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“first appeal”

AppealsSection 246ASection 246A5,395 judgments

The decision most relied on for first appeal is CIT v. Union Tyres (240 ITR 556), cited in 135 judgments on BharatTax.

Leading authorities on first appeal

CIT v. Union Tyres
240 ITR 556 · 1999 · High Court
135
citing judgments

The first appellate authority, the Commissioner (Appeals), cannot enhance an assessment by considering a new scope or source of income that was not part of the original assessment proceedings. Its power to enhance under Section 251(1)(a) is restricted to what was originally assessed.

Sanjay Sawhney v. Principal Commissioner of Income-tax
116 Taxmann.com 701 · 2020 · High Court
87
citing judgments

Rule 27 of the ITAT Rules allows a respondent to defend a favourable order of the CIT(A) by raising grounds decided against them, even without filing an appeal or cross-objection. Such issues can be raised orally and for the first time before the Tribunal.

Sugar Mills Pvt. Ltd. v. CIT
156 ITR 54 · 1985 · High Court
59
citing judgments

An appellate authority can admit and adjudicate a new legal ground for the first time, even if not raised in earlier appellate proceedings, provided its omission was neither willful nor unreasonable.

Kiran Singh & Ors. v. Chaman Paswan & Ors.
1 SCR 117 · 1955 · Supreme Court
55
citing judgments

A decree or proceeding initiated by an authority without jurisdiction is a nullity, void ab initio, and its invalidity can be raised at any stage, including in collateral proceedings or for the first time on appeal, as a defect of jurisdiction cannot be cured even by consent.

CIT v. S. Chenniappa Mudaliar
74 ITR 41 · 1969 · Supreme Court
40
citing judgments

The first appellate authority cannot dismiss an appeal for default without disposing of the grounds on merits. Dismissal without going into the merits is not justified.

Ultratech Cement Ltd. v. Additional Commissioner of Income Tax
408 ITR 500 · 2018 · High Court
32
citing judgments

A tribunal can exercise its discretion to admit an additional ground of appeal, even if raised for the first time, provided it considers the facts and circumstances of the case.

CIT v. Geo Industries and Insecticides (1) Pvt Ltd.
96 TTJ 211 · 2005 · ITAT
30
citing judgments

The Income Tax Appellate Tribunal (ITAT) can adjudicate a fresh claim raised for the first time before it, provided it is permissible under the law.

Ramco Cements Ltd. v. DCIT
373 ITR 146 · 2015 · High Court
28
citing judgments

An assessee can make a claim of deduction for the first time before the appellate authorities.

Judgments citing first appeal

Sachin Kumar Dixit, Farrukhabad vs. Income Tax Officer, Ward-4(2)(2), Farrukhabad

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

ITA 203/AGR/2024[2017-18]Status: DisposedITAT Agra19 Feb 2025AY 2017-18

Bench: : Shri Ramit Kochar & Shri Sudhir Kumarassessment Year: 2017-18

Section 115BSection 142(1)Section 144Section 44ASection 69A

other credit entries in the said bank accounts vide best judgment assessment order passed by the AO u/s. 144. 4. Aggrieved, the assessee filed first appeal with the CIT(Appeals). The CIT(Appeals) dismissed the appeal of the assessee as the assessee had not participated in the assessment proceedings

Nitin Chocrsey, Shivpuri vs. Income Tax Officer Shivpuri, Shivpuri

The appeal stand partly allowed for statistical purposes

ITA 138/AGR/2024[2010-11]Status: DisposedITAT Agra19 Feb 2025AY 2010-11

Bench: Hon’Ble Shri Satbeer Singh Godara, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं. / Ita No.138/Agr/2024 (िनधा"रणवष" / Assessment Year: 2010-11) Sh. Nitin Chocrsey Ito बनाम/ Chowksey Bhawan Shivpuri Ab Road, Kamalaganj, Shivpuri Vs. Mp – 473 551 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Ajfpc-1120-M (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri Rajendra Sharma (Advocate) – Ld. Ar " थ"कीओरसे/Respondent By : Shri Shailendra Shrivastava – Ld. Sr. Dr सुनवाईकीतारीख/Date Of Hearing : 19-02-2025 घोषणाकीतारीख /Date Of Pronouncement : 19-02-2025

