Parashuram Pottery Works Co. Ltd. v. ITO

106 ITR 1Supreme Court of India1977#143 most cited

What is Parashuram Pottery Works Co. Ltd. v. ITO authority for?

The principle of finality dictates that stale issues should not be reactivated, and lapse of time brings repose to judicial and quasi-judicial controversies. A Commissioner cannot substitute their judgment for the Assessing Officer's unless the assessment order is legally erroneous, not merely less elaborate, thus limiting revisionary powers under Section 263.

486

judgments rely on this decision, according to BharatTax’s citation analysis of 367,154 Indian tax judgments — from 1991 to 2026.

Also referred to as

Parashuram Pottery Works Co. Ltd. v. ITO · Parashuram Pottery · Section 263 · erroneous order · revision power · substitution of Commissioner's judgment · finality of assessment · stale issues · judicial precedent · 106 ITR 1

Sections most often in play

Section 143(3)Section 147Section 148Section 263Section 142(1)Section 151Section 69CSection 68
Read the full judgment

Issues it is cited on

section 10(31a)section 100section 76section 142(2c)section 153b(1)(b)section 150(1)section 153b(1)rectification under section 154section 144basection 33(4)section 206csection 158bc

Judgments citing Parashuram Pottery Works Co. Ltd. v. ITO

Aarav Financial Services Pvt. Ltd., Ahmedabad vs. The Dy. CIT, Cent. Circle-1(1), Ahmedabad

In the result, all the four appeals of respective assessees are partly allowed

ITA 13/AHD/2024[2012-13]Status: DisposedITAT Ahmedabad22 Oct 2024AY 2012-13

Bench: Ms. Suchitra Kamble (Judicial Member), Shri Makarand V. Mahadeokar (Accountant Member)

For Appellant: Shri Deepak R. Shah, A.RFor Respondent: Shri Prateek Sharma, Sr. D.R
Section 145Section 147Section 148

…self. The ld. A.R. relied upon the following decisions:- i) NDTV 271 taxman 1 (SC) I.T.A Nos. 10 to 13/Ahd/2024 A.Y. 2011-12 to 2012-13 Page No. 10 ii) Calcutta Discount 41 ITR 191 (SC) iii) Bombay Stock Exchange 365 ITR 181 (Bom HC) iv) Parshuram Potteries 106 ITR 1 (SC) The ld. A.R. in respect of ground no. 1 related to reopening u/s. 147 relied upon the decision of NDTV 271 taxman 1 (SC), Calcutta Discount 41 ITR 191 (SC), Bombay Stock Exchange 365 ITR 181 Bom HC, Parshuram Potteries 106 ITR S (SC) as relates to merits of the case regarding disallowance of share trade loss of Rs. 2,94,763/- in the share of M…

Vicky Rajesh Jhaveri, Ahmedabad vs. The Dy.CIT, Cent. Circle-1(1), Ahmedabad

In the result, all the four appeals of respective assessees are partly allowed

ITA 12/AHD/2024[2012-13]Status: DisposedITAT Ahmedabad22 Oct 2024AY 2012-13

Bench: Ms. Suchitra Kamble (Judicial Member), Shri Makarand V. Mahadeokar (Accountant Member)

For Appellant: Shri Deepak R. Shah, A.RFor Respondent: Shri Prateek Sharma, Sr. D.R
Section 145Section 147Section 148

…self. The ld. A.R. relied upon the following decisions:- i) NDTV 271 taxman 1 (SC) I.T.A Nos. 10 to 13/Ahd/2024 A.Y. 2011-12 to 2012-13 Page No. 10 ii) Calcutta Discount 41 ITR 191 (SC) iii) Bombay Stock Exchange 365 ITR 181 (Bom HC) iv) Parshuram Potteries 106 ITR 1 (SC) The ld. A.R. in respect of ground no. 1 related to reopening u/s. 147 relied upon the decision of NDTV 271 taxman 1 (SC), Calcutta Discount 41 ITR 191 (SC), Bombay Stock Exchange 365 ITR 181 Bom HC, Parshuram Potteries 106 ITR S (SC) as relates to merits of the case regarding disallowance of share trade loss of Rs. 2,94,763/- in the share of M…

