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“Section 139(2)”

Section References (mined)Section 139Section 139(2)39 judgments

The decision most relied on for Section 139(2) is CIT v. Kelvinator of India Ltd. (320 ITR 561), cited in 1,673 judgments on BharatTax.

Leading authorities on Section 139(2)

CIT v. Kelvinator of India Ltd.
320 ITR 561 · 2010 · Supreme Court
1,673
citing judgments

An Assessing Officer cannot initiate reassessment proceedings under Section 147 of the Income Tax Act based on a mere change of opinion. Reassessment is permissible only when there is fresh tangible material leading to the belief of income escapement, not merely a review of existing facts.

CIT v. AIMIL Ltd.
321 ITR 508 · 2010 · High Court
1,629
citing judgments

Employee contributions to PF and ESIC, deposited beyond the due date under the respective Acts but within the due date for filing the income tax return under Section 139(1), are allowable deductions under Section 36(1)(va). Such disallowance cannot be made during processing under Section 143(1).

Checkmate Services Pvt. Ltd. v. CIT
143 Taxmann.com 178 · 2022 · Supreme Court
1,392
citing judgments

Employee contributions to provident fund and ESI deposited by an employer beyond the due dates prescribed under the respective special Acts are not allowable as a deduction under section 36(1)(va) of the Income-tax Act, 1961. Such disallowance can be made during processing under section 143(1).

CIT v. Gujarat State Road Transport Corporation
366 ITR 170 · 2014 · High Court
1,158
citing judgments

Employees' contributions to welfare funds, such as provident fund, are not allowable as a deduction under section 36(1)(va) if deposited beyond the due date prescribed under the respective welfare statutes, even by a single day. Such delayed deposits are not cured even if made before the income-tax return filing due date.

Union of India v. Azadi Bachao Andolan
263 ITR 706 · 2003 · Supreme Court
691
citing judgments

A citizen is free to carry on business within the law, and mere tax planning without a motive to evade taxes through colorable devices is not frowned upon. The liability to taxation, for the purpose of tax treaty application, is a legal situation, not the fiscal fact of actual payment.

(i) CIT v. Merchem Ltd.
378 ITR 443 · 2015 · High Court
631
citing judgments

Belated remittance of employees' contribution to ESI and PF, even if deposited before the due date for filing the return of income under Section 139(1), is not allowed as a deduction. This disallowance falls under Section 36(1)(va) read with Section 2(24)(x), as Section 43B applies only to employer's contributions.

Co-operative Bank Ltd. v. CIT
384 ITR 490 · 2016 · High Court
631
citing judgments

Co-operative banks are not fundamentally different from co-operative societies, entitling them to claim deductions under Section 80P of the Income Tax Act, 1961, including for interest income treated as business income.

CIT v. Gujarat State Road Transport Corpn
41 Taxmann.com 100 · 2014 · High Court
540
citing judgments

Employees' contributions to provident fund or other welfare funds are deductible under section 36(1)(va) only if paid by the due date specified in the respective welfare fund enactments, and section 43B does not extend this period to the income tax return filing due date under section 139(1).

Judgments citing Section 139(2)

Dharam Chand Agarwal, Kanpur (Uttar Pardesh) vs. Principal Commissioner of Income Tax, Kanpur- I

