“advance tax”

Chapter XVII - Collection & Recovery (Advance tax)Chapter XVII-CSection 2(1) / Chapter XVII-C / ITR Schedule IT1,785 judgments

The decision most relied on for advance tax is Bajaj Tempo Ltd. v. CIT (196 ITR 188), cited in 289 judgments on BharatTax.

Leading authorities on advance tax

Bajaj Tempo Ltd. v. CIT

196 ITR 188 · 1992 · Supreme Court

289

citing judgments

Provisions in taxing statutes that grant incentives, concessions, or exemptions for promoting economic growth and industrialization must be interpreted liberally and purposively. Any restrictions placed on such provisions should also be construed reasonably to advance their objective, not frustrate it.

DIT v. GE Packaged Power Inc.

373 ITR 65 · 2015 · High Court

199

citing judgments

Interest under section 234B for default in payment of advance tax is not leviable when the entire income is subject to tax deduction at source under section 195, as no advance tax liability arises for the assessee in such circumstances.

Sreenivas Charitable Trust v. Dy. CIT

280 ITR 357 · 2006 · High Court

182

citing judgments

The expression "sufficient cause" for condoning delay in filing appeals must receive a liberal and purposive construction. This approach aims to advance substantial justice, which is of paramount importance.

Pradip Kumar Malhotra v. CIT

338 ITR 538 · 2011 · High Court

152

citing judgments

Section 2(22)(e) of the Income Tax Act, which addresses deemed dividends, does not apply to loans or advances provided by a company to its shareholders if these transactions occur in the normal course of business, are driven by business expediency, or are made in consideration of a benefit conferred upon the company by the shareholder. Conversely, gratuitous loans or advances given to shareholders fall within the purview of this section.

DIT v. NGC Network Asia LLC

313 ITR 187 · 2009 · High Court

144

citing judgments

Where a duty is cast on the payer to deduct and pay tax at source under Section 195, the payee-assessee cannot be levied interest under Section 234B for failure to pay advance tax if the payer defaults on its TDS obligation. This principle may also extend to interest under Section 234C.

Topman Exports v. CIT

342 ITR 49 · 2012 · Supreme Court

121

citing judgments

Export incentives, such as DEPB (Duty Entitlement Pass Book) and advance license benefits, constitute income taxable on an accrual basis under Section 28 of the Income-tax Act. Profit arising on the transfer of DEPB is not eligible for deduction under Section 80HHC.

CIT v. Creative Dyeing & Printing Pvt. Ltd.

318 ITR 476 · 2009 · High Court

119

citing judgments

Genuine trade advances or amounts advanced for bona fide business transactions, driven by commercial expediency, do not fall within the definition of deemed dividend under section 2(22)(e) of the Income-tax Act.

CIT v. Raj Kumar

318 ITR 462 · 2009 · High Court

119

citing judgments

Genuine trade advances made by a company in the ordinary course of business to a shareholder do not fall within the definition of deemed dividend under Section 2(22)(e) of the Income-tax Act.

Judgments citing advance tax

Income Tax Officer, Chennai vs. Rohitkumar Nemchand Piparia, Chennai

The appeal stand allowed in terms of our above order

ITA 1344/CHNY/2023[2008-09]Status: DisposedITAT Chennai31 Dec 2024AY 2008-09

Bench: Hon’Ble Shri Aby T. Varkey, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं./ Ita No.1344/Chny/2023 (िनधा*रण वष* / Assessment Year: 2008-09) Ito Shri Rohitkumar Nemchand Piparia बनाम International Taxation Ward-2(1) #34 (Old #77), Meddox Street, / Vs. Chennai. Choolai, Chennai-600 112. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Akzpp-0661-M (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ"कीओरसे/ Assessee By : Shri T. Banusekar & Ms. Samyuktha Banusekar (Advocates) - Ld. Ars " थ"कीओरसे/Revenue By : Shri Nilay Baran Som (Cit) - Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 07-10-2024 घोषणाकीतारीख /Date Of Pronouncement : 31-12-2024 आदेश / O R D E R