Vicky Rajesh Jhaveri, Ahmedabad vs. The Dy. CIT, Cent. Circle-1(1), Ahmedabad

In the result, all the four appeals of respective assessees are partly allowed

ITA 11/AHD/2024[2011-12]Status: DisposedITAT Ahmedabad22 Oct 2024AY 2011-12

Bench: Ms. Suchitra Kamble (Judicial Member), Shri Makarand V. Mahadeokar (Accountant Member)

For Appellant: Shri Deepak R. Shah, A.RFor Respondent: Shri Prateek Sharma, Sr. D.R
Section 145Section 147Section 148

…self. The ld. A.R. relied upon the following decisions:- i) NDTV 271 taxman 1 (SC) I.T.A Nos. 10 to 13/Ahd/2024 A.Y. 2011-12 to 2012-13 Page No. 10 ii) Calcutta Discount 41 ITR 191 (SC) iii) Bombay Stock Exchange 365 ITR 181 (Bom HC) iv) Parshuram Potteries 106 ITR 1 (SC) The ld. A.R. in respect of ground no. 1 related to reopening u/s. 147 relied upon the decision of NDTV 271 taxman 1 (SC), Calcutta Discount 41 ITR 191 (SC), Bombay Stock Exchange 365 ITR 181 Bom HC, Parshuram Potteries 106 ITR S (SC) as relates to merits of the case regarding disallowance of share trade loss of Rs. 2,94,763/- in the share of M…

Sagar Rajesh Jhaveri, Ahmedabad vs. The Dy.CIT, Cent. Circle-1(1), Ahmedabad

In the result, all the four appeals of respective assessees are partly allowed

ITA 10/AHD/2024[2011-12]Status: DisposedITAT Ahmedabad22 Oct 2024AY 2011-12

Bench: Ms. Suchitra Kamble (Judicial Member), Shri Makarand V. Mahadeokar (Accountant Member)

For Appellant: Shri Deepak R. Shah, A.RFor Respondent: Shri Prateek Sharma, Sr. D.R
Section 145Section 147Section 148

…self. The ld. A.R. relied upon the following decisions:- i) NDTV 271 taxman 1 (SC) I.T.A Nos. 10 to 13/Ahd/2024 A.Y. 2011-12 to 2012-13 Page No. 10 ii) Calcutta Discount 41 ITR 191 (SC) iii) Bombay Stock Exchange 365 ITR 181 (Bom HC) iv) Parshuram Potteries 106 ITR 1 (SC) The ld. A.R. in respect of ground no. 1 related to reopening u/s. 147 relied upon the decision of NDTV 271 taxman 1 (SC), Calcutta Discount 41 ITR 191 (SC), Bombay Stock Exchange 365 ITR 181 Bom HC, Parshuram Potteries 106 ITR S (SC) as relates to merits of the case regarding disallowance of share trade loss of Rs. 2,94,763/- in the share of M…

M/S. Rameshwar Enterprises, Mumbai vs. ITO -20(3)(1), Mumbai

ITA 1797/MUM/2023[2015-16]Status: DisposedITAT Mumbai09 Oct 2024AY 2015-16

Bench: MS. PADMAVATHY S, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Piyush ChajjedFor Respondent: Ms. Sanyogita Nagpal
Section 143(1)Section 143(3)Section 263Section 36(1)(iii)

…cipal Commissioner of Income Tax erred in initiating proceedings with a view to start the fishing and roving enquiries in order which is already concluded and the same is not permitted as held by Hon Supreme Court in case of Parashuram Pottery Works Co. Ltd., 106 ITR 1 and by the Bombay High Court in case of Gabriel India Ltd, 203 ITR 108. 3. On the facts and circumstances of the case, the Learned Principal Commissioner of Income Tax erred in passing the order under section 263 merely been change of opinion. The order under section 143(3) passed by the Ld. AO was not erroneous and neither prejudicial to the inter…

Comfort Intech Limited, Mumbai vs. Assistant Commissioner of Income Tax 4(1)(1) Mumbai, Aaykar Bhawan Mumbai

In the result, the appeals filed by the Assessee are allowed and the appeals of the Revenue are dismissed

ITA 2926/MUM/2024[2012-2013]Status: DisposedITAT Mumbai27 Sept 2024AY 2012-2013

Bench: Shri B.R. Baskaran & Shri Anikesh Banerjee

For Appellant: Shri Rajiv Khandelwal&For Respondent: Shri Yogendra T. Wakare, Sr.DR
Section 132Section 143(1)Section 143(3)Section 148