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

ITA 358/LKW/2024[2016-2017]Status: DisposedITAT Lucknow31 Dec 2025AY 2016-2017

Bench: Sh. Kul Bharat & Sh. Nikhil Choudharya.Y. 2016-17 Dharam Chand Agarwal, Vs. Pr. Commissioner Of Income Tax, 14/75 D Gopal Vihar Civil Lines, Kanpur-I, U.P. Kanpur, U.P. Pan: Aanpa1942L (Appellant) (Respondent) Assessee By: Sh. P.K. Kapoor, C.A. Revenue By: Sh. R.K. Agarwal, Cit Dr Date Of Hearing: 07.10.2025 Date Of Pronouncement: 31.12.2025 O R D E R Per Nikhil Choudhary, A.M.: This Is An Appeal Filed By The Assessee Against The Orders Of The Ld. Pr. Cit, Kanpur-1 On 31.03.2024 Under Section 263 Of The Income Tax Act, 1961, Wherein The Ld. Pcit Has Set Aside The Order Passed By The Ld. Ao On 28.03.2022 Under Section 147 R.W.S. 144B For The A.Y. 2016-17 & Directing Him To Pass A Fresh Assessment Order. The Grounds Of Appeal Are As Under:- “1. Because The Assessment Order U/S 147 R.W.S 144 Dated 28.03.2022, Which Has Been Set Aside U/S 263 Of The Act By The Impugned Order Passed By Pr. Cit, Itself Was Illegal & Was Not Enforceable Due To Various Infirmities In The Initiation & Conclusion Of Re-Assessment Proceedings, The Same Could Not Have Been Subjected To Revision U/S 263 Of The Act & Consequently The Impugned Order Is Bad In Law & Wholly Without Jurisdiction. Without Prejudice To The Aforesaid 2. Because The Pr. Cit Has Erred In Law & On Facts In Holding That The Assessment Order Dated 28.03.2022 Passed By The Assessing Officer, Nfac U/S 147 R.W.S 144B Of The Act Is Erroneous In So Far As It Is Prejudicial To The Interest Of Revenue & In Setting Aside The Same By Exercising His Revisionary Jurisdiction U/S 263 Of The Act.

For Appellant: Sh. P.K. Kapoor, C.AFor Respondent: Sh. R.K. Agarwal, CIT DR
Section 133ASection 147Section 148Section 263

Gujarat High Court has held that if the assessee fails to file return as required by a notice under section 139(2), the ld. AO is bound to make an assessment of the total income or loss of the assessee to the best of his judgment under section

Sarvesh Kumar, Farrukhabad vs. Income Tax Officer Ward 4(2)(2) Farrukhabad, Farrukhabad

In the result, the appeal of the assessee is allowed

ITA 452/AGR/2024[2017-18]Status: DisposedITAT Agra13 Nov 2025AY 2017-18

Bench: Shri M. Balaganesh(Through Virtual Hearing) Sarvesh Kumar, Vs. Ito, Okharu Khanpur, Ward-4(2)(2), Farrukhabad, Fatehgarh, Farrukhabad Ho 209601 (Appellant) (Respondent) Pan: Dsqpk3348G Assessee By : Shri Swaran Singh, Ca Shri Shailesh Gupta, Ca Revenue By: Shri Anil Kumar, Sr. Dr Date Of Hearing 18/08/2025 Date Of Pronouncement 18/11/2025

For Appellant: Shri Swaran Singh, CAFor Respondent: Shri Anil Kumar, Sr. DR
Section 115BSection 139Section 139(1)Section 139(4)Section 142(1)Section 143(3)Section 144Section 147Section 148Section 44A

after the end of the assessment year and were, therefore, invalid and in that context our attention was invited to the provisions of section 139(2) before their deletion by Direct Tax Laws (Amendment) Act, 1987, we.f. 1-4- 1989, requiring such a notice to be issued before ... assessment year. As the notice under section 142(1) is a substitution of the requirement under section 139(2), the time limit for its issuance in the assessment year is inbuilt. 3 ……….…..………… 4 …………..…………. 5 …………………….. 6 ……………..……… 7 ………..…………… 8. Explanation 2(a) to section 147 of the Income-tax Act includes

Ujjal Sinha, Kolkata vs. DCIT, Central Circle 4(1), Kolkata

In the result, all the captioned appeals of the assessee are allowed

ITA 1931/KOL/2025[2008-2009]Status: DisposedITAT Kolkata13 Nov 2025AY 2008-2009

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubey

Section 139(1)Section 143(2)Section 153ASection 24Section 250Section 271(1)(c)Section 274

Indian Income Tax Act, 1922 or which you were required to furnish un 139(1) or by a notice given under section 139(2)/148 of the Income No. dated or have without failed to furnish it within the time allowed and the | ner 39(1) or by the such

