← All Phrases

“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

DCIT Central Circle-31, New Delhi vs. Rswm Ltd, Kharigram

In the result, the Appeals filed by the assessee in ITA No

ITA 1928/DEL/2020[2014-15]Status: DisposedITAT Delhi31 Jan 2024AY 2014-15

Bench: Dr. B.R.R. Kumar & Shri Yogesh Kumar U.S.Ita Nos.145 & 146 /Del/2021 (Assessment Years 2014-15 & 2015-16)

Section 115JSection 14ASection 14A(2)Section 37(1)Section 40Section 69

universalise quality basic education, is proposed to be levied at the rate of two per cent on the amount of tax deducted or advance tax paid, inclusive of surcharge.” M/s RSWM Ltd. vs. DCIT 22. The provisions of the Finance Act 2011 relevant to the Assessment Year under consideration

Dimexon Diamonds Ltd, Mumbai vs. ACIT Cent. Cir 1(4), Mumbai

ITA 2429/MUM/2022[2018-19]Status: DisposedITAT Mumbai30 Jan 2024AY 2018-19

Bench: Shri Amarjit Singh & Shri Sandeep Singh Karhail

For Appellant: Shri Rajesh SimhanFor Respondent: Shri H. M. Bhatt
Section 143(3)Section 144C(13)Section 144C(5)Section 92C(3)

made, the same should be based on international rates (such as LIBOR) and not SBI PLR. Short grant of credit of Advance tax and Taxes deducted at Source ("TDS") 17. Erred in not granting advance tax credit of INR 20,93,675. 18. Erred in not granting TDS credit

Lupin Ltd., Mumbai vs. The Dy CIT, Circle-3(4), Mumbai

In the result, all the appeals of the assessee and revenue are treated as partly allowed

ITA 1921/MUM/2020[2010-11]Status: DisposedITAT Mumbai25 Jan 2024AY 2010-11

Bench: Shri B.R. Baskaran (Am) & Shri Pavan Kumar Gadale (Jm)

Asst. year 2010-11, 2011-12 and 2012-13 33. The next issue relates to the interest levied u/s 234C of the Act. The advance tax remitted by the assessee got delayed by one day beyond the due date and hence interest u/s 234C of the Act to the tune ... Rs.57,20,000/- was levied. It is the case of the assessee that the delay in payment of advance tax was beyond the control of the assessee and hence the interest u/s 234C should not be levied. We notice that the Ld CIT(A) has rejected the above said claim

Strides Shasun Ltd, Navi Mumbai vs. DCIT Cir 15(3)(2), Mumbai

In the result, appeal of assessee is partly allowed

ITA 932/MUM/2017[2012-13]Status: DisposedITAT Mumbai15 Jan 2024AY 2012-13

Bench: Shri Vikas Awasthy& Shri Amarjit Singhआअसं.932 /मुं/2017 (िन.व. 2012-13) Strides Pharma Science Limited [Formerly Known As Strides Arcolab Limited/ Strides Shasun Limited] 201, Devavrata, Sector -17, Vashi, Navi Mumbai – 400 703 Pan: Aadcs-8104-P ...... अपीलाथ"/Appellant बनाम Vs. The Deputy Commissioner Of Income Tax Circle – 15(3)(2), Mumbai Room No.451, 4Th Floor, Aaykar Bhavan, M.K.Road, Mumbai – 400 020 ..... "ितवादी/Respondent अपीलाथ" "ारा/ Appellant By : Shri Nitesh Joshi, Advocate With Shri Ninand Patade "ितवादी "ारा/Respondent By : Shri Anoop Hiwase सुनवाई क" ितिथ/ Date Of Hearing : 26/10/2023 घोषणा क" ितिथ/ Date Of Pronouncement : 15 /01/2024 आदेश/Order Per Vikas Awasthy, Jm: This Appeal By The Assessee Is Directed Against The Final Assessment Order Dated 23/01/2017 Passed U/S. 143(3) R.W.S. 144C(13) Of The Income Tax Act, 1961 [In Short ‘The Act’], For The Assessment Year 2012-13. 2. The Assessee In Appeal Has Raised As Many As 12 Grounds. Shri Nitesh Joshi, Advocate Appearing On Behalf Of The Assessee Submitted At The Outset

For Appellant: Shri Nitesh Joshi, Advocate with Shri Ninand PatadeFor Respondent: Shri Anoop Hiwase
Section 143(3)

ld.Counsel for the assessee submitted that the Assessing Officer has charged interest u/s. 234C of the Act. There is no shortfall in payment of advance tax liability, hence, no interest u/s. 234C of the Act was leviable. 21. We have heard the submissions made by ld.Counsel for the assessee. Charging