For Appellant: Shri Rajendra Sharma (Advocate) – Ld. ARFor Respondent: Shri Shailendra Shrivastava – Ld. Sr. DR
Section 143(3)

valuation (SDV) of Rs.88.80 Lacs. The Ld. AO, invoking the provisions of Se.50C, adopted SDV of Rs.88.80 Lacs and re-computed capital gains. The first appeal was dismissed for want of any representation from the assessee. Aggrieved, the assessee is in further appeal before us. The Ld. AR has sought

Veerendra Singh, Jalaun vs. ITO, W 2(1)(5), Orai, Jalaun

The appeal of the assessee is allowed in the manner as indicated above

ITA 169/AGR/2022[2011-12]Status: DisposedITAT Agra19 Feb 2025AY 2011-12

Bench: Shri Ramit Kocharveerendra Singh, Income-Tax Officer, Vill. Dakor Mohana, Orai, Ward 2(1)(5), Orai, Distt. Jalaun (Up)-285001. V. Distt. Jalaun (Up) "थायीलेखासं./जीआइआरसं./Pan/Gir No: Bbjps 3108 J Appellant .. Respondent

Section 139Section 143(2)Section 147Section 148Section 250Section 44A

tune of Rs. 9,50,000/-; and unexplained investment in cash purchases to the tune of Rs. 3,54,495/-. Aggrieved, assessee filed first appeal to the learned CIT(Appeals) and the CIT(Appeals) partly allowed the appeal of the assessee. Now the assessee is in appeal before Tribunal

Usha Keshri, Saharsa vs. ITO, Ward-3(4), Saharsa

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

ITA 417/PAT/2024[2017-18]Status: DisposedITAT Patna19 Feb 2025AY 2017-18

Bench: SHRI SANJAY GARG, JUDICIAL MEMBER SHRI SANJAY AWASTHI (Accountant Member)

Section 142(1)Section 144Section 147Section 148Section 250Section 69A

aware about any such service of notice and ultimately ex-parte assessment was framed by order dated 13.12.2019. Against the assessment order first appeal was filed before CIT Appeal but later on the same was transferred under NFAC who vide order dated 08.04.2024 decided the appeal and confirm the addition

Jignesh Sukhdevbhai Patel L/H of Sukhdev Patel, Surat vs. Income Tax Officer, Ward -2(3)(6), Surat

In the result, this ground of appeal is partly allowed

ITA 128/SRT/2023[2012-13]Status: DisposedITAT Surat19 Feb 2025AY 2012-13

Bench: Shri Pawan Singh & Shri Bijayananda Prusethआयकर अपील सं./Ita No. 128/Srt/2023 (Ay 2012-13) (Physical Court Hearing) Jignesh Sukhdevbhai Patel Income Tax Officer, Ward-2(3)(6), 43, Ashutosh Nagri, Surat, Room No.606, बनाम Jahangirpura, Olpad Road, Aaykar Bhavan, Opp. New Civil Vs Surat-395 005 Hospital, Majura Gate, [Pan : Ajapp 1141 J] Surat-395 001 अपीलाथ"/Appellant ""थ" /Respondent

Section 142A(1)Section 142A(6)Section 143(3)Section 147Section 148Section 254(1)Section 50C

find that before Assessing Officer, the assessee has not raised any objection against the reopening nor raised such ground of appeal while filing first appeal. Before us, Ld. AR of the assessee has taken shelter of legal angle that this issue is purely legal in nature, however, on consideration ... valuation), New Delhi for review of the order of DVO. We further find that a revised report of DVO was received during pendency of first appeal. In the second report/revised report, DVO determined/estimated FMV @ Rs. 975/- per square meter. We have compared the comparable instances in first report

Bhagwan Singh Gour Running Aashirwad Fuel Point, Village Neemkhedi Post Runaha vs. ITO- 4 (3) Cv R Jaya Kumar, Income Tax Department Office of ITO