Arus Properties LLP, Kolkata vs. D.C.I.T., Exempt - 1, Circle - 1(1), Kolkata

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

ITA 533/KOL/2025[2023-2024]Status: DisposedITAT Kolkata31 Oct 2025AY 2023-2024

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) & Shri Rajesh Kumari.T.A. No. 533/Kol/2025 Assessment Year: 2023-2024 Arus Properties Llp,………………………..….…Appellant 7B, Pretoria Street, ‘Alom House’, Kolkata-700071 [Pan:Abcfa4787H] -Vs.- Deputy Commissioner Of Income Tax,..…….Respondent Exempt-1, Circle-1(1), Kolkata, 10B, Middleton Row, Kolkata-700071 Appearances By: Shri P.J. Bhide, Fca, Appeared On Behalf Of The Assessee Ms. Archana Gupta, Addl. Cit, Sr. D.R., Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: August 06, 2025 Date Of Pronouncing The Order: October 31, 2025 O R D E R

Section 132(9)Section 71

view that the assessee has filed the return of income much prior to the date of filing of the return of income under section 139(2) of the Act. Therefore, the assessee is entitled to carry forward and set off against the future profits in accordance with the provisions

Deputy Commissioner of Income-Tax vs. The Jawaharlal Nehru Port Trust, Raigad

In the result, all the three appeals filed by the Revenue are dismissed and all the three appeals filed by the assessee are partly allowed

ITA 545/PUN/2016[2005-06]Status: DisposedITAT Pune30 Sept 2025AY 2005-06

Bench: Shri R. K. Panda & Ms Astha Chandra

For Appellant: S/Shri Madhur Agrawal, AdvocateFor Respondent: S/Shri Sham Walve, Special Counsel along with Tanzil Padvekar and Bhavik Chheda
Section 10(20)Section 11Section 12ASection 142Section 143(1)Section 143(3)Section 263

IN THE INCOME TAX APPELLATE TRIBUNAL PUNE BENCH “B”, PUNE BEFORE SHRI R. K. PANDA, VICE PRESIDENT AND MS ASTHA

Deputy Commissioner of Income-Tax vs. The Jawaharlal Nehru Port Trust, Raigad

In the result, all the three appeals filed by the Revenue are dismissed and all the three appeals filed by the assessee are partly allowed

ITA 544/PUN/2016[2004-05]Status: DisposedITAT Pune30 Sept 2025AY 2004-05

Bench: Shri R. K. Panda & Ms Astha Chandra

For Appellant: S/Shri Madhur Agrawal, AdvocateFor Respondent: S/Shri Sham Walve, Special Counsel along with Tanzil Padvekar and Bhavik Chheda
Section 10(20)Section 11Section 12ASection 142Section 143(1)Section 143(3)Section 263

IN THE INCOME TAX APPELLATE TRIBUNAL PUNE BENCH “B”, PUNE BEFORE SHRI R. K. PANDA, VICE PRESIDENT AND MS ASTHA

Deputy Commissioner of Income-Tax vs. The Jawaharlal Nehru Port Trust, Raigad

In the result, all the three appeals filed by the Revenue are dismissed and all the three appeals filed by the assessee are partly allowed

ITA 543/PUN/2016[2003-04]Status: DisposedITAT Pune30 Sept 2025AY 2003-04

Bench: Shri R. K. Panda & Ms Astha Chandra

For Appellant: S/Shri Madhur Agrawal, AdvocateFor Respondent: S/Shri Sham Walve, Special Counsel along with Tanzil Padvekar and Bhavik Chheda
Section 10(20)Section 11Section 12ASection 142Section 143(1)Section 143(3)Section 263

IN THE INCOME TAX APPELLATE TRIBUNAL PUNE BENCH “B”, PUNE BEFORE SHRI R. K. PANDA, VICE PRESIDENT AND MS ASTHA

Jawahar Lal Nehru Port Trust, Navi Mumbai vs. ACIT Panvel, Panvel

In the result, all the three appeals filed by the Revenue are dismissed and all the three appeals filed by the assessee are partly allowed

ITA 1155/MUM/2016[2004-05]Status: DisposedITAT Pune30 Sept 2025AY 2004-05

Bench: Shri R. K. Panda & Ms Astha Chandra

For Appellant: S/Shri Madhur Agrawal, AdvocateFor Respondent: S/Shri Sham Walve, Special Counsel along with Tanzil Padvekar and Bhavik Chheda
Section 10(20)Section 11Section 12ASection 142Section 143(1)Section 143(3)Section 263