Strides Shasun Ltd, Navi Mumbai vs. DCIT Cir 15(3)(2), Mumbai

In the result, appeal of the assessee is partly allowed

ITA 7400/MUM/2017[2013-14]Status: DisposedITAT Mumbai15 Jan 2024AY 2013-14

Bench: Shri Vikas Awasthy& Shri Amarjit Singhआअसं.7400 /मुं/2017 (िन.व. 2013-14) Strides Pharma Science Limited [Formerly Known As Strides Arcolab Limited/ Strides Shasun Limited] 201, Devavrata, Sector -17, Vashi, Navi Mumbai – 400 703 Pan: Aadcs-8104-P ...... अपीलाथ"/Appellant बनाम Vs. The Deputy Commissioner Of Income Tax Circle – 15(3)(2), Mumbai Room No.451, 4Th Floor, Aaykar Bhavan, M.K.Road, Mumbai – 400 020 ..... "ितवादी/Respondent अपीलाथ" "ारा/ Appellant By : Shri Nitesh Joshi, Advocate With Shri Ninand Patade "ितवादी "ारा/Respondent By : Shri Anoop Hiwase & Dr. Samuel Pitta सुनवाई क" ितिथ/ Date Of Hearing : 30/10/2023 घोषणा क" ितिथ/ Date Of Pronouncement : 15/01/2024 /01/2024 आदेश/Order Per Vikas Awasthy, Jm: This Appeal By The Assessee Is Directed Against The Final Assessment Order Dated 30/10/2017 Passed U/S. 143(3) R.W.S. 144C(13) Of The Income Tax Act, 1961 [In Short ‘The Act’], For The Assessment Year 2013-14. 2 2. The Assessee In Appeal Has Raised Ten Grounds Of Appeal. The Assessee Has Also Raised Additional Grounds Of Appeal Vide Application Dated 26/10/2023. 3. The Ground No.1 Of Appeal Is General In Nature, Hence, Require No Separate Adjudication.

For Appellant: Shri Nitesh Joshi, Advocate with Shri Ninand PatadeFor Respondent: Shri Anoop Hiwase &
Section 143(3)Section 36(1)(va)

interest u/s. 234B and 234C of the Act, respectively. The ld. Counsel for the assessee submitted that there is no shortfall in deposits of advance tax, therefore, no interest u/s. 234C of the Act could be charged. Charging of 10 interest u/s. 234B and 234C of the Act are consequential

M/S. Arvindbhai Kalyanbhai Textile, Ahmedabad vs. The Income Tax Officer, Ward-5(3)(4), Ahmedabad

In the result, the appeal of the assessee is allowed

ITA 706/AHD/2023[2017-18]Status: DisposedITAT Ahmedabad12 Jan 2024AY 2017-18

Bench: Ms. Suchitra Kamble (Judicial Member)

For Appellant: Ms. Urvashi Sodhan, A.RFor Respondent: Ms. Saumya Pandey Jain, Sr. D.R
Section 115BSection 142(1)Section 143(1)Section 143(2)Section 234ASection 271(1)(c)Section 68

assessee filed part submissions on various occasions filed the details called for. The Assessing Officer observed that the assessee made large payment of advance tax in cash during demonetization period and has claimed refund of substantive amount later. The assessee has given its reply and after taking into account

Shree Lakshmi Mahila Souharda Credit Co Operative Limited, Ramanagara vs. Income Tax Officer, Ward-1, Ramanagara

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

ITA 1021/BANG/2023[2017-18]Status: DisposedITAT Bangalore12 Jan 2024AY 2017-18

Bench: Shri George George Kshri Laxmi Prasad Sahuassessment Year : 2017-18

For Appellant: Shri Sandeep Chalapathy, C.AFor Respondent: Shri Ganesh R Ghale
Section 115BSection 249(4)(b)Section 68Section 80P

assesee has stated ‘No’ in the respective columns and it establishes that, the assessee has not paid an amount equivalent to the amount of advance tax, which was payable on or before filing the return. Accordingly, the appeal of the assessee shall not be admitted

Zheng Yuan Mobiles Private Limited, Patna vs. DCIT Central Circle -30, Delhi

The appeal of the assessee is allowed

ITA 864/DEL/2023[2017-2018]Status: DisposedITAT Delhi11 Jan 2024AY 2017-2018

Bench: Shri Shamim Yahya & Shri Anubhav Sharmaassessment Year: 2017-18

Section 143(3)