For Appellant: Shri T. Banusekar & Ms. SamyukthaFor Respondent: Shri Nilay Baran Som (CIT) - Ld. DR

Section 143(3)Section 148Section 234BSection 234C

confirmed the charging of interest u/s 234C of the Act amounting to Rs.3,31,564/- which is actually for deferment of Advance tax. The above decision is contrary to the provisions of the Act, since, the charging of interest u/s 234C emanate only from the existence of advance tax liability ... also from the shortfall of advance tax payable by the assessee. To explain further, the interest u/s 234C is chargeable for the default in payment of installment(s) / shortfall of advance tax payable by the assessee with relevant interest u/s 234B in case of default. The Ld.CIT

M/S. Bhiwandi Nzampur Nagarpalika Collage, Mumbai vs. ITO Ward 1(1), Kalyan

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

ITA 4242/MUM/2024[2018-19]Status: DisposedITAT Mumbai31 Dec 2024AY 2018-19

Bench: Shri. Om Prakash Kant, Am & Ms. Kavitha Rajagopal, Jm M/S. Bhiwandi Nizampur Assessing Officer, Ward 1(1), Nagarpalika College Mohan Plaza, Katak Pada, Kalyan, 1, Dhamankar Naka, Bhiwandi, Vs. Dist. Thane – 421301. Vidyashram, S. O. Thane – 421305. Pan/Gir No. Aaaab1757C (Assessee) : (Respondent) Assessee By : Shri. H. N. Motiwalla Respondent By : Mr. Tushar Mohite, Sr. Dr Date Of Hearing : 17.10.2024 Date Of Pronouncement : 31.12.2024 O R D E R Per Kavitha Rajagopal, J M: This Appeal Has Been Filed By The Assessee, Challenging The Order Of The Learned Commissioner Of Income Tax (Appeals), Delhi (‘Ld. Cit(A)’ For Short), National Faceless Appeal Centre (‘Nfac’ For Short) Passed U/S.250 Of The Income Tax Act, 1961 (‘The Act'), Pertaining To The Assessment Year (‘A.Y.’ For Short) 2018-19. 2. The Assessee Has Raised The Following Grounds Of Appeal: “1. On The Facts & In The Circumstances Of The Case, The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi, Erred In Dismissing The Appeal Only On The Ground That The Appellant Has Not Made Payment Equal To Advance Tax Which Was Due On Its Income Without Appreciating The Fact That The Appellant Is A College Affiliated To University Of Mumbai Under The Management Of Padmashri Annasahib Jadhav Bhartiya Samaj Unnati Mandal (Trust) Bhiwandi Assessed Under Pan Aaatp2888P. 2. On The Facts & In The Circumstances Of The Case The Said Learned Commissioner Of Income Tax Has Also Erred In Not Considering The Ground That The Assessing Officer, Assessment Unit, Income Tax Department Has Erred In Estimating @ 8% On College Fee Receipt Of Rs. 1,63,75,639/- I.E. Rs. 13,10,051/- As Business Receipt Without Appreciating

For Appellant: Shri. H. N. MotiwallaFor Respondent: Mr. Tushar Mohite, Sr. DR

Section 147Section 148Section 249(4)(b)Section 250

National Faceless Appeal Centre (NFAC), Delhi, erred in dismissing the appeal only on the ground that the appellant has not made payment equal to advance tax which was due on its income without appreciating the fact that the appellant is a college affiliated to university of Mumbai under the management ... appeal filed by the assessee on the ground that the assessee has not filed its return of income nor has it filed its advance tax. Further, it was held that the assessee has not requested for exemption from operation of Section 249(4)(b) of the Act, thereby failed

Trent Limited, Mumbai vs. Deputy Commissioner of Income Tax Circle 2(3)(1), Mumbai

ITA 4074/MUM/2024[2017-18]Status: DisposedITAT Mumbai31 Dec 2024AY 2017-18

Bench: Shri Pavan Kumar Gadale & Shri Girish Agrawal

For Respondent: Shri Rajan Vora and Nikhil Tiwari, CA

Section 10(34)Section 115JSection 143(3)Section 14ASection 234Section 234CSection 250