In the result, Ground No. 2 of the assessee’s appeal is allowed

ITA 159/IND/2024[2017-2018]Status: DisposedITAT Indore19 Feb 2025AY 2017-2018

Bench: Shri Siddhartha Nautiyal & Shri Bhagirath Mal Biyani

For Appellant: Shri Ankur Singh Gangwar, Rep. of the assesseeFor Respondent: Shri Ashish Porwal, Sr. DR
Section 115Section 115BSection 115bSection 1ISection 69

Respectfully following the precedent, I overturn the impugned order and direct to delete the addition of Rs.1,78,500/- sustained in the first appeal.” 5. Respectfully following the decision of ITAT Pune Bench in the case of M/s.Bhagur Urban Credit Co-operative Society Ltd., in ITA No.561/PUN/2022, it is held

Nitesh Mandhyan Lr Hiranand Mandhyan, Bhubaneswar vs. Income Tax Officer, Manicktala

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

ITA 2056/KOL/2024[2012-13]Status: DisposedITAT Kolkata19 Feb 2025AY 2012-13

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 10(38)Section 143(3)Section 147Section 148Section 250Section 68

also acknowledged the receipt of the information in the assessment order. Despite the knowledge of the same, the assessment order as well as the first appeal order has been passed in the name of the dead person Shri Hiranand Mandhyan. Hence, the reopening of the assessment and continuation

Symbolist Technology Private Limited, Mumbai vs. ITO, Ward 15(3)(1), Mumbai

In the result, the appeal in ITA No

ITA 93/MUM/2025[2022-23]Status: DisposedITAT Mumbai19 Feb 2025AY 2022-23

Bench: Shriamarjit Singh & Shri Anikesh Banerjee

For Appellant: Shri Manoj Kataruka, AdvFor Respondent: Ms. Monika H Pande,SR. AR
Section 143(1)Section 249(2)Section 250

appeal for adjudication. 3. The Ld. AR argued that the assessee's appeal was dismissed ex parte by the Ld. CIT(A). The first appeal was filed with a delay of 13 days, and the reasons for the delay were duly explained at the time of filing. However

The Orchard Residency Co-Op Housing Society Limited, Mumbai vs. Ward 27(3)(1), Mumbai

ITA 6009/MUM/2024[2020-21]Status: DisposedITAT Mumbai19 Feb 2025AY 2020-21

Bench: Shri Narender Kumar Choudhry

For Appellant: Shri Bhupendra Shah, Ld. A.RFor Respondent: Shri Kiran Unavekar, Ld. Sr. D.R
Section 143(3)Section 250Section 80(2)(d)Section 80P

said deduction claimed by the Assessee. 5. The Assessee, being aggrieved, challenged the said disallowance of deduction made by the AO, by filing first appeal 3 ITA No.6009/M/2024 M/s. The Orchard Residency Co-op Housing Society Limited before the Ld. Commissioner, however, with a delay of 318 days in filing ... order “. 7. The Assessee, being aggrieved, is in appeal before this Court and with regard to the contention of delay in filing of first appeal before the Ld. Commissioner, by filing a petition dated 15.01.2015 has contended as under: “Background: Our society, comprising 550 members, is a_ non-profit organization

Mr Rajesh Asrani, Mumbai vs. Income Tax Officer-23(3)(1), Mumbai

In the result, the appeal filed by the Assessee stands allowed

ITA 5964/MUM/2024[2011-12]Status: DisposedITAT Mumbai19 Feb 2025AY 2011-12

Bench: Shri Narender Kumar Choudhryassessment Year: 2011-12 Mr. Rajesh Baldevdas Income Tax Officer- Asrani, 23(3)(1), 201, Mangaldarshan, Piramal Chambers, Vs. 14 Turner Road, Bandra (West), Dr. Ss Rao Marg, Mumbai Parel, Mumbai Maharashtra – 400 050 Maharashtra – 400 012 Pan: Acopa6039M (Appellant) (Respondent)