Balance Sheet. 2. High Revenue from operations (including other income) and no scrutiny in preceding 5 assessment years. 3. Large refund claimed out of advance tax. 4. Large value claim of refund. 3. During assessment proceedings, learned AO was not satisfied with the genuineness of the expenditure on account

M/S. Deepak Industries Ltd., Kolkata vs. DCIT, Circle - 6(1), Kolkata

In the result, both the appeals of the assessee are partly allowed

ITA 467/KOL/2022[2019-2020]Status: DisposedITAT Kolkata10 Jan 2024AY 2019-2020

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma]

Section 139(1)Section 143(1)Section 2(24)(x)Section 234CSection 36(1)(va)Section 43(1)Section 43A

brought to our notice to the provisions of section 234C of the Act which is read as under: “Interest for deferment of advance tax 234C (1) Where in any financial year,— (a) the company which is liable to pay advance tax under section 208 has failed to pay such tax ... advance tax paid by the company on its current income on or before the 15th day of June is less than fifteen per cent of the tax due on the returned income or the amount of such advance tax paid on or before the 15th day of September is less

Crisil Ltd, Mumbai vs. Asst CIT RG 9(2)(2), Mumbai

ITA 1345/MUM/2017[2012-13]Status: DisposedITAT Mumbai10 Jan 2024AY 2012-13

Bench: Shri Aby T Varkey, Hon'Ble & Shri S. Rifaur Rahman, Hon'Bleιτα.Νο. 7603/Mum/2012 (A.Y: 2008-09) M/S. Crisil Limited 8Th Floor, Central Avenue Road Hiranandani Business Park Opp. D-Mart, Powai Mumbai- 400076 Pan: Aaaст3151E (Appellant) V. Addl. Cit - 8(1) Aayakar Bhavan, M.K. Road Mumbai- 400020 (Respondent) Ιτα.Νο. 1564/Mum2014 (A.Y: 2009-10) M/S. Crisil Limited Central Avenue Road Hiranandani Business Park Opp. D-Mart, Powai Mumbai- 400076 Pan: Aaaст3151E (Appellant) V. Dy. Cit (Osd) – 8(1) Aayakar Bhavan, M.K. Road Mumbai- 400020 (Respondent)

Section 133(6)Section 144C(5)

claimed in the revised return of income filed under section 139(5) of the Act. 9. Not considering advance tax payments of Rs. 25,000 and Rs. 3,75,00,000 paid on 14th June 2007 and 14th March 2008 respectively and dividend distribution tax ... while calculating the total tax liability. 10. Considering the date of credit of the advance tax to the government treasury as the date of payment instead of the date of tendering of the cheque of advance tax while calculating the interest u/s 234C of the Act." 5. Further, assessee

Crisil Ltd, Mumbai vs. DCIT 9(2)(2), Mumbai

ITA 997/MUM/2016[2011-12]Status: DisposedITAT Mumbai10 Jan 2024AY 2011-12

Bench: Shri Aby T Varkey, Hon'Ble & Shri S. Rifaur Rahman, Hon'Bleιτα.Νο. 7603/Mum/2012 (A.Y: 2008-09) M/S. Crisil Limited V. Addl. Cit - 8(1) 8Th Floor, Central Avenue Road Aayakar Bhavan, M.K. Road Hiranandani Business Park Mumbai- 400020 Opp. D-Mart, Powai Mumbai- 400076 (Respondent) Pan: Aaaст3151E (Appellant) Ιτα.Νο. 1564/Mum2014 (A.Y: 2009-10) M/S. Crisil Limited V. Dy. Cit (Osd) – 8(1) Central Avenue Road Aayakar Bhavan, M.K. Road Hiranandani Business Park Mumbai- 400020 Opp. D-Mart, Powai Mumbai- 400076 (Respondent) Pan: Aaaст3151E (Appellant)

Section 133(6)Section 144C(5)

claimed in the revised return of income filed under section 139(5) of the Act. 9. Not considering advance tax payments of Rs. 25,000 and Rs. 3,75,00,000 paid on 14th June 2007 and 14th March 2008 respectively and dividend distribution tax ... while calculating the total tax liability. 10. Considering the date of credit of the advance tax to the government treasury as the date of payment instead of the date of tendering of the cheque of advance tax while calculating the interest u/s 234C of the Act." 5. Further, assessee

