mumbai-400063 स्थायी लेखा सं./जीआइआर सं./ Pan/Gir No: Aaccm7365H Appellant .. Respondent Dcit-12(2)(2) Vs. Group M Media (India) Room No. 145, 1 St Floor, Pvt. Ltd. Aayakar Bhavan, 8Th Floor, Commerz M.K. Road, International Business Mumbai-400020 Park, Oberoi Garden City, Off Western Express Highway, Goregaon (E), Mumbai-400063 स्थायी लेखा सं./जीआइआर सं./ Pan/Gir No: Aaccm7365H Appellant .. Respondent Appellant By : Shri. Nikhil Tiwari Respondent By : Shri. Ganesh Rakh Date Of Hearing 27.10.2023 Date Of Pronouncement 31.10 .2023

For Appellant: Shri. Nikhil TiwariFor Respondent: Shri. Ganesh Rakh
Section 143(2)Section 143(3)Section 36(1)(iii)

…. Nirmiti Realities Pvt. Ltd. The Ld. Counsel has also placed reliance on the following judicial pronouncement to admit the additional evidence.  Prabhavati S. Shah (231 ITR 1) (Bom HC).  CIT Vs. Ganibhai Wahabbhai (1998) 232 ITR 900(MP)  Dwarka Prasad 63 ITD 1 (Pat) (TM)  Abhay Kumar Shroff 63 ITD 144 (Pat) (TM)  K. Venkataramiah Vs. A. Seetharama Reddy AIR 1963 (SC) 1526  Rajmoti Industries (1995) 52 ITD 286 11. On the other hand, the Ld. DR supported the order of lower authorities. P a g e | 10 ITA No. 2760, 3087/Mum/2019 & CO 137/Mum/2021 M/s Group Media M (India) Pvt. Ltd. 12. Heard both the s…

Anchor Electricals Pvt. Ltd., Mumbai vs. Jt. CIT - Ccc- 7(2)`, Mumbai

In the result, the appeal of the assessee is partly allowed

ITA 4940/MUM/2018[2014-15]Status: DisposedITAT Mumbai13 Oct 2022AY 2014-15

Bench: Shri Amarjit Singh & Shri Rahul Chaudharyanchor Electricals Vs. Joint Commissioner Of Private Limited Income-Tax, Central 3Rd Floor, I-Think Techno Circle-7(2) Campus, Pokhran Road Room No.655, 6Th Floor, No.2, Thane (W), Aayakar Bhavan, M.K. 400607 Road, Mumbai - 400020 स्थायी लेखा सं./जीआइआर सं./ Pan/Gir No: Aaeca2190C Appellant .. Respondent

For Appellant: M.P. Lohia &For Respondent: Yogesh Kamat
Section 143(3)Section 234CSection 271(1)(c)Section 274

…of trademark agreement dated 11.09.2014. The ld. Counsel has also placed reliance on the following case law for admitting additional evidences: “i. Prabhavati S. Shah 231 ITR 1 (Bom). ii. CIT Vs. Ganibhai Wahabbhai (1998) 232 ITR 900 (MP) iii. Dwarka Prasad 63 ITD 1 (Pat) (TM) iv. Abhay Kumar Shroff 63 ITD 144 (Pat (TM) v. K. Venkataramiah Vs. A. Seetharama Reddy AIR 1963 (SC) 1526 vi. Rajmoti Industries (1995) 52 ITD 286.” We have perused the additional evidences furnished by the assessee and also perused the finding of the DRP, it is observed that DRP had not directed the assessee to furnish any other eviden…

Kirloskar Industries Ltd, Pune vs. Deputy Commissioner of Income-Tax, Circle -14, Pune

Appeals are dismissed in above terms

ITA 524/PUN/2020[2016-17]Status: DisposedITAT Pune29 Aug 2022AY 2016-17

Bench: Shri S.S.Godara, Jm & Shri Dr. Dipak P. Ripote, Am आयकर अपीऱ सं. / Ita No. 523 & 524/Pun/2020 ननधधारण वषा / Assessment Year : 2015-16 & 2016-17

For Appellant: Shri C.H.Naniwadekar &For Respondent: Shri Arvind Desai
Section 10(34)Section 14Section 143(3)Section 14A