IN THE INCOME TAX APPELLATE TRIBUNAL “E” BENCH MUMBAI BEFORE SHRI PAVAN KUMAR GADALE, JUDICIAL MEMBER AND SHRI GIRISH AGRAWAL

DCIT-14(1)(1), Mumbai vs. Indian Oil Corporation Ltd, Mumbai

In the result, the appeal of the assessee is partly allowed and that of the revenue is dismissed

ITA 2752/MUM/2024[2009-10]Status: DisposedITAT Mumbai31 Dec 2024AY 2009-10

Bench: Shri Anikesh Banerjee & Smt. Renu Jauhriindian Oil Corporation V/S. Dcit-14(2)(1), Mumbai Ltd. बनाम Aaykar Bhavan, G-9, Ali Yavar Jung Marg, M.K.Road, Bandra (East), Mumbai-400020 Mumbai-400051 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aaaci1681G Appellant/अपीलार्थी .. Respondent/प्रतिवादी Dcit-14(2)(1), Mumbai V/S. Indian Oil Corporation Ltd. Aaykar Bhavan, बनाम G-9, Ali Yavar Jung Marg, M.K.Road, Bandra (East), Mumbai-400020 Mumbai-400051 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aaaci1681G Appellant/अपीलार्थी .. Respondent/प्रतिवादी

For Appellant: Shri. Niraj D. ShethFor Respondent: Shri Krishna Kumar

Section 115JSection 143(3)Section 244Section 244(1)(au)Section 244ASection 244A(1)(b)Section 250

refund of Rs. 18,61,65,829/- was issued to the assessee on 30.07.2013. As the AO had not allowed certain credits of advance tax, TDS and also interest on excess payment of self-assessment tax, the assessee filed an appeal before the Ld. CIT(A) who issued necessary directions ... following manner, namely :- (a) (a) where the refund is out of any tax collected at source under section 206C or paid by way of advance tax or treated as paid under section 199, during the financial year immediately preceding the assessment year, such interest shall be calculated at the rate

Indian Oil Corporation Ltd, Mumbai vs. DCIT 14(2)(1), Mumbai

In the result, the appeal of the assessee is partly allowed and that of the revenue is dismissed

ITA 2317/MUM/2024[2009-10]Status: DisposedITAT Mumbai31 Dec 2024AY 2009-10

For Appellant: Shri. Niraj D. ShethFor Respondent: Shri Krishna Kumar

Section 115JSection 143(3)Section 244Section 244(1)(au)Section 244ASection 244A(1)(b)Section 250

Laxman Yadav, Khargone Madhya Pradesh vs. ITO, Chanakyapuri Dhar

Appeal is allowed for statistical purpose

ITA 515/IND/2024[1999-2000]Status: DisposedITAT Indore27 Dec 2024AY 1999-2000

Bench: Shri Tr Senthil Kumar & Shri B.M. Biyani

Section 144Section 147Section 250

filed by the appellant for the assessment year in connection with which ‘the appeal is preferred, whether an amount equal to the amount of advance tax payable by him during the financial year immediately preceding such assessment year has been paid. (If the answer is in the affirmative, give details

Krishi Utpadan Mandi Samiti, Rura, Kanpur Dehat vs. CPC, Bangalore ITO (Exemption), Kanpur

In the result, the appeal of the assessee is partly allowed for statistical purposes

ITA 102/LKW/2024[2016-17]Status: DisposedITAT Lucknow26 Dec 2024AY 2016-17

Bench: Shri Anadee Nath Misshra

Section 11Section 143(1)Section 249(3)Section 5

Where no return has been filed by the assessee, the assessee has paid an amount equal to the amount of advance tax which was payable by him: Provided that, in a case failing under clauses (b) and] on an application made by the appellant in this behalf, the Commissioner (Appeals

Gurcharan Singh, Kurukshetra vs. ITO, Ward-1, Kurukshetra

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

ITA 139/CHANDI/2024[2012-13]Status: DisposedITAT Chandigarh26 Dec 2024AY 2012-13

Bench: The Ld. Cit(A) Who Has Since Dismissed The Appeal Of The Assessee Holding That Since The Assessee Has Neither Filed The Return Of Income Nor Paid Advance Tax Before Filing The Appeal, The Appeal Cannot Be Admitted As Per The Provisions Of Section 249(4)(B) Of The Act.