Asst CIT RG 9(2)(1), Mumbai vs. Crisil Ltd, Mumbai

In the result the issue under

ITA 843/MUM/2015[2010-11]Status: DisposedITAT Mumbai10 Jan 2024AY 2010-11

Bench: Shri Aby T Varkey, Hon'Ble

Section 133(6)Section 144C(5)

claimed in the revised return of income filed under section 139(5) of the Act. 9. Not considering advance tax payments of Rs. 25,000 and Rs. 3,75,00,000 paid on 14 June 2007 and 14° March 2008 respectively and dividend distribution tax ... while calculating the total tax liability. 10. Considering the date of credit of the advance tax to the government treasury as the date of payment instead of the date of tendering of the cheque of advance tax while calculating the interest u/s 234C of the Act.” 5. Further, assessee

Crisil Ltd, Mumbai vs. Asst CIT RG 9(2)(2), Mumbai

In the result the issue under consideration is remitted back to the file of Assessing Officer for statistical purpose

ITA 1114/MUM/2015[2010-11]Status: DisposedITAT Mumbai10 Jan 2024AY 2010-11

Bench: Shri Aby T Varkey, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

Section 133(6)Section 144C(5)

claimed in the revised return of income filed under section 139(5) of the Act. 9. Not considering advance tax payments of Rs. 25,000 and Rs. 3,75,00,000 paid on 14th June 2007 and 14th March 2008 respectively and dividend distribution tax ... while calculating the total tax liability. 10. Considering the date of credit of the advance tax to the government treasury as the date of payment instead of the date of tendering of the cheque of advance tax while calculating the interest u/s 234C of the Act.” 5. Further, assessee

Crisil Ltd, Mumbai vs. DCIT (OSD) 8(1), Mumbai

In the result the issue under consideration is remitted back to the file of Assessing Officer for statistical purpose

ITA 1564/MUM/2014[2009-10]Status: DisposedITAT Mumbai10 Jan 2024AY 2009-10

Bench: Shri Aby T Varkey, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

Section 133(6)Section 144C(5)

claimed in the revised return of income filed under section 139(5) of the Act. 9. Not considering advance tax payments of Rs. 25,000 and Rs. 3,75,00,000 paid on 14th June 2007 and 14th March 2008 respectively and dividend distribution tax ... while calculating the total tax liability. 10. Considering the date of credit of the advance tax to the government treasury as the date of payment instead of the date of tendering of the cheque of advance tax while calculating the interest u/s 234C of the Act.” 5. Further, assessee

DCIT RG (OSD) 8(1), Mumbai vs. Crisil Ltd, Mumbai

ITA 1180/MUM/2014[2009-10]Status: DisposedITAT Mumbai10 Jan 2024AY 2009-10

Bench: Shri Aby T Varkey, Hon'Ble & Shri S. Rifaur Rahman, Hon'Bleιτα.Νο. 7603/Mum/2012 (A.Y: 2008-09) M/S. Crisil Limited 8Th Floor, Central Avenue Road Hiranandani Business Park Opp. D-Mart, Powai Mumbai- 400076 Pan: Aaaст3151E (Appellant) V. Addl. Cit - 8(1) Aayakar Bhavan, M.K. Road Mumbai- 400020 (Respondent) Ιτα.Νο. 1564/Mum2014 (A.Y: 2009-10) M/S. Crisil Limited Central Avenue Road Hiranandani Business Park Opp. D-Mart, Powai Mumbai- 400076 V. Dy. Cit (Osd) – 8(1) Aayakar Bhavan, M.K. Road Mumbai- 400020 (Respondent) Pan: Aaaст3151E (Appellant)

Section 133(6)Section 144C(5)Section 92C(2)

claimed in the revised return of income filed under section 139(5) of the Act. 9. Not considering advance tax payments of Rs. 25,000 and Rs. 3,75,00,000 paid on 14th June 2007 and 14th March 2008 respectively and dividend distribution tax ... while calculating the total tax liability. 10. Considering the date of credit of the advance tax to the government treasury as the date of payment instead of the date of tendering of the cheque of advance tax while calculating the interest u/s 234C of the Act." 5. Further, assessee

Crisil Ltd, Mumbai vs. Addl CIT 8(1), Mumbai

In the result the issue under consideration is remitted back to the file of Assessing Officer for statistical purpose