…ention as rightly pointed out by the CIT(A). Therefore, in the absence of such valid evidences, we find no infirmity in the order of CIT(A). The ld. AR placed on record order of Delhi Tribunal in the case of Neelam Cable Manufacturing Co. Vs. ACIT reported in 63 ITD 1. On perusal of the same the Tribunal held no separate deduction for security service charges is provided u/s. 24 of the Act but the service charges is to be deductible while computing the annual value u/s. 23 of the Act. In the present case, as discussed above, there was no break up provided by the assessee as pointed out by the CIT(A) and also Leav…

Kirloskar Industries Ltd, Pune vs. Deputy Commissioner of Income-Tax, Circle -14, Pune

Appeals are dismissed in above terms

ITA 523/PUN/2020[2015-16]Status: DisposedITAT Pune29 Aug 2022AY 2015-16

Bench: Shri S.S.Godara, Jm & Shri Dr. Dipak P. Ripote, Am आयकर अपीऱ सं. / Ita No. 523 & 524/Pun/2020 ननधधारण वषा / Assessment Year : 2015-16 & 2016-17

For Appellant: Shri C.H.Naniwadekar &For Respondent: Shri Arvind Desai
Section 10(34)Section 14Section 143(3)Section 14A

…ention as rightly pointed out by the CIT(A). Therefore, in the absence of such valid evidences, we find no infirmity in the order of CIT(A). The ld. AR placed on record order of Delhi Tribunal in the case of Neelam Cable Manufacturing Co. Vs. ACIT reported in 63 ITD 1. On perusal of the same the Tribunal held no separate deduction for security service charges is provided u/s. 24 of the Act but the service charges is to be deductible while computing the annual value u/s. 23 of the Act. In the present case, as discussed above, there was no break up provided by the assessee as pointed out by the CIT(A) and also Leav…

Pawan Kumar, New Delhi vs. ITO Ward - 43(2), New Delhi

Appeal are allowed for statistical purposes

ITA 7809/DEL/2019[2011-12]Status: DisposedITAT Delhi30 Mar 2022AY 2011-12

Bench: Shri Kul Bharat[Assessment Year: 2011-12

Section 144Section 148Section 69A

…fore same may kindly be set aside. Reliance is placed on the following:- a) ITA/140/DEL/2018 AY 2009-10 Dharampal Tyagi Vs. ITO, Meerut b) Tek Ram 262 CTR 118 (Hon'ble Supreme Court) Mukta Metal Works, 336 ITR 555 (Hon'ble P&H High Court) c) Dwarka Prasad 63 ITD 1 (Pat) (TM) Ganibhai Wahabbhai 232 ITR 900 MP d) Sri Shankar Khandasari Sugar Mills Vs. CIT (1992) 193 ITR 669(Karnataka HC) 3. That on facts and circumstances of the case and in the interest of principle of natural justice appellant prays that assessment order passed u/s 144 r. w. s. 147 may be set aside and restored to the file of Ld. AO to make th…

Kirloskar Industries Ltd, Pune vs. Deputy Commissioner of Income-Tax, Circle - 14, Pune

ITA 267/PUN/2018[2013-14]Status: DisposedITAT Pune11 Mar 2022AY 2013-14

Bench: Shri Inturi Rama Rao & Shri S.S. Viswanethra Ravi

For Appellant: Shri C.H. NaniwadekarFor Respondent: Shri Piyush Kumar Singh Yadav
Section 10(34)Section 14A

…ention as rightly pointed out by the CIT(A). Therefore, in the absence of such valid evidences, we find no infirmity in the order of CIT(A). The ld. AR placed on record order of Delhi Tribunal in the case of Neelam Cable Manufacturing Co. Vs. ACIT reported in 63 ITD 1. On perusal of the same the Tribunal held no separate deduction for security service charges is provided u/s. 24 of the Act but the service charges is to be deductible while computing the annual value u/s. 23 of the Act. In the present case, as discussed above, there was no break up provided by the assessee as pointed out by the CIT(A) and also Leav…

Kirloskar Industries Ltd, Pune vs. Deputy Commissioner of Income-Tax, Pune

ITA 787/PUN/2017[2011-12]Status: DisposedITAT Pune11 Mar 2022AY 2011-12

Bench: Shri Inturi Rama Rao & Shri S.S. Viswanethra Ravi

For Appellant: Shri C.H. NaniwadekarFor Respondent: Shri Piyush Kumar Singh Yadav
Section 10(34)Section 14A