For Appellant: Shri Nishit Gandhi, Ld. A.RFor Respondent: Shri Kiran Unavekar, Ld. Sr. D.R
Section 143(1)Section 147Section 148Section 250Section 69C

added back in the income of the Assessee u/s 69C of the Act. 4. The Assessee, being aggrieved, challenged the impugned addition by filing first appeal before the Ld. Commissioner but failed, as the Ld. Commissioner affirmed the said addition by dismissing appeal of the Assessee vide impugned order

Bharat Mithalal Jain, Bhayandar vs. NFAC, Delhi

In the result, the appeal filed by the Assessee is allowed in the aforesaid terms

ITA 5217/MUM/2024[2015-16]Status: DisposedITAT Mumbai19 Feb 2025AY 2015-16

Bench: Shri Narender Kumar Choudhry

For Appellant: Shri Vimal Punmiya, Ld. CAFor Respondent: Shri Srinivas P., Ld. Sr.DR
Section 115BSection 147Section 148Section 250Section 56(2)(vii)Section 69

added to the total income of the Assessee. 4. The Assessee, being aggrieved, challenged the said addition before the Ld. Commissioner by filing first appeal and reiterated his claim as made before the AO, however, of no avail, as the Ld. Commissioner by dismissing the appeal of the Assessee affirmed

Praham India LLP, Mumbai vs. Income Tax Officer 31(2), Mumbai

In the result, appeal of the assessee is allowed

ITA 4422/MUM/2024[2013-14]Status: DisposedITAT Mumbai19 Feb 2025AY 2013-14

Bench: Shri Amit Shukla & Shri Girish Agrawalassessment Year: 2013-14

For Appellant: Shri Madhur Agarwal, Advocate and Shri Mayur Kisnadwala, CAFor Respondent: Shri Krishna Kumar, Sr. DR
Section 132Section 143(3)Section 68

loans from the two entities was treated as unexplained cash credit in the hands of assessee u/s. 68 of the Act. 3. In the first appeal, assessee reiterated all its submissions along with documentary evidences, emphasising on the fact that the loans taken having duly repaid through proper banking channel

Sarbinder Singh Bindra, New Delhi vs. ACIT Circle-47(1), New Delhi

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

ITA 7591/DEL/2019[2016-17]Status: DisposedITAT Delhi19 Feb 2025AY 2016-17

Bench: Shri Vikas Awasthy & Shri Manish Agarwalsarbinder Singh Bindra Asst. Cit, 362, 2Nd Floor, Circle-47(1), Naya Katra, Chandni Vs. Delhi. Chowk, Delhi-110006. Pan-Aaepb2783P (Appellant) (Respondent)

Section 154

dated 02/08/2019 reduced the amount of disallowance of interest expense from Rs.1,13,15,755/- to Rs.99,19,025/-. 5. In first appeal, the Ld. CIT(A) has not accepted the contentions of the assessee, therefore, the appeal is filed before us. 6. During the course of hearing

Gorav Footwear, Agra vs. Deputy Commissioner of Income-Tax, Circle1(1)(1), Agra/CIT(A), NFAC, Delhi, Agra

The appeal stand allowed in terms of our above order

ITA 503/AGR/2024[2012-13]Status: DisposedITAT Agra18 Feb 2025AY 2012-13

Bench: Hon’Ble Shri Satbeer Singh Godara, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं./ Ita No.503/Agr/2024 (िनधा"रणवष" / Assessment Year: 2012-13) Gorav Footwear Dcit Circle 1(1)(1) बनाम/ 6, Nath Complex, Agra Vs. Dhakran Crossing, Agra – 282 003 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aahfg-7549-R (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri Deependra Mohan (Ca)- Ld.Ar " थ"कीओरसे/Respondent By : Shri Shailendra Shrivastava – Ld. Sr. Dr सुनवाईकीतारीख/Date Of Hearing : 18-02-2025 घोषणाकीतारीख /Date Of Pronouncement : 18-02-2025