IN THE INCOME TAX APPELLATE TRIBUNAL PUNE BENCH “B”, PUNE BEFORE SHRI R. K. PANDA, VICE PRESIDENT AND MS ASTHA

Jawahar Lal Nehru Port Trust, Navi Mumbai vs. ACIT Panvel, Panvel

In the result, all the three appeals filed by the Revenue are dismissed and all the three appeals filed by the assessee are partly allowed

ITA 1154/MUM/2016[2005-06]Status: DisposedITAT Pune30 Sept 2025AY 2005-06

Bench: Shri R. K. Panda & Ms Astha Chandra

For Appellant: S/Shri Madhur Agrawal, AdvocateFor Respondent: S/Shri Sham Walve, Special Counsel along with Tanzil Padvekar and Bhavik Chheda
Section 10(20)Section 11Section 12ASection 142Section 143(1)Section 143(3)Section 263

IN THE INCOME TAX APPELLATE TRIBUNAL PUNE BENCH “B”, PUNE BEFORE SHRI R. K. PANDA, VICE PRESIDENT AND MS ASTHA

Jawahar Lal Nehru Port Trust, Navi Mumbai vs. ACIT Panvel, Panvel

In the result, all the three appeals filed by the Revenue are dismissed and all the three appeals filed by the assessee are partly allowed

ITA 1153/MUM/2016[2003-04]Status: DisposedITAT Pune30 Sept 2025AY 2003-04

Bench: Shri R. K. Panda & Ms Astha Chandra

For Appellant: S/Shri Madhur Agrawal, AdvocateFor Respondent: S/Shri Sham Walve, Special Counsel along with Tanzil Padvekar and Bhavik Chheda
Section 10(20)Section 11Section 12ASection 142Section 143(1)Section 143(3)Section 263

IN THE INCOME TAX APPELLATE TRIBUNAL PUNE BENCH “B”, PUNE BEFORE SHRI R. K. PANDA, VICE PRESIDENT AND MS ASTHA

Sanjay Kumar Agrawal, Burhanpur vs. Joint Commissioner of Income Tax -OSD, Central-1, Indore

ITA 716/IND/2024[2014-15]Status: DisposedITAT Indore15 Sept 2025AY 2014-15

Bench: Shri B.M. Biyani

Section 132Section 153ASection 271(1)(c)Section 274

sarang aries arftaorsalkt earatio, galt IN THE INCOME TAX APPELLATE TRIBUNAL INDORE BENCH, INDORE BEFORE SHRI B.M. BIYANI, ACCOUNTANT MEMBER

Sanjay Kumar Agrawal, Burhanupur vs. Joint Commisiioner of Income Tax -OSD, Central-1, Indore

ITA 715/IND/2024[2013-14]Status: DisposedITAT Indore15 Sept 2025AY 2013-14

Bench: Shri B.M. Biyani

Section 132Section 153ASection 271(1)(c)Section 274

sarang aries arftaorsalkt earatio, galt IN THE INCOME TAX APPELLATE TRIBUNAL INDORE BENCH, INDORE BEFORE SHRI B.M. BIYANI, ACCOUNTANT MEMBER

Sanjay Kumar Agrawal, Burhanpur vs. Joint Commissioner of Income Tax (OSD) Central-1, Indore

ITA 714/IND/2024[2012-13]Status: DisposedITAT Indore15 Sept 2025AY 2012-13

Bench: Shri B.M. Biyani

Section 132Section 153ASection 271(1)(c)Section 274

sarang aries arftaorsalkt earatio, galt IN THE INCOME TAX APPELLATE TRIBUNAL INDORE BENCH, INDORE BEFORE SHRI B.M. BIYANI, ACCOUNTANT MEMBER

Krishnamurthy L/R by Smt. Nagarathnamma, Bangalore vs. DCIT, Circle-2(1), Bangalore

In the result, appeal filed by the assessee is allowed

ITA 570/BANG/2025[2012-13]Status: DisposedITAT Bangalore28 Aug 2025AY 2012-13

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan Kassessment Year : 2012-13 Shri. Krishnamurthy, Vs. Dcit, Represented By His Lr Smt. Nagarathnamma, Circle –2(1), No.152, 2Nd Floor, Hanuman Chambers, Bangalore. 7Th Cross, 2Nd Main, Chamarajpet, Bangalore – 560 018. Pan : Admpk 2463 J Appellant Respondent Assessee By : Shri. Ravishankar S. V, Advocate Revenue By : Shri. Balusamy N, Jcit(Dr)(Itat), Bangalore. Date Of Hearing : 22.07.2025 Date Of Pronouncement : 28.08.2025