…ention as rightly pointed out by the CIT(A). Therefore, in the absence of such valid evidences, we find no infirmity in the order of CIT(A). The ld. AR placed on record order of Delhi Tribunal in the case of Neelam Cable Manufacturing Co. Vs. ACIT reported in 63 ITD 1. On perusal of the same the Tribunal held no separate deduction for security service charges is provided u/s. 24 of the Act but the service charges is to be deductible while computing the annual value u/s. 23 of the Act. In the present case, as discussed above, there was no break up provided by the assessee as pointed out by the CIT(A) and also Leav…

Kirloskar Industries Ltd, Pune vs. Deputy Commissioner of Income-Tax, Circle - 14 (5), Pune

ITA 268/PUN/2018[2014-15]Status: DisposedITAT Pune11 Mar 2022AY 2014-15

Bench: Shri Inturi Rama Rao & Shri S.S. Viswanethra Ravi

For Appellant: Shri C.H. NaniwadekarFor Respondent: Shri Piyush Kumar Singh Yadav
Section 10(34)Section 14A

…ention as rightly pointed out by the CIT(A). Therefore, in the absence of such valid evidences, we find no infirmity in the order of CIT(A). The ld. AR placed on record order of Delhi Tribunal in the case of Neelam Cable Manufacturing Co. Vs. ACIT reported in 63 ITD 1. On perusal of the same the Tribunal held no separate deduction for security service charges is provided u/s. 24 of the Act but the service charges is to be deductible while computing the annual value u/s. 23 of the Act. In the present case, as discussed above, there was no break up provided by the assessee as pointed out by the CIT(A) and also Leav…

Kirloskar Industries Ltd, Pune vs. Assistant Commissioner of Income Tax, Pune

ITA 1383/PUN/2017[2012-13]Status: DisposedITAT Pune11 Mar 2022AY 2012-13

Bench: Shri Inturi Rama Rao & Shri S.S. Viswanethra Ravi

For Appellant: Shri C.H. NaniwadekarFor Respondent: Shri Piyush Kumar Singh Yadav
Section 10(34)Section 14A

…ention as rightly pointed out by the CIT(A). Therefore, in the absence of such valid evidences, we find no infirmity in the order of CIT(A). The ld. AR placed on record order of Delhi Tribunal in the case of Neelam Cable Manufacturing Co. Vs. ACIT reported in 63 ITD 1. On perusal of the same the Tribunal held no separate deduction for security service charges is provided u/s. 24 of the Act but the service charges is to be deductible while computing the annual value u/s. 23 of the Act. In the present case, as discussed above, there was no break up provided by the assessee as pointed out by the CIT(A) and also Leav…

DCIT, New Delhi vs. M/S Arham It Infrastructure Pvt. Ltd., New Delhi

In the result the appeal of the Revenue in ITA No

ITA 5300/DEL/2016[2012-13]Status: DisposedITAT Delhi27 Jul 2021AY 2012-13

Bench: Shri N.K. Billaiya & Shri K.N. Chary[A.Y 2013-14]

For Appellant: Shri Sudesh Garg, AdvFor Respondent: Shri Jagdish Singh, Sr. DR

…pellant, rent received is separately offered as income from house property. There were no separate receipts for maintenance of common facilities as in the case of the appellant. 7. Neelam Cable Mfg. Co. vs. ACIT The assessee let out property which (ITAT, Del) 63 ITD 1 included incidental charges. The ITAT has allowed the security services charges claimed by the assessee as deductible. It amounts to allowing the expenses incurred in respect of services rendered. 8. K. Bhaskaran Nair Vs CIT (Ker) 177 The assessee let out lodging house Taxman 478 charging separate rent for building and furniture. It is not a case of…

Niit Technologies Ltd., New Delhi vs. ACIT, New Delhi

In the result, both the appeals of the assessee are partly allowed and the appeal of Revenue for assessment year 2007-08

ITA 5525/DEL/2013[2008-09]Status: DisposedITAT Delhi28 Jan 2020AY 2008-09

Bench: Shri Bhavnesh Saini & Shri O.P. Kant

For Appellant: 1. That the Commissioner of Income-Tax (Appeals) erred on facts and in law in up
Section 14ASection 35D