For Appellant: Shri Deependra Mohan (CA)- Ld.ARFor Respondent: Shri Shailendra Shrivastava – Ld. Sr. DR
Section 143(3)Section 147Section 40A

addition has been made for the issue which form the very basis of reopening the case of the assessee. Though the assessee preferred first appeal, Ld. CIT(A) confirmed the action of Ld. AO and rejected the legal grounds as well as grounds on merits. Aggrieved, the assessee

Gaurav Goyal (HUF), Mathura vs. Income Tax Officer, Ward-1(3)(1), Mathura

The appeal stand allowed for statistical purposes

ITA 217/AGR/2024[2020-21]Status: DisposedITAT Agra18 Feb 2025AY 2020-21

Bench: Hon’Ble Shri Satbeer Singh Godara, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं./ Ita No.217/Agr/2024 (िनधा"रणवष" / Assessment Year: 2020-21) Gaurav Goyal (Huf) Ito Ward 1(3)(1) बनाम/ D-63,64, Shri Radhapuram Mathura Vs. Krishna Nagar, Mathura – 281 004 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aafhg-3017-C (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri Anurag Sinha (Advocate)- Ld.Ar " थ"कीओरसे/Respondent By : Shri Shailendra Shrivastava – Ld. Sr. Dr सुनवाईकीतारीख/Date Of Hearing : 18-02-2025 घोषणाकीतारीख /Date Of Pronouncement : 18-02-2025

For Appellant: Shri Anurag Sinha (Advocate)- Ld.ARFor Respondent: Shri Shailendra Shrivastava – Ld. Sr. DR
Section 143(3)

Rs.25.87 Lacs as ‘income from other sources’ since the assessee failed to substantiate the same. The Ld. CIT(A) did not admit the first appeal for want of condonation of delay of 2 months approx. Aggrieved, the assessee is in further appeal before us. 2. Summarizing various arguments favoring ... land which is taken on lease which is evidenced by lease deed as placed before lower authorities. The Ld. AR pleaded for admission of first appeal and also sought another opportunity of hearing to substantiate its case. The Ld. Sr. DR has opposed any interference in the impugned order

Jitendra Kumar, Bharatpur vs. ITO Ward 4(2)(1), Farrukhabad

The appeal stand allowed for statistical purposes

ITA 206/AGR/2024[2017-18]Status: DisposedITAT Agra18 Feb 2025AY 2017-18

Bench: Hon’Ble Shri Satbeer Singh Godara, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं./ Ita No.206/Agr/2024 (िनधा"रणवष" / Assessment Year: 2017-18) Shri Jitendra Kumar Ito Ward 4(2)(1) बनाम/ C/O J.N. Goyal & Company Farukhabad – 209 601 C-162, Ranjeet Nagar Vs. Bharatpur – 321 001 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Azppk-9634-G (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : None " थ"कीओरसे/Respondent By : Shri Shailendra Shrivastava – Ld. Sr. Dr सुनवाईकीतारीख/Date Of Hearing : 18-02-2025 घोषणाकीतारीख /Date Of Pronouncement : 18-02-2025

For Appellant: NoneFor Respondent: Shri Shailendra Shrivastava – Ld. Sr. DR
Section 143(3)Section 68

pleaded for dismissal of the appeal. In the assessment order, Ld. AO made addition u/s 68 for Rs.18.53 Lacs. Though the assessee preferred first appeal, it failed to make any representation therein which led to confirmation of assessment order. Aggrieved, the assessee is in further appeal before us. 2. Though

Bharat Nathabhai Barad, Veraval, Gir Somnath vs. ITO Ward-4, Veraval

ITA 411/RJT/2023[2014-15]Status: DisposedITAT Rajkot18 Feb 2025AY 2014-15

Bench: Dr. Arjun Lal Saini, Am. & Dinesh Mohan Sinha, Jm आयकरअपीलसं./Ita No.411/Rjt/2023 "नधा"रणवष" / Assessment Year: (2014-15) (Hybrid Hearing) Bharat Nathabhai Barad Vs. The Income Tax Officer, Prop. Of M/S. Vinesh Enterprise, Ward-4, Village: Savani, Tal.: Veraval, Veraval. Veraval - Kodinar Highway, Dist.: Gir Somnath-362 268. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Avjpb6301K (Appellant) (Respondent)