…e that no particular case was considered by the Hon'ble Supreme Court while deciding Ashish Agarwal (Supra). It is apposite to cite here an extract of the judgment of the Hon'ble Supreme Court in Parashuram Pottery Works Co. Ltd V/s. Income Tax Officer (1977) 106 ITR 1, which reads as under : ........... It has been said that the taxes are the price that we pay for civilization. If so, it is essential that those who are entrusted with the task of calculating and realising that price should familiarise themselves with the relevant provisions and become well-versed with the law on the subject. 14 Comfort Intech Li…

Comfort Intech Limited, Mumbai vs. Assistant Commissioner of Income Tax 4(1)(1) Mumbai, Aaykar Bhawan Mumbai

In the result, the appeals filed by the Assessee are allowed and the appeals of the Revenue are dismissed

ITA 2573/MUM/2024[2011-12]Status: DisposedITAT Mumbai27 Sept 2024AY 2011-12

Bench: Shri B.R. Baskaran & Shri Anikesh Banerjee

For Appellant: Shri Rajiv Khandelwal&For Respondent: Shri Yogendra T. Wakare, Sr.DR
Section 132Section 143(1)Section 143(3)Section 148

…e that no particular case was considered by the Hon'ble Supreme Court while deciding Ashish Agarwal (Supra). It is apposite to cite here an extract of the judgment of the Hon'ble Supreme Court in Parashuram Pottery Works Co. Ltd V/s. Income Tax Officer (1977) 106 ITR 1, which reads as under : ........... It has been said that the taxes are the price that we pay for civilization. If so, it is essential that those who are entrusted with the task of calculating and realising that price should familiarise themselves with the relevant provisions and become well-versed with the law on the subject. 14 Comfort Intech Li…

Assistant Commissioner of Income Tax- 4(1)(1), Mumbai vs. Comfort Intech Limited, Mumbai

In the result, the appeals filed by the Assessee are allowed and the appeals of the Revenue are dismissed

ITA 2218/MUM/2024[2011-12]Status: DisposedITAT Mumbai27 Sept 2024AY 2011-12

Bench: Shri B.R. Baskaran & Shri Anikesh Banerjee

For Appellant: Shri Rajiv Khandelwal&For Respondent: Shri Yogendra T. Wakare, Sr.DR
Section 132Section 143(1)Section 143(3)Section 148

…e that no particular case was considered by the Hon'ble Supreme Court while deciding Ashish Agarwal (Supra). It is apposite to cite here an extract of the judgment of the Hon'ble Supreme Court in Parashuram Pottery Works Co. Ltd V/s. Income Tax Officer (1977) 106 ITR 1, which reads as under : ........... It has been said that the taxes are the price that we pay for civilization. If so, it is essential that those who are entrusted with the task of calculating and realising that price should familiarise themselves with the relevant provisions and become well-versed with the law on the subject. 14 Comfort Intech Li…

Assistant Commissioner of Income Tax-4(1)(1), Mumbai vs. Comfort Intech Limited, Mumbai

In the result, the appeals filed by the Assessee are allowed and the appeals of the Revenue are dismissed

ITA 2216/MUM/2024[2012-13]Status: DisposedITAT Mumbai27 Sept 2024AY 2012-13

Bench: Shri B.R. Baskaran & Shri Anikesh Banerjee

For Appellant: Shri Rajiv Khandelwal&For Respondent: Shri Yogendra T. Wakare, Sr.DR
Section 132Section 143(1)Section 143(3)Section 148

…e that no particular case was considered by the Hon'ble Supreme Court while deciding Ashish Agarwal (Supra). It is apposite to cite here an extract of the judgment of the Hon'ble Supreme Court in Parashuram Pottery Works Co. Ltd V/s. Income Tax Officer (1977) 106 ITR 1, which reads as under : ........... It has been said that the taxes are the price that we pay for civilization. If so, it is essential that those who are entrusted with the task of calculating and realising that price should familiarise themselves with the relevant provisions and become well-versed with the law on the subject. 14 Comfort Intech Li…

Assistant Commissioner of Income Tax- 4(1)(1), Mumbai vs. Comfort Intech Limited, Mumbai

