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“Commissioner (Appeals)”

Chapter I - PreliminarySection 2 - DefinitionsSection 2(16A) / Section 1174,761 judgments

The decision most relied on for Commissioner (Appeals) is Jute Corporation of India Ltd. v. CIT (187 ITR 688), cited in 1,372 judgments on BharatTax.

Leading authorities on Commissioner (Appeals)

Jute Corporation of India Ltd. v. CIT
187 ITR 688 · 1991 · Supreme Court
1,372
citing judgments

The Commissioner of Income Tax (Appeals) possesses co-terminus powers with the Assessing Officer and can direct the Assessing Officer to perform actions he failed to do, but cannot introduce a new source of income in the assessment. The appellate assessment must be confined to the items of income that were the subject matter of the original assessment.

CIT v. Premkumar Arjundas Luthra (HUF)
297 CTR 614 · 2017 · High Court
659
citing judgments

The Commissioner of Income-tax (Appeals) cannot dismiss an appeal for non-prosecution or default in appearance. Under Section 250(6) of the Income-tax Act, the CIT(A) must decide the appeal on its merits, even in an ex parte proceeding.

Ahmedabad Electricity Co. Ltd. v. CIT
199 ITR 351 · 1993 · High Court
441
citing judgments

Appellate authorities can consider additional grounds for deduction, even if not originally claimed before the Assessing Officer or Appellate Assistant Commissioner, provided the facts are not disputed and it pertains to a legal claim for correct tax liability. This is because the purpose of an appeal is to ascertain the correct tax liability.

CIT v. Kanpur Coal Syndicate
53 ITR 225 · 1964 · Supreme Court
359
citing judgments

The Commissioner (Appeals) holds plenary powers when disposing of an appeal, with their scope being coterminous with the Assessing Officer. This allows the CIT(A) to exercise all powers of the AO, including admitting additional evidence and redetermining income.

CIT v. Shapoorji Pallonji Mistry
44 ITR 891 · 1962 · Supreme Court
278
citing judgments

The Commissioner of Income-tax (Appeals) cannot enhance an assessment by introducing a new source of income or by changing the head of income during appellate proceedings.

Commissioner of Income Tax Madras v. Chenniyappa Mudiliar
1 SCC 591 · 1985 · Reported
225
citing judgments

The appellate tribunal must render a proper decision on both facts and law, disposing of an appeal on its merits rather than dismissing it solely due to the appellant's absence. This obligation is derived from Section 33(4) of the Income Tax Act, 1922, and reflects principles of natural justice.

Mahindra and Mahindra Ltd. v. DCIT
30 SOT 374 · 2009 · ITAT
201
citing judgments

The Commissioner of Income Tax (Appeals) cannot expand the scope of an assessment or improve the Assessing Officer's case in a manner that usurps the revisional power of the Commissioner of Income Tax under Section 263 of the Income-tax Act.

CIT v. Jansampark Advertising & Marketing (P.) Ltd.
56 Taxmann.com 286 · 2015 · High Court
196
citing judgments

The Commissioner of Income-tax (Appeals) has an independent statutory obligation to conduct proper inquiries and verify facts, especially when the Assessing Officer has failed to do so. The CIT(A) must ensure effective inquiry is carried out before deleting additions or accepting additional evidence.

Judgments citing Commissioner (Appeals)