ITA 7603/MUM/2012[2008-09]Status: DisposedITAT Mumbai10 Jan 2024AY 2008-09

Bench: Shri Aby T Varkey, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

Section 133(6)Section 144C(5)

claimed in the revised return of income filed under section 139(5) of the Act. 9. Not considering advance tax payments of Rs. 25,000 and Rs. 3,75,00,000 paid on 14th June 2007 and 14th March 2008 respectively and dividend distribution tax ... while calculating the total tax liability. 10. Considering the date of credit of the advance tax to the government treasury as the date of payment instead of the date of tendering of the cheque of advance tax while calculating the interest u/s 234C of the Act.” 5. Further, assessee

M/S. Deepak Industries Ltd., Kolkata vs. DCIT, Circle-6(1), Kolkata

In the result, both the appeals of the assessee are partly allowed

ITA 466/KOL/2022[2018-2019]Status: DisposedITAT Kolkata09 Jan 2024AY 2018-2019

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma]

Section 139(1)Section 143(1)Section 2(24)(x)Section 234CSection 36(1)(va)Section 43(1)Section 43A

brought to our notice to the provisions of section 234C of the Act which is read as under: “Interest for deferment of advance tax 234C (1) Where in any financial year,— (a) the company which is liable to pay advance tax under section 208 has failed to pay such tax ... advance tax paid by the company on its current income on or before the 15th day of June is less than fifteen per cent of the tax due on the returned income or the amount of such advance tax paid on or before the 15th day of September is less

The DCIT Circle 5(1), Bhopal vs. M/S L N Malviya Infra Projects P Ltd, Bhopal

In the result, appeal of the revenue is partly allowed

ITA 189/IND/2023[2021-2022]Status: DisposedITAT Indore09 Jan 2024AY 2021-2022

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanidcit, Circle 5(1) M/S. L.N. Malviya Infra Projects Bhopal Pvt. Ltd. Plot No.29, F/F Sector, Dwarka Vs. New Delhi

Section 234ASection 3(3)Section 37(1)

assessee's business. The court held that (headnote) : "When interest is paid for committing a default in respect of the statutory liability to pay advance tax, the amount paid and the expenditure incurred in that connection is not in any way connected with preserving or promoting the business ... assessee. . . The liability in the case of payment of income-tax and interest for delayed payment of income- tax or advance tax arises on the computation of the profits and gains of business". The court further held that (headnote): "Under the Income-tax Act, the payment of such interest

Dy CIT 11 (3)(1), Mumbai vs. Total Oil India Pvt Ltd., Mumbai

In the result, the appeal of the revenue is dismissed and the Cross

ITA 6997/MUM/2019[2016-17]Status: DisposedITAT Mumbai29 Dec 2023AY 2016-17

Bench: Shri Vikas Awasthy&F Shri Amarjit Singhdy. Commissioner Of Vs. Total Oil India Pvt. Ltd. Income Tax-11(3)(1) 3Rd Floor, The Leela Room No. 204, Aayakar Galleria, Bhavan, M.K.Road, Andheri (E) Marine Lines Mumbai 400 059 Mumbai – 400 020 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aaace2175M Appellant .. Respondent

For Appellant: Niraj ShethFor Respondent: Ajay Kumar Sharma
Section 143(2)Section 143(3)Section 195Section 40

tax leviable for that assessment year" that in substance, a legal fiction is created by which the payments have been treated as advance tax. That is the purpose for which the legal fiction is created. In construing the said legal fiction, it will be proper and necessary to assume ... Total Oil India Pvt. Ltd. (emphasis supplied) So, necessarily all the provisions in the Act in respect of the payment of advance tax will apply. On effecting the regular assessment, if there is any excess payment made by the assessee, then the assessee would be entitled to the excess amount

Asst CIT (Ltu) 1, Mumbai vs. Grasim Industries Limited (As A Successor to Aditya Birla Nuvo Ltd, Mumbai

In the result, appeal of the Revenue is dismissed

ITA 1248/MUM/2017[2011-12]Status: DisposedITAT Mumbai28 Dec 2023AY 2011-12

Bench: Shri Vikas Awasthy, Jm & Ms Padmavathy S, Am

For Appellant: Shri Yogesh Thar, ARFor Respondent: Ms. A. Alankrutha, Sr. DR
Section 10BSection 115JSection 14ASection 234BSection 271(1)(c)Section 32(1)(iia)Section 37Section 40Section 43BSection 80I

IN THE INCOME TAX APPELLATE TRIBUNAL “K” BENCH, MUMBAI BEFORE SHRI VIKAS AWASTHY, JM & MS PADMAVATHY S, AM I.T.A. No