In the result, the appeals filed by the Assessee are allowed and the appeals of the Revenue are dismissed

ITA 2212/MUM/2024[2014-15]Status: DisposedITAT Mumbai27 Sept 2024AY 2014-15

Bench: Shri B.R. Baskaran & Shri Anikesh Banerjee

For Appellant: Shri Rajiv Khandelwal&For Respondent: Shri Yogendra T. Wakare, Sr.DR
Section 132Section 143(1)Section 143(3)Section 148

…e that no particular case was considered by the Hon'ble Supreme Court while deciding Ashish Agarwal (Supra). It is apposite to cite here an extract of the judgment of the Hon'ble Supreme Court in Parashuram Pottery Works Co. Ltd V/s. Income Tax Officer (1977) 106 ITR 1, which reads as under : ........... It has been said that the taxes are the price that we pay for civilization. If so, it is essential that those who are entrusted with the task of calculating and realising that price should familiarise themselves with the relevant provisions and become well-versed with the law on the subject. 14 Comfort Intech Li…

Sushila Bhaurao Deshmukh, Amravati vs. Principal Commissioner of Income Tax-1, Nagpur

In the result, appeal filed by the assessee is allowed

ITA 76/NAG/2022[2017-18]Status: DisposedITAT Nagpur20 Sept 2024AY 2017-18

Bench: Shri V. Durgarao & Shrik.M. Roy, Accountant, Member

For Appellant: ShriK.P. DewaniFor Respondent: Shri Sandeep Salunke
Section 143(3)Section 263Section 263(1)Section 54BSection 54E

…ssues should not be reactivated beyond a particular stage and that lapse of time must induce repose in and set at rest judicial and quasi-judicial controversies as it must in other spheres of human activity. (See Parashuram Pottery Works Co. Ltd. v. ITO[1977] 106 ITR 1 (SC) at page 10)... From the aforesaid definitions it is clear that an order cannot be termed as erroneous unless it is not in accordance with law. If an Income-tax Officer acting in accordance with law makes a certain assessment, the same cannot be branded as erroneous by the Commissioner simply because, according to him, the order should have bee…

Mahendra Kumar Sharma, Churu vs. PCIT (Central), Jaipur

In the result the appeal of the assessee is allowed

ITA 725/JPR/2024[2019-20]Status: DisposedITAT Jaipur29 Aug 2024AY 2019-20

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Sh. R. P. Sharma, CAFor Respondent: Sh. Arvind Kumar, CIT-DR
Section 133ASection 142(1)Section 143(2)Section 143(3)Section 263Section 69A

…before him which merely there is audit objection the order passed after examination of the issue cannot be taken again. To drive home to this contention we take support on a decision of apex court in the case of Parashuram Pottery Works Co. Ltd Vs ITO [ 1977] 106 ITR 1 “At the same time, we have to bear in mind that the policy of law is that there must be a point of finality in all legal proceedings, that stale issues should not be reactivated beyond a particular stage and that lapse of time must induce repose in and set at rest judicial and quasi judicial controversies as it must in other spheres of human activi…

Data Ingenious Global Limited, Alwar Rajasthan vs. ACIT, Central Circle, Alwar

Appeal is hereby dismissed on merits also", these findings are

ITA 676/JPR/2024[2008-09]Status: DisposedITAT Jaipur27 Aug 2024AY 2008-09
For Appellant: Shri P.C. Parwal, CAFor Respondent: Mrs. Monisha Choudhary, Addl. CIT-DR
Section 14ASection 292B

…s the order so passed is against the well established principle of judicial precedence and consistency as upheld by apex court in the case of Radhasaomi Satsang V/s Commissioner of Income-Tax 193 ITR 321 (SC) and Parshuram Pottery Works v/s Income Tax Officer 106 ITR 1 (SC), thus the order so passed is in total disregard of the apex court decision as referred to hereinabove and deserves to be quashed. 3. That the ld. Commissioner of Income-Tax (Appeals)-IV, Jaipur has erred in law as well as on the facts and circumstances of the case in mentioning that “in view of the absence of facts and evidences from the side…

Data Ingenious Global Limited, Alwar vs. ACIT, Central Circle, Alwar

ITA 652/JPR/2024[2011-12]Status: DisposedITAT Jaipur27 Aug 2024AY 2011-12
Section 139(1)Section 143(3)Section 153ASection 271(1)