Shri Saraswati Kelavani Mandal, Kathlal vs. Income Tax Officer, Ward-1, Nadiad

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

ITA 1912/AHD/2024[2021-22]Status: DisposedITAT Ahmedabad10 Mar 2025AY 2021-22

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinhaआयकर अपील सं./Ita No. 1912/Ahd/2024 "नधा"रण वष"/Asstt. Year: 2021-22 Shri Saraswati Kelavani Mandal, The Income Tax Officer, Patel Jivabhai Dhulabhai, बनामVs Ward-1, . Katulal, Nadiad. Kheda-387630. Pan: Aajts0827Q ( ""यथ" /Respondent) (अपीलाथ" /Appellant Assessee By : Shri Girish B. Mehta, Ar Revenue By : Shri Prathvi Raj Meena, Cit.Dr सुनवाई क" तार"ख/Date Of Hearing : 05/03/2025 घोषणा क" तार"ख /Date Of Pronouncement: 10/03/2025 आदेश/O R D E R Per Narendra Prasad Sinha, Am: This Appeal Is Filed By The Assessee Against The Order Dated 04.09.2024 Passed By The Additional/Joint Commissioner Of Income Tax(Appeals), Mumbai, (Hereinafter Referred As Jcit(A)) Relevant To The Assessment Year 2021-22. 2. The Brief Facts Of The Case Are That The Assessee Is A Trust Running Educational Institutions. The Return Of Income For A.Y 2021-22 Was Filed On 09.02.2022, Declaring Total Income At Rs. Nil. In The Return Of Income, The Assessee Had Claimed Exemption Of Rs.2,42,88,361/- U/S.10(23C) Of The Act. The Return Of Assessee Was Processed By The Cpc On 09.12.2022 U/S.143(1) Of Asst. Year 2021-22

For Appellant: Shri Girish B. Mehta, ARFor Respondent: Shri Prathvi Raj Meena, CIT.DR
Section 10Section 143(1)

assessee was dismissed. 4. Now the assessee is in second appeal before us. The following grounds have been taken in this appeal. 1. The Commissioner(Appeals) has arbitrarily, non-judiciously and summarily dismissed the appeal of assessee charitable Trust, running schools( Grant in aid and Non Grantable) in rural area ... sole ground of limitation, therefore to be set aside. 2. The Commissioner (Appeals) has on the facts and in the circumstances of the case and in law, erroneously dismissed the appeal of the assessee without liberally appreciating the facts demonstrating good and sufficient cause for delay in filing of appeal

Jermel'S Accademy, Siliguri vs. I.T.O., Ward - 1(4), Siliguri

In the result, the appeal filed by the assessee is allowed as per the directions mentioned above

ITA 1652/KOL/2024[2016-2017]Status: DisposedITAT Kolkata10 Mar 2025AY 2016-2017

Bench: Shri Pradip Kumar Choubey & Shri Rakesh Mishra

Section 11(1)Section 11(1)(A)Section 12ASection 12A(2)Section 139(1)Section 143(2)Section 147Section 148Section 250

ground of absence of registration u/s. 12A for the impugned year and therefore its income becoming taxable. In fact, it is found, that the Commissioner (Appeals)(A) has accepted that reopening could not have been resorted to on account of absence of registration u/s. 12A for the impugned year ... income stands fulfilled. The section, it is found that nowhere prescribes the filing of return by any due date, therefore the findings of the Commissioner (Appeals) that the assessee having not filed its return within the prescribed time it had failed to comply with the requirement prescribed, is not tenable

Indianoil Adani Ventures Limited) (Formerly Known As Indian Oiltanking Ltd, Mumbai vs. Asstt. Comm. of Income Tax Circle 15(1)(2), Mumbai

The appeal of the assessee is partly allowed

ITA 6711/MUM/2024[2013-14]Status: DisposedITAT Mumbai10 Mar 2025AY 2013-14

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankar

For Appellant: Ms. Vasanti Patel,ARFor Respondent: Shri Mahesh Pamnani (Sr. DR)
Section 143(3)Section 14A

Therefore, it is duty cast upon him to consider all points of issue and give a finding. Further, section 250 clearly provides that the Commissioner (Appeals) may make further inquiry or direct the Assessing officer to undertake further inquiry before disposing of the appeal and reports the results ... inquiry to the commissioner (Appeals) and also, the order of the Commissioner (Appeals) shall state the point of determination, decision and the reasons for such decision while disposing of the appeal in writing. From the plain reading of the section, it emerges that the CIT Sam Ves Qa Page

Income Tax Officer, Mumbai vs. Priti Nilesh Jain Daga, Mumbai

In the result the appeal filed by the assessee stands allowed and appeal filed by the revenue stands dismissed

ITA 4616/MUM/2024[2014-15]Status: DisposedITAT Mumbai10 Mar 2025AY 2014-15

Bench: Shri Sandeep Gosain, () & Shri Prabhash Shankar, ()