For Appellant: Shri. Ravishankar S. V, AdvocateFor Respondent: Shri. Balusamy N, JCIT(DR)(ITAT), Bangalore
Section 139(1)Section 139(9)Section 140ASection 143(1)Section 143(2)Section 148Section 292B

income tax. At that relevant time (i.e. in 1986-87), there was sub-section (2) in Section 139 which provided as follows: "Section 139(2) : In the case of any person who, in the Income Tax Officer's opinion is assessable under this Act, whether on his own total income ... treated as an "invalid return" and provisions of the Act would apply "as if the assessee had filed to furnish the return"), section 139(2) (as it stood then) (which entitled the assessing officer to issue notice to the assessee to file a return when he is of the opinion

Pramod Kumar Choudhary, Jaipur vs. ITO, Jaipur

In the result, the appeal of the assessee is allowed

ITA 206/JPR/2025[2012-13]Status: DisposedITAT Jaipur09 Jul 2025AY 2012-13
For Appellant: Shri Vinod Kumar Gupta, CAFor Respondent: Shri Gautam Singh Choudhary, JCIT
Section 143(3)Section 147Section 69

this Act shall, so far as may be, apply accordingly as if such return were a return required to be furnished under section 139:" 2. Further, the expression “so for as may be” used in section 148 of the Act has been interpreted by the Hon'ble Apex court ... that section is very significant which provides that the aforesaid notice has to be treated as if it is a notice under section 139(2) and that all the provisions of the Act shall apply to the subsequent procedure and the final assessment. In other words, the notice issued under

Riyaz Qureshi, Jhabua vs. Income Tax Officer, Jhabua

Appeals are allowed

ITA 665/IND/2024[2015-16]Status: DisposedITAT Indore15 May 2025AY 2015-16

Bench: Shri B.M. Biyani

Section 139Section 139(1)Section 139(2)Section 142(1)Section 22(1)Section 271Section 271(1)(c)Section 274

India Income Tax Act, 1922 or which you were required to furnish under section 139(i) or by a nolice given under section 139(2)/148 of the Income Tax Act, 1961, ING, ciiccius.. OUR = or Have without reasonable cause failed to furnish it within the time allowed

Riyaz Qureshi, Jhabua vs. Income Tax Officer, Jhabua

Appeals are allowed

ITA 664/IND/2024[2014-15]Status: DisposedITAT Indore15 May 2025AY 2014-15

Bench: Shri B.M. Biyani

Section 139Section 139(1)Section 139(2)Section 142(1)Section 22(1)Section 271Section 271(1)(c)Section 274

India Income Tax Act, 1922 or which you were required to furnish under section 139(i) or by a nolice given under section 139(2)/148 of the Income Tax Act, 1961, ING, ciiccius.. OUR = or Have without reasonable cause failed to furnish it within the time allowed

Riyaz Qureshi, Jhabua vs. Income Tax Officer, Income Tax

Appeals are allowed

ITA 663/IND/2024[2013-14]Status: DisposedITAT Indore15 May 2025AY 2013-14

Bench: Shri B.M. Biyani

Section 139Section 139(1)Section 139(2)Section 142(1)Section 22(1)Section 271Section 271(1)(c)Section 274

India Income Tax Act, 1922 or which you were required to furnish under section 139(i) or by a nolice given under section 139(2)/148 of the Income Tax Act, 1961, ING, ciiccius.. OUR = or Have without reasonable cause failed to furnish it within the time allowed