For Appellant: Shri Kalpesh Parekh, Ld. ARFor Respondent: Shri B.D. Gupta, Ld. Sr. DR
Section 143(3)Section 250Section 253Section 69

been passed against me and a penalty of Rs.18,93,615/- is also levied. At this juncture only. I came to know that my first appeal has been dismissed in limine by the Hon'ble CIT(A) vide appellate order dated 11.06.2022. 7. Thereafter, on asking about the remedy available

Deputy Commissioner of Income -Tax, Central Circle-1(1), Ahmedabad vs. Prakash Misrimal Sanghvi, Ahmedabad

In the result, the appeal of the Revenue in ITA No

ITA 1184/AHD/2024[2021-22]Status: DisposedITAT Ahmedabad18 Feb 2025AY 2021-22
For Appellant: Shri S. N. Soparkar, Sr. Advocate &For Respondent: Shri A. P. Singh, CIT-DR
Section 132Section 132(4)Section 143(3)Section 147Section 148

Accordingly, the total credit of Rs.20,82,37,741/- as appearing in this ledger account was treated as income of the assessee. 55. In first appeal, the Ld. CIT(A) had held that the Maalkhaate ledger also had debit entries and, therefore, he reduced the addition ... interest of Rs.16,39,02,055/- as income of the assessee following the mercantile system of accounting and accordingly made the addition. In the first appeal, the Ld. CIT(A) had deleted the addition by holding that the entries for accrued interest were only notional entries and that no income

Deputy Commissioner of Income -Tax, Central Circle-1(1), Ahmedabad vs. Prakash Misrimal Sanghvi, Ahmedabad

In the result, the appeal of the Revenue in ITA No

ITA 1155/AHD/2024[2020-21]Status: DisposedITAT Ahmedabad18 Feb 2025AY 2020-21
For Appellant: Shri S. N. Soparkar, Sr. Advocate &For Respondent: Shri A. P. Singh, CIT-DR
Section 132Section 132(4)Section 143(3)Section 147Section 148

Accordingly, the total credit of Rs.20,82,37,741/- as appearing in this ledger account was treated as income of the assessee. 55. In first appeal, the Ld. CIT(A) had held that the Maalkhaate ledger also had debit entries and, therefore, he reduced the addition ... interest of Rs.16,39,02,055/- as income of the assessee following the mercantile system of accounting and accordingly made the addition. In the first appeal, the Ld. CIT(A) had deleted the addition by holding that the entries for accrued interest were only notional entries and that no income

Deputy Commissioner of Income -Tax, Central Circle-1(1), Ahmedabad vs. Prakash Misrimal Sanghvi, Ahmedabad

In the result, the appeal of the Revenue in ITA No

ITA 1154/AHD/2024[2019-20]Status: DisposedITAT Ahmedabad18 Feb 2025AY 2019-20

Bench: Shri T.R. Senthil Kumar & Shri Narendra Prasad Sinhaआयकर अपील सं./I.T.A. Nos. 1138 To 1146/Ahd/2024 ("नधा"रण वष" / Assessment Years : 2013-14 To 2021-22) बनाम/ Prakash Misrimal Deputy Commissioner Of Sanghvi Income-Tax Vs. 17, Rajmugat Soc. Central Circle-1(1), Naranpura Char Rasta, Ahmedabad Naranpura, Ahmedabad 380013 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaeps7266A (Appellant) .. (Respondent)

For Appellant: Shri S. N. Soparkar, Sr. Advocate &For Respondent: Shri A. P. Singh, CIT-DR
Section 132Section 132(4)Section 143(3)Section 147Section 148

total credit of Rs.20,82,37,741/- as appearing in this ledger account was treated as income of the assessee. 55. In first appeal, the Ld. CIT(A) had held that the Maalkhaate ledger also had debit entries and, therefore, he reduced the addition to 20% of the total credits