Section 10(38)Section 139(1)Section 147Section 148Section 250Section 68

opportunity goes to root of the matter and strikes at the very foundation of the assessment and, therefore, renders the orders passed by the Commissioner (Appeals) and the Tribunal vulnerable. The assessee was bound to be provided with the material used against him apart from being permitting him to cross ... Assessing Officer rejected assessee's plea and made additions under sections 68 and 69 by relying on statements from 'entry operators' - On appeal, Commissioner (Appeals) accepted assessee's claim, noting that shares were purchased via Account Payee Cheques, held in a Demat Account for over 12 months, and sold through

Priti Nilesh Jain Daga, Mumbai vs. Income Tax Officer 19(2)(4), Mumbai

In the result the appeal filed by the assessee stands allowed and appeal filed by the revenue stands dismissed

ITA 4507/MUM/2024[2014-15]Status: DisposedITAT Mumbai10 Mar 2025AY 2014-15

Bench: Shri Sandeep Gosain, () & Shri Prabhash Shankar, ()

Section 10(38)Section 139(1)Section 147Section 148Section 250Section 68

opportunity goes to root of the matter and strikes at the very foundation of the assessment and, therefore, renders the orders passed by the Commissioner (Appeals) and the Tribunal vulnerable. The assessee was bound to be provided with the material used against him apart from being permitting him to cross ... Assessing Officer rejected assessee's plea and made additions under sections 68 and 69 by relying on statements from 'entry operators' - On appeal, Commissioner (Appeals) accepted assessee's claim, noting that shares were purchased via Account Payee Cheques, held in a Demat Account for over 12 months, and sold through

Devaraaya Atluri, Vijayawada vs. Income Tax Officer, Ward-2(1), Vijayawada

In the result, appeals of the assessee are treated as allowed for statistical purposes

ITA 64/VIZ/2025[2022-23]Status: DisposedITAT Visakhapatnam07 Mar 2025AY 2022-23

Bench: Shri K.Narasimha Chary & Shri Balakrishnan Sआ.अपी.सं / Ita No.64/Viz/2025 (निर्धारण वर्ा / Assessment Year: 2022-23) Devaraya Atluri Vs. Income Tax Officer Vijayawada Ward-2(1) [Pan : Aqzpa6317M] Vijayawada अपीलधर्थी / Appellant प्रत्‍यर्थी / Respondent निर्धाररती द्वधरध/Assessee By: Shri K.A.Sai Prasad, Ar रधजस्‍व द्वधरध/Revenue By: Dr.Aparna Villuri, Dr

For Appellant: Shri K.A.Sai Prasad, ARFor Respondent: Dr.Aparna Villuri, DR
Section 250Section 250(6)

evidence to substantiate the grounds raised. 5. Requirement of law under section 250 (6) of the Act is that the order of the Commissioner (Appeals) disposing of the appeal shall be in writing and shall state the points for determination, the decision thereon and the reason for the decision. Even

Assistant Commissioner of Income-Tax Circle-3(1)(1), Ahmedabad vs. Shri Govind Jairamdas Changlani, Ahmedabad

In the result, the appeal filed by the Revenue is hereby dismissed

ITA 183/AHD/2024[2016-17]Status: DisposedITAT Ahmedabad07 Mar 2025AY 2016-17

Bench: DR. BRR KUMAR (Vice President), Shri T.R. SENTHIL KUMAR (Judicial Member)

Section 143(3)Section 145ASection 68

witness to enable him to dispose of the appeal. In the facts of the present case, a perusal of the order of the Commissioner (Appeals) reveals that he has recorded therein that the Assessing Officer has not examined the aspect relating to genuineness of the commission expenses during the assessment ... asked to prove the genuineness of the commission expenses also. Therefore, it is evident that it was at the instance of the Commissioner (Appeals) that the assessee had produced the additional evidence on record, which would fall within the ambit of sub rule (4) of rule 46A of the rules

Frank S International Itl Limited, Mumbai vs. ACIT(It), Circle (2)(3)(1), Mumbai

In the result, the question of law referred to the Special Bench is answered in favour of the