…e same set of facts, thus the order so passed is against the well established principle of consistency as upheld by apex court in the case of Radhasaomi Satsang V/s Commissioner of Income-Tax 193 ITR 321 (SC) and Parshuram Pottery Works v/s Income Tax Officer 106 ITR 1 (SC), thus the order so passed is in total disregard of the apex court decision as referred to hereinabove and deserves to be quashed. 3. That the ld. Commissioner of Income-Tax (Appeals) – IV, Jaipur has erred in law as well as on the facts and circumstances of the case in not considering the assessment order dated 31.12.2017 passed under section…

Goyal Vegoils Limited, Kasar, Kota vs. DCIT, Circle -2, Kota

In the result ground no. 2 & 3 raised by the assessee

ITA 243/JPR/2024[2012-13]Status: DisposedITAT Jaipur27 Aug 2024AY 2012-13

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Sh. Rajendra Sisodia, CAFor Respondent: Sh. Anoop Singh, Addl. CIT
Section 143(3)Section 147Section 148Section 250

…n (a)Sardar Kehar Singh Vs. CIT [1992] 195 ITR 769 (Raj), (b) Taraben Ramanbhai Patel Vs. ITO [1995] 215 ITR 323(Guj ) and (c )CIT Vs. Hindusthan Motors Ltd. [1991] 192 ITR 619 (Cal ). (d) Hon’ble Apex Court in Parashuram Pottery Works Co. Ltd. Vs. ITO [1977] 106 ITR 1 (SC) 3.5 In a very recent decision, ITAT, Mumbai in the case of Jitendra Udaylal Jain vs. National Faceless Assessment Centre (NFAC) in ITA No. 2042/MUM/2023 held that Addition based on third party statement without tangible material is unsustainable. Hon’ble ITAT Bangalore in the case of Dr. Sreenivasulu Reddy Ponnaluru Vs ACIT in ITA No. ITA No.…

Pragati Power Corporation Ltd, New Delhi vs. ACIT, Circle 20(1), New Delhi

In the result, the appeal filed by the assessee is partly allowed as indicated above

ITA 1617/DEL/2023[2018-19]Status: DisposedITAT Delhi14 Aug 2024AY 2018-19

Bench: SHRI S.RIFAUR RAHMAN (Accountant Member), SHRI SUDHIR PAREEK (Judicial Member)

Section 115JSection 145(2)Section 32Section 36Section 36(1)(iii)Section 37Section 43ASection 46ASection 80I

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘F’: NEW DELHI BEFORE, SHRI S.RIFAUR RAHMAN, ACCOUNTANT MEMBER AND SHRI SUDHIR PAREEK, JUDICIAL MEMBER Pragati Power Asst. CIT Corporation Ltd. Circle-20(1) Himadri Rajghat Power Vs. New Delhi House, Office Complex Rajghat New Delhi-110002 PAN:AACCP 8035F (Appellant) (Respondent) Assessee by Shri Ajay Vohra, Sr. Adv., Shri S. Krishnan, Adv. & Shri Shaurya Jain, CA Respondent by Ms. Nimisha Singh, CIT-DR Date of Hearing 20/05/2024 Date of Pronouncement 14/08/2024 O R D E R PER S.RIFAUR RAHMAN, AM: 1. This appeal has been filed by the Assessee against the o…

Mahesh Reddy, Bangalore vs. Principal Commissioner of Income Tax, Bengaluru-2, Bengaluru

ITA 1379/BANG/2024[2017-18]Status: DisposedITAT Bangalore05 Aug 2024AY 2017-18

Bench: Shri Chandra Poojari & Shri Soundararajan K.