For Appellant: Shri Parikshit Aggarwal, C.AFor Respondent: Shri Vivek Vardhan, JCIT, Sr. DR

Section 144Section 249(4)(b)Section 250

since dismissed the appeal of the assessee holding that since the assessee has neither filed the return of income nor paid advance tax before filing the appeal, the appeal cannot be admitted as per the provisions of Section 249(4)(b) of the Act. 5. Being aggrieved, the assessee ... written submission to the appellant to file response to the same. 8. It was further submitted that the appellant was not liable to pay advance tax as his total income was less than the maximum amount not chargeable to tax and the Worthy CIT(A) without application of mind

Biocon Biologics Limited, Bangalore vs. The Assistant Commissioner of Income Tax, Circle 2(1)(1), Bangalore

ITA 1590/BANG/2024[2020-21]Status: DisposedITAT Bangalore23 Dec 2024AY 2020-21

Bench: Shri Prashant Maharishi & Shri Prakash Chand Yadavit(Tp)A No.1590/Bang/2024

For Appellant: Shri Padamchand Khincha, CAFor Respondent: Shri D.K. Mishra, CIT(DR)(ITAT), Bengaluru

Section 115JSection 143(3)Section 92Section 92C

Further, no adjustment can be made for computation of the book profits unless specifically provided u/s 115JB of the Act Non-grant of advance tax, TDS, TCS credits and FTC The Ld. AO has erred in law and on facts: 8.1 in not considering that Biocon Research Limited ... merged with the Appellant during the year under dispute and disregarding the credit claimed (i.e., advance tax, TDS/TCS) by the Appellant, as per the order of the National Company Law Tribunal under the approved merger scheme. 8.2 in unjustifiably reducing the advance tax credit

Yunusbhai Ibrahimbhai Patel, Vadodara vs. The Income Tax Officer, Ward-1(2)(2), Vadodara

In the result, the appeal filed by the Assessee is allowed for statistical purpose

ITA 954/AHD/2024[2011-12]Status: DisposedITAT Ahmedabad20 Dec 2024AY 2011-12

Bench: Ld. Cit(A) Be Taken On Record & Decide On Merits Of The Case.

Section 144Section 249Section 249(4)(b)Section 69

case of assessee that by virtue of provisions contained in section 249, Appellate Authority should exempt assessee from requirement of paying advance tax in cases where a return of income had not been filed by assessee - Whether since it was not in dispute that case of assessee fell under proviso

Shri Vilasrao Deshmukh Shikshan Prasarak Va Bahudeshiya S Buldana, Buldhana vs. Income Tax Officer, Ward-2(Exemption), Nagpur

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

ITA 333/NAG/2024[2015-16]Status: DisposedITAT Nagpur20 Dec 2024AY 2015-16

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Kishore P. DewaniFor Respondent: Shri Abhay Y. Marathe

Section 10Section 11Section 12ASection 143(2)Section 144Section 148Section 234ASection 249(4)Section 250

erred in holding that appellant has not filed return of income and as well as not paid an amount equal to advance tax which was payable and present appeal is not liable to be admitted. 4. The CIT(A) erred in holding that assessee has not paid the taxes ... advance tax and therefore appeal is liable to be dismissed in terms of provisions of section 249(4) of I.T. Act 1961. CIT(A) ought to have admitted the appeal as return was submitted declaring income at NIL. 5. The assessee has submitted return of income on 14/11/2018 declaring income

Goli Pichaiah, Guntur vs. Income Tax Officer, Ward-2(3), Guntur

In the result, appeal of the assessee is partly allowed in the aforesaid terms

ITA 443/VIZ/2024[2017-18]Status: DisposedITAT Visakhapatnam20 Dec 2024AY 2017-18

Bench: Justice (Retd.) C.V. Bhadang, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.No.443/Viz/2024 (निर्धारण वर्ा/ Assessment Year: 2017-18) Goli Pichaiah V. Ito – Ward – 2(3) D.No. 11-9-45/30 Income Tax Office Plot No. 17, Bhagat Singh Nagar C.R. Buildings, Kannavarithota Guntur – 522004 Mangalagiri, Guntur – 522008 Andhra Pradesh Andhra Pradesh [Pan: Bbdpg9796C] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