ITA 5429/MUM/2024[2019-20]Status: DisposedITAT Mumbai07 Mar 2025AY 2019-20

Bench: Shri. Amarjit Singh, Am & Ms. Kavitha Rajagopal, Jm

Section 115JSection 143(1)Section 143(2)Section 143(3)Section 2Section 250Section 50Section 50(1)

assessment year 1995-96 and thereafter, the flat was treated as an investment and was so shown in the balance sheet. On appeal, the Commissioner (Appeals) concurred with the Assessing Officer. However, on second appeal, the Tribunal, solely relying on the entry in the balance sheet of the assessee wherein

Pranam Enterprise, Junagadh vs. DCIT, Circle-1(1), Rajkot

In the result, the appeal of the assessee is allowed

ITA 391/RJT/2024[2017-18]Status: DisposedITAT Rajkot06 Mar 2025AY 2017-18

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं./Ita No.391/Rjt/2024 Assessment Year: (2017-18) (Hybrid Hearing) Pranam Enterprise Vs. The Dcit Office No.3, City Centre, Opp. Circle-1(1), Rajkot New Collector Office, Junagadh – 362001, Gujarat "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaffp7926H (Assessee) (Respondent) Assessee By Shri Mehul Ranpura, Ar Respondent By Shri Abhimanyu Singh Yadav, Sr.Dr Date Of Hearing 18/12/2024 Date Of Pronouncement 06/03/2025 आदेश / O R D E R Per Dr. A. L. Saini, Am:

Section 142(1)Section 143(2)Section 143(3)Section 270ASection 270A(1)Section 274Section 80I

would be useful to reproduce the relevant extract of Section 270A of the Act for ready reference:- "(1) The Assessing Officer or the Commissioner (Appeals) or the Principal Commissioner or Commissioner may, during the course of any proceedings under this Act, direct that any person who has under-reported ... namely:— (a) the amount of income in respect of which the assessee offers an explanation and the Assessing Officer or 29-30 [the Joint Commissioner (Appeals) or] the Commissioner (Appeals) or the Commissioner or the Principal Commissioner, as the case may be, is satisfied that the explanation is bona fide

Income Tax Officer, Ward-1(1), Jaipur vs. Sujeet Singh Chouhan, Jaipur

In the result, the appeal of the revenue is allowed for statistical purposes with the above directions and the C

ITA 1361/JPR/2024[2017-18]Status: DisposedITAT Jaipur06 Mar 2025AY 2017-18

Bench: Shri Sandeep Gosain & Shri Gagan Goyalincome Tax Officer, Ward-1(1), Jaipur – 302 005 ...... Appellant Vs.

For Appellant: Mr. Vikash Rajvanshi, CA, Ld. ARFor Respondent: Mr. Manoj Kumar,JCIT, Ld. DR
Section 250Section 68Section 69A

section 251 of the Act r.w.r 46A of the Rules as under: Section - 251, Income-tax Act, 1961 - FA, 2024 Powers of the Joint Commissioner (Appeals) or theCommissioner (Appeals). 251. (1) In disposing of an appeal, theCommissioner (Appeals)] shall have the following powers— (a) in an appeal against an order ... other case, he may pass such orders in the appeal as he thinks fit. (1A) In disposing of an appeal, the Joint Commissioner (Appeals) shall have the following powers— (a) in an appeal against an order of assessment, he may confirm, reduce, enhance or 11annul the assessment

Subrata Mukherjee, Kolkata vs. DCIT, Cir. 5(1), Kolkata

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

ITA 471/KOL/2024[2011-12]Status: DisposedITAT Kolkata06 Mar 2025AY 2011-12

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 144Section 250Section 250(6)

this respect, it is relevant to examine the provisions of section 250(6) which are reproduced as under: “250(6) – The order of the Commissioner (Appeals) disposing of the appeal shall be in writing and shall state the points for determination, the decision thereon and the reason for the decision ... taxmann.com 348 (Madras) it has been held that a speaking order on merits with reasons and findings is to be passed by Commissioner (Appeals) on basis of ground raised in assessee's appeal; he cannot dispose the assessee's appeal merely by holding that Assessing Officer's order