Pankajkumar Chimanlal Lodhiya, Rakjot vs. The ACIT, Central Circle-2, Rajkot

ITA 81/RJT/2022[2014-15]Status: DisposedITAT Rajkot30 Apr 2025AY 2014-15

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं/.Ita No.76 To 80/Rjt/2022 निर्धारणवर्ष /Assessment Year: 2008-09 To 2012-13 & आयकर अपीलसं/.Ita No. 81/Rjt/2022 निर्धारणवर्ष /Assessment Year: 2014-15 Shri Pankaj Chimanlal Lodhiya 3Rd Floor, Parth, Diwanpara | बनाम Main Road, Rajkot-3600 001 Vs. Pan: Aampl 3903 F Assistant Commissioner Of Income-Tax, Central Circle-2 Rajkot, 2Nd Floor, Amruta Estate, M.G. Rad, Rajkot-360 001 (अपीलार्थी/Assessee) (प्रत्यर्थी/Respondent) निर्धारिती की ओर से/Assessee By : Shri Mehul Ranpura, Ar राजस्व की ओर से/Revenue By : Shri Sanjay Punglia, Cit-Dr सुनवाई की तारीख/Date Of Hearing : 05/03/2025 घोषणा की तारीख/Date Of Pronouncement : 30/04/2025 Order Per Bench, Captioned Six Appeals Filed By The Assessee, Pertaining To The Assessment Years (Ays) 2008-09 To 2012-13 & Ay 2014-15, Are Directed Against The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals), (“Ld.Cit(A)” For Short) Under Section 250 Of The Income Tax Act, 1961 (“The Act" For Short), Which In Turn Arise Out Of Separate Penalty Orders, Passed By The Assessing Officer U/S 271(1)(C) & 271Aab(1)(C) Of The Act.

For Appellant: Shri Mehul Ranpura, ARFor Respondent: Shri Sanjay Punglia, CIT-DR
Section 132Section 139(1)Section 143(3)Section 153ASection 250Section 271(1)(c)Section 271ASection 40

आयकर अपीलीय अधिकरण, राजकोटन्यायपीठ, राजकोट । IN THE INCOME TAX APPELLATE TRIBUNAL, RAJKOT BENCH, RAJКОТ BEFORE DR. ARJUN LAL SAINI, ACCOUNTANT

Pankajkumar Chimanlal Lodhiya, Rajkot vs. The ACIT, Central Circle-2, Rajkot

ITA 80/RJT/2022[2012-13]Status: DisposedITAT Rajkot30 Apr 2025AY 2012-13

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं/.Ita No.76 To 80/Rjt/2022 निर्धारणवर्ष /Assessment Year: 2008-09 To 2012-13 & आयकर अपीलसं/.Ita No. 81/Rjt/2022 निर्धारणवर्ष /Assessment Year: 2014-15 Shri Pankaj Chimanlal Lodhiya 3Rd Floor, Parth, Diwanpara Main Road, Rajkot-3600 001 Pan: Aampl 3903 F (अपीलार्थी/Assessee) बनाम Vs. Assistant Commissioner Of Income-Tax, Central Circle-2 Rajkot, 2Nd Floor, Amruta Estate, M.G. Rad, Rajkot-360 001 (प्रत्यर्थी/Respondent) निर्धारिती की ओर से/Assessee By : Shri Mehul Ranpura, Ar राजस्व की ओर से/Revenue By : Shri Sanjay Punglia, Cit-Dr सुनवाई की तारीख/Date Of Hearing घोषणा की तारीख/Date Of Pronouncement : 05/03/2025 : 30/04/2025 Order Per Bench, Captioned Six Appeals Filed By The Assessee, Pertaining To The Assessment Years (Ays) 2008-09 To 2012-13 & Ay 2014-15, Are Directed Against The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals), (“Ld.Cit(A)” For Short) Under Section 250 Of The Income Tax Act, 1961 (“The Act" For Short), Which In Turn Arise Out Of Separate Penalty Orders, Passed By The Assessing Officer U/S 271(1)(C) & 271Aab(1)(C) Of The Act.

For Appellant: Shri Mehul Ranpura, ARFor Respondent: Shri Sanjay Punglia, CIT-DR
Section 132Section 139(1)Section 143(3)Section 153ASection 250Section 271(1)(c)Section 271ASection 40

आयकर अपीलीय अधिकरण, राजकोटन्यायपीठ, राजकोट । IN THE INCOME TAX APPELLATE TRIBUNAL, RAJKOT BENCH, RAJKOT BEFORE DR. ARJUN LAL SAINI, ACCOUNTANT