Section 249Section 249(4)(b)Section 4Section 69A

admitted unless there is a compliance of section 249(4)(b) of the Act as the Appellant having failed to deposit the advance tax which was payable on the assessed income. 3. We have heard the Ld. AR for the Appellant and Ld.DR for the respondent, with their assistance ... where no return has been filed by the assessee, the assessee has paid an amount equal to the amount of advance tax which was payable by him:] Provided that, in a case falling under clause (b) and on an application made by the appellant in this behalf, the Joint Commissioner

Jayanti Polymers Pvt. Ltd., Ahmedabad vs. The Income Tax Officer, Ward-2(1)(2), Ahmedabad

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

ITA 334/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad19 Dec 2024AY 2017-18

Bench: Dr.Brr Kumarshri Tr Senthil Kumar

For Appellant: Shri Tushar Hemani, Sr. Advocate with Shri Parimalsinh B Parmar, ARFor Respondent: Shri Rignesh Das, Sr. DR

Section 144Section 234ASection 249Section 249(4)(b)Section 271ASection 271FSection 272A(1)(d)Section 69A

where no return has been filed by the assessee, the assessee has paid an amount equal to the amount of advance tax which was payable by him: Provided that, in a case falling under clause (b) and on an application made by the appellant in this behalf, the Commissioner (Appeals

Shubhamangal Sadi Depo, Hingoli vs. Income Tax Officer, National Faceless Assessment Unit

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

ITA 1652/PUN/2024[2017-2018]Status: DisposedITAT Pune18 Dec 2024AY 2017-2018

Bench: Dr.Manish Borad

For Appellant: NoneFor Respondent: Shri Sourabh Nayak

Section 147Section 250Section 44ASection 68Section 69

Depo ground that the assessee has not furnished the return of income as well as not paid the amount equal to the amount of advance tax which was payable by it and has only referred to sections 249(4), 243B(1) and 208 of the Act. However, this observation

Shri Trimbakeshwar De vs. Than Trust, Nashikvs.CIT (Exemption) Pune, Pune

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

ITA 1051/PUN/2024[2018-2019]Status: DisposedITAT Pune18 Dec 2024AY 2018-2019

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1051/Pun/2024

For Appellant: Shri Pramod S. ShingteFor Respondent: Shri Ajay Kumar Keshari

Section 11Section 142(1)Section 143(2)Section 143(3)Section 263

failed to verify the payment of income tax of Rs.1,55,38,112/- (for A.Y.2011-12 Regular assessment tax Rs.39,28,922/- for A.Y.2017-18, Advance Tax Rs.77,31,000/- plus for A.Y. 2014-15 for tax on regular assessment of Rs. 38,78,190/-) during assessment u/s.143(3) for A.Y.2018-19

Spectra Equipment Private Limited, Hyderabad vs. Income Tax Officer, Ward 3(1), Hyderabad

In the result, the appeal of the assessee is dismissed

ITA 500/HYD/2023[Assessment Year 2017-18]Status: DisposedITAT Hyderabad18 Dec 2024

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdiaassessment Year: 2017-18 Spectra Equipment Private Vs. The Income Tax Officer, Ward 3(1), Limited, Hyderabad. Hyderabad. Pan No.Aaccs8677C. (Appellant) (Respondent) Assessee By: Ms. Akanksha, C.A. For Shri Sunil Kumar Jain, C.A. Revenue By: Ms. Narmada, Cit-Dr For Shri Madan Mohan Meena, Sr.D.R. Date Of Hearing: 11.12.2024 Date Of Pronouncement: 18.12.2024

For Appellant: Ms. Akanksha, C.AFor Respondent: Ms. Narmada, CIT-DR for Shri Madan Mohan Meena