Rishikesh Mercantile Pvt. Ltd., Kolkata vs. ITO, Ward-4(1), Kolkata

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

ITA 2431/KOL/2024[2012-13]Status: DisposedITAT Kolkata06 Mar 2025AY 2012-13

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 143(3)Section 245Section 250Section 250(4)

below, duly declare and affirm for and on behalf of the appellant 1. That the appeal filed by the Assessee Company before the Commissioner (Appeals) was disposed of by his ex-parte order dated 28.12.2023 passed by Commissioner (Appeals), NFAC New Delhi. 2. That the time for filing ... this respect, it is relevant to examine the provisions of section 250(6) which are reproduced as under: “250(6) – The order of the Commissioner (Appeals) disposing of the appeal shall be in writing and shall state the points for determination, the decision thereon and the reason for the decision

Archana Prashant Date, Pune vs. ITO, Ward 11(1), Pune

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

ITA 2472/PUN/2024[2013-14]Status: DisposedITAT Pune05 Mar 2025AY 2013-14

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.2472/Pun/2024 िनधा"रण वष" / Assessment Year : 2013-14

For Appellant: Shri Sarang GudhateFor Respondent: Shri Ramnath P. Murkunde
Section 142(1)Section 144Section 147Section 250Section 271(1)(b)Section 274

273B of the Act. "Section 271 FAILURE TO FURNISH RETURNS, COMPLY WITH NOTICES, CONCEALMENT OF INCOME, ETC. (1) If the Assessing Officer or the Commissioner (Appeals) in the course of any proceedings under this Act, is satisfied that any person – (a) Omitted) xxxxxxxxxxxxx xxxxxxxxxxxxx "273B. Penalty not to be imposed

Rajaram Krishnamurthy, Coimbatore vs. Deputy Commissioner of Income Tax, Coimbatore

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

ITA 2582/CHNY/2024[2019-20]Status: DisposedITAT Chennai05 Mar 2025AY 2019-20

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपील सं./Ita No.2582/Chny/2024 िनधा&रण वष&/Assessment Year: 2019-20 Shri Rajaram Krishnamurthy, Vs. The Dcit, No.38, Jai Nagar, Non-Corporate Circle 2, Kavundampalayam, Coimbatore. Coimbatore – 641 030. [Pan: Adcpr 2211H] (अपीलाथ"/Appellant) ()*थ"/Respondent) अपीलाथ" की ओर से/ Appellant By : Shri Vishva Padmanabhan, Ca )*थ" की ओर से /Respondent By : Ms. R. Anita, Addl.Cit सुनवाईकीतारीख/Date Of Hearing : 16.01.2025 घोषणाकीतारीख /Date Of Pronouncement : 05.03.2025

For Appellant: Shri Vishva Padmanabhan, CAFor Respondent: Ms. R. Anita, Addl.CIT
Section 144

favour of the asses-see. 5. The appeals are allowed. The order under challenge is set aside. The assessment order, that of the Commissioner (Appeals) and of the Tribunal are also set aside. The matter shall now be remanded to the assessing authority for fresh consideration, as aforestated. No order

Navbharat Potteries Private Limited, Mumbai vs. Deputy Commissioner of Income Tax - Circle 7(1)(1), Mumbai

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

ITA 2700/MUM/2024[2016-17]Status: DisposedITAT Mumbai05 Mar 2025AY 2016-17

Bench: Shri B R Baskaran & Shri Raj Kumar Chauhan

Section 142(1)Section 143(3)Section 147Section 148Section 22Section 23(1)(c)Section 250

expressed in case of Dr. Prabha Singhi. Therefore, applying the ratio laid down in the decisions referred to above, we hold that the learned Commissioner (Appeals) was justified in directing the Assessing Officer to allow the deduction under section 23(1)(c) to the assessee. Thus, grounds raised

Deputy Commissioner of Income Tax, (It)-4(2)(1), Mumbai vs. M/S. Siemens, Mumbai

In the result, the appeal by the Revenue is dismissed

ITA 3109/MUM/2016[2008-09]Status: DisposedITAT Mumbai05 Mar 2025AY 2008-09

Bench: Shri Amarjit Singhshri Sandeep Singh Karhaildeputy Commissioner Of Income Tax, (It)-4(2)(1), Scindia House, Balard Pier, N.M. Road, Mumbai – 400038 ……………. Appellant Maharashtra V/S M/S. Siemens Aktiengensellschaft, C/O, Bsr & Co. Lodha Excelus, 1St Floor, Apollo Mills Compound, M.N. Joshi Marg, Mahalaxmi, ……………. Respondent Mumbai - 400038, Maharashtra Pan – Aabcs8516K