…AT Delhi have also held in the case of Electra (Jaipur) (P) Ltd. vs. lAC (26 ITO 236) that if the evidence is genuine, reliable, proves the assessee's case, then the assessee should not be denied the opportunity. Similarly it was held in Dwarka Prasad VIs ITO 63 ITD 1 (TM) that additional evidence if in the interest of justice, and renders assistance to the authority in passing order, may be admitted. Other similar rulings are 68 TTJ 722, 231 ITR 1, 21 SOT ITA Nos. 5524 & 5525/Del/2013 218,293 ITR 53, 941TD 79 etc. In view of the guidance available in the afore-cited judicial pronouncements, 1 hold that the addi…

Niit Technologies Ltd., New Delhi vs. ACIT, New Delhi

In the result, both the appeals of the assessee are partly allowed and the appeal of Revenue for assessment year 2007-08

ITA 5524/DEL/2013[2007-08]Status: DisposedITAT Delhi28 Jan 2020AY 2007-08

Bench: Shri Bhavnesh Saini & Shri O.P. Kant

For Appellant: 1. That the Commissioner of Income-Tax (Appeals) erred on facts and in law in up
Section 14ASection 35D

…AT Delhi have also held in the case of Electra (Jaipur) (P) Ltd. vs. lAC (26 ITO 236) that if the evidence is genuine, reliable, proves the assessee's case, then the assessee should not be denied the opportunity. Similarly it was held in Dwarka Prasad VIs ITO 63 ITD 1 (TM) that additional evidence if in the interest of justice, and renders assistance to the authority in passing order, may be admitted. Other similar rulings are 68 TTJ 722, 231 ITR 1, 21 SOT ITA Nos. 5524 & 5525/Del/2013 218,293 ITR 53, 941TD 79 etc. In view of the guidance available in the afore-cited judicial pronouncements, 1 hold that the addi…

ACIT, New Delhi vs. M/S Niit Technologies Ltd., New Delhi

In the result, both the appeals of the assessee are partly allowed and the appeal of Revenue for assessment year 2007-08

ITA 5492/DEL/2013[2008-09]Status: DisposedITAT Delhi28 Jan 2020AY 2008-09

Bench: Shri Bhavnesh Saini & Shri O.P. Kant

For Appellant: 1. That the Commissioner of Income-Tax (Appeals) erred on facts and in law in up
Section 14ASection 35D

…AT Delhi have also held in the case of Electra (Jaipur) (P) Ltd. vs. lAC (26 ITO 236) that if the evidence is genuine, reliable, proves the assessee's case, then the assessee should not be denied the opportunity. Similarly it was held in Dwarka Prasad VIs ITO 63 ITD 1 (TM) that additional evidence if in the interest of justice, and renders assistance to the authority in passing order, may be admitted. Other similar rulings are 68 TTJ 722, 231 ITR 1, 21 SOT ITA Nos. 5524 & 5525/Del/2013 218,293 ITR 53, 941TD 79 etc. In view of the guidance available in the afore-cited judicial pronouncements, 1 hold that the addi…

ACIT, New Delhi vs. M/S Niit Technologies Ltd., New Delhi

In the result, both the appeals of the assessee are partly allowed and the appeal of Revenue for assessment year 2007-08

ITA 5491/DEL/2013[2007-08]Status: DisposedITAT Delhi28 Jan 2020AY 2007-08

Bench: Shri Bhavnesh Saini & Shri O.P. Kant

For Appellant: 1. That the Commissioner of Income-Tax (Appeals) erred on facts and in law in up
Section 14ASection 35D

…AT Delhi have also held in the case of Electra (Jaipur) (P) Ltd. vs. lAC (26 ITO 236) that if the evidence is genuine, reliable, proves the assessee's case, then the assessee should not be denied the opportunity. Similarly it was held in Dwarka Prasad VIs ITO 63 ITD 1 (TM) that additional evidence if in the interest of justice, and renders assistance to the authority in passing order, may be admitted. Other similar rulings are 68 TTJ 722, 231 ITR 1, 21 SOT ITA Nos. 5524 & 5525/Del/2013 218,293 ITR 53, 941TD 79 etc. In view of the guidance available in the afore-cited judicial pronouncements, 1 hold that the addi…

Neelam Cable Manufacturing Co. v. ACIT (63 ITD 1) — Cited in 29 Judgments | BharatTax