For Appellant: Sri K.R. Pradeep, A.R. & Ms. Girija G.P., A.RFor Respondent: Sri Kiran D., D.R
Section 143(3)Section 263Section 54

…issues should not be reactivated beyond a particular stage and that lapse of time must induce repose in and set at rest judicial and quasi- judicial controversies as it must in other spheres of human activity. (Parashuram Pottery Works Co. Ltd. v. ITO [1977] 106 ITR 1 (SC) at page 10) 6.10 There are other plethora of case laws from various High Courts and various benches of the Tribunal for the same effect. 6.11 Further, there was another angle to these cases when the Commissioner of Income Tax held the order of the Assessing Officer to be erroneous and at the conclusion of his order directs the Assessing Office…

Mahadev Enclave Pvt. Ltd., Jaipur vs. PCIT(Central), Jaipur

In the result, the appeal of the assessee is allowed

ITA 636/JPR/2024[2019-20]Status: DisposedITAT Jaipur22 Jul 2024AY 2019-20

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Sh. P. C. Parwal, CAFor Respondent: Sh. Anil Dhaka (CIT)
Section 10Section 143(3)Section 14ASection 263

…defendant is bound by the judgment, although it may be true enough that subsequent light or ingenuity might suggest some traverse which had not been taken." Again Hon’ble Supreme Court in case of Parashuram Pottery Works Co. Ltd. Vs. ITO 1977 CTR 32 / (1977) 106 ITR 1 held as under:- "At the same time, we have to bear in mind that the policy of law is that there must be a point of finality in all legal proceedings, that stale issues should not be reactivated beyond a particular stage and that lapse of time must induce repose in and set at rest judicial and quasi-judicial controversies as it must in other spheres…

Sh. Baljit Singh, Ludhiana vs. Pr. CIT, Ludhiana -1, Ludhiana

In the result, appeal of the Assessee is dismissed

ITA 416/CHANDI/2022[2017-18]Status: DisposedITAT Chandigarh22 May 2024AY 2017-18

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member), SHRI. PARESH M. JOSHI (Judicial Member)

For Appellant: Shri Rajiv Kaushal &For Respondent: Shri Rohit Sharma, CIT DR
Section 143(3)Section 263Section 263(1)Section 68Section 92C

…nserting Explanation 2 to sec. 263 of the Act, since it would lead to unending litigations and there would not be any point of finality in the legal proceedings. The Hon'ble Supreme Court has held in the case of Parashuram Pottery Works Co. Ltd Vs. ITO (1977)(106 ITR 1) that there must be a point of finality in all legal proceedings and the stale issues should not be re activated beyond a particular stage and the lapse of time must induce repose in and set at rest judicial and quasi-judicial controversies as it must in other spheres of human activity. 20. Further clause (a) of Explanation states that an order sh…

Mohammed Khalid Masud, Kolkata vs. ACIT, Cir-33, Kolkata.

In the result, the appeal of the assessee stands allowed

ITA 171/KOL/2024[2017-18]Status: DisposedITAT Kolkata21 May 2024AY 2017-18

Bench: Shri Sanjay Garg & Shri Sanjay Awasthii.T.A. No.171/Kol/2024 (Assessment Year: 2017-18) Mohammed Khalid Masud……..…..……............…...……………....Appellant 70, Karaya Road, Circus Row Kolkata - 700019. [Pan:Afapm6677G] Vs. Acit, Circle-33, Kolkata…...............................................…..…..... Respondent Appearances By: Shri Abhishak Bansal, Ca Appeared On Behalf Of The Appellant. Shri Divakar Chakraborty, Addl. Cit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : May 15, 2024 Date Of Pronouncing The Order : May 21 , 2024 आदेश / Order संजय गग", "या"यक सद"य "वारा / Per Sanjay Garg: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 07.11.2022 Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). 2. The Appeal Is Time Barred By 389 Days. A Separate Application For Condonation Of Delay Has Been Filed, Which Is Further Supported By An Affidavit Of The Petitioner Namely Mohammed Khalid Masud. Considering The Submissions Made In The Affidavit, The Delay In Filing The Appeal Is Hereby Condoned.

Section 250Section 50CSection 50C(2)

…आयकर अपील"य अ"धकरण, कोलकाता पीठ ‘ए’, कोलकाता IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH KOLKATA Before Shri Sanjay Garg, Judicial Member and Shri Sanjay Awasthi, Accountant Member I.T.A. No.171/Kol/2024 (Assessment Year: 2017-18) Mohammed Khalid Masud……..…..……............…...……………....Appellant 70, Karaya Road, Circus Row Kolkata - 700019. [PAN:AFAPM6677G] vs. ACIT, Circle-33, Kolkata…...............................................…..…..... Respondent Appearances by: Shri Abhishak Bansal, CA appeared on behalf of the appellant. Shri Divakar Chakraborty, Addl. CIT-DR, appeared on behalf of the Respondent. Dat…