For Appellant: Shri Nitesh JoshiFor Respondent: Shri Ajay Chandra, CIT-DR
Section 142(1)Section 143(2)Section 250Section 271GSection 92CSection 92D

international transaction fails to furnish any such information or document as required by sub-section (3) of section 92D, the Assessing Officer or the Commissioner (Appeals) may direct that such person shall pay, by way of penalty, a sum equal to two per cent of the value of the international ... prescribe the period for which the information and document shall be kept and maintained under that sub-section. (3) The Assessing Officer or the Commissioner (Appeals) may, in the course of any proceeding under this Act, require any person who has entered into an international transaction to furnish any information

Durgaraja Veerarouthula, Kakinada vs. Income Tax Officer, Ward - 1, Kakinada

In the result, appeals of the assessee are treated as allowed for statistical purposes

ITA 523/VIZ/2024[2017-2018]Status: DisposedITAT Visakhapatnam04 Mar 2025AY 2017-2018

Bench: Shri K.Narasimha Chary & Shri Balakrishnan S.

For Appellant: Shri G.V.N.Hari, ARFor Respondent: Dr. Aparna Villuri, DR
Section 250Section 250(6)

evidence to substantiate the grounds raised. 5. Requirement of law under section 250(6) of the Act is that the order of the Commissioner (Appeals) disposing of the appeal shall be in writing and shall state the points for determination, the decision thereon and the reason for the decision. Even

Konthala Rajendra Prasad, Anakapalli vs. Income Tax Officer, Ward-1, Anakapalle

In the result, appeals of the assessee are treated as allowed for statistical purposes

ITA 283/VIZ/2024[2008-09]Status: DisposedITAT Visakhapatnam04 Mar 2025AY 2008-09

Bench: Shri K.Narasimha Chary & Shri Balakrishnan S.आ.अपी.सं / Ita No.283/Viz/2024 (निर्धारण वर्ा / Assessment Year: 2008-09)

For Appellant: Shri P.C.Rao, ARFor Respondent: Dr.Aparna Villuri, LD.DR
Section 250Section 250(6)

evidence to substantiate the grounds raised. 7. Requirement of law under section 250 (6) of the Act is that the order of the Commissioner (Appeals) disposing of the appeal shall be in writing and shall state the points for determination, the decision thereon and the reason for the decision. Even

Bhargava Swaroop Chitturi, Hyderabad vs. ITO., Ward-6(1), Hyderabad

In the result, appeals of the assessee are treated as allowed for statistical purposes

ITA 1335/HYD/2024[2018-19]Status: DisposedITAT Hyderabad04 Mar 2025AY 2018-19

Bench: Shri K.Narasimha Chary & Shri Madhusudan Sawdiaआ.अपी.सं / Ita No.1335/Hyd/2024 (निर्धारण वर्ा / Assessment Year: 2018-19)

For Appellant: Shri C.Subrahmanyam, ARFor Respondent: Dr.Sachin Kumar, DR
Section 250Section 250(6)

evidence to substantiate the grounds raised. 5. Requirement of law under section 250 (6) of the Act is that the order of the Commissioner (Appeals) disposing of the appeal shall be in writing and shall state the points for determination, the decision thereon and the reason for the decision. Even

ACIT Circle 1 (1)&Tps, Mangaluru vs. M/S the South Canara District Central Co-Operative Bank Limited., Mangaluru

In the result, the appeal of the revenue is hereby dismissed

ITA 2333/BANG/2024[2018-19]Status: DisposedITAT Bangalore04 Mar 2025AY 2018-19

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Smt. Sheetal Borkar – AdvocateFor Respondent: Ms. Nandini Das, CIT (DR)
Section 145Section 22(1)

first take up the issue relating to amortization of premium on investment in government securities. Relevant grounds read as under : " i) The learned Commissioner (Appeals) ought to have appreciated that the appellant has to invest surplus fund in Government Securities as per RBI guidelines and the premium paid while investing