Section 115BSection 131Section 133(6)Section 143(1)Section 143(3)Section 68

declaration, consequential relief is sought against Ext.P2 assessment order levying tax at the enhanced rate of 60% and surcharge @25% on the 'advance tax'. The learned Single Judge rejected the writ petition by a cryptic judgment relying on Commissioner of Income Tax v. S.A.Wahab ... Financial Year 2016-2017; which is the year in which the subject seizures were occasioned. The proviso refers to various provisions where the advanced tax computed under the first proviso stands increased by a surcharge for the purpose of the Union. Section 115BBE is one of the provisions referred

Parsvnath Developers Ltd, New Delhi vs. JCIT, Range-76, New Delhi

The appeal of the assessee is allowed

ITA 1821/DEL/2022[2012-13]Status: DisposedITAT Delhi18 Dec 2024AY 2012-13

Bench: Shri S. Rifaur Rahman & Shri Anubhav Sharmaassessment Year: 2012-13 Parsvnath Developers Ltd., Vs Jcit, Parsvnath Tower, Range-76, Near Shahdara Metro Station, New Delhi.. New Delhi – 110 032. Pan: Aaacp0743J (Appellant) (Respondent) Assessee By : Shri Paritosh Jain, Advocate Revenue By : Ms Harpreet Kaur Hansra, Sr.Dr Date Of Hearing : 02.12.2024 Date Of Pronouncement : 18.12.2024

For Appellant: Shri Paritosh Jain, AdvocateFor Respondent: Ms Harpreet Kaur Hansra, Sr.DR

Section 194CSection 194ISection 197Section 271C

considered sufficient justification in case of short deductions. Ld. Tax authorities should have a realistic attitude to understand the ground realties. Provisions for advance tax deposits, TDS or TCS are mode of Parsvnath Developers ltd. vs. JCIT collecting taxes and the provisions in the Act concerning them should be liberally

Efy Thechnologies, Jaipur vs. Income Tax Officer WD 5(4), Jpr, Jaipur

Appeal is disposed of for statistical purposes

ITA 1226/JPR/2024[2017-18]Status: DisposedITAT Jaipur16 Dec 2024AY 2017-18

Bench: Ld. Cit(A), The Assessment Order Dated

For Appellant: Sh. Ashok Kumar Gupta, Adv. &For Respondent: Mrs. Anita Rinesh, JCIT-Sr. DR

Section 115Section 142(1)Section 144Section 249(4)(b)Section 250Section 271Section 271FSection 272A(1)(d)Section 69A

business activities were done by the assessee in the year under consideration, and as such there was no question of deposit of any advance tax of filing of any return, said question could be determined only after going through the evidence sought to be produced by the assessee

Barmer Lignite Mining Co. Ltd., C-Scheme, Jaipur vs. DCIT, Circle-6, Jaipur

Appeals of the assessee are allowed for statistical purposes in view of our detailed order (supra)

ITA 463/JPR/2023[2020-21]Status: DisposedITAT Jaipur16 Dec 2024AY 2020-21

Bench: Dr. S. Seethalakshmi & Shri Gagan Goyal

For Appellant: Mr. P. C. Parwal, CA, Ld. ARFor Respondent: MS. Alka Gautam, CIT, Ld. DR

Section 234ASection 250Section 94E

following manner, namely :— (a) where the refund is out of any tax collected at source under section 206C or paid by way of advance tax or treated as paid under section 199, during the financial year immediately preceding the assessment year, such interest shall be calculated at the rate

Barmer Lignite Mining Co. Ltd., C-Scheme, Jaipur vs. DCIT, Circle-6, Jaipur

Appeals of the assessee are allowed for statistical purposes in view of our detailed order (supra)

ITA 462/JPR/2023[2018-19]Status: DisposedITAT Jaipur16 Dec 2024AY 2018-19

Bench: Dr. S. Seethalakshmi & Shri Gagan Goyal

For Appellant: Mr. P. C. Parwal, CA, Ld. ARFor Respondent: MS. Alka Gautam, CIT, Ld. DR

Section 234ASection 250Section 94E