“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

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

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

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

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

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

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

citing judgments

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

Judgments citing first appeal

Parveen Kumar, Ludhiana vs. ITO, Ward 3(1), Ludhiana

In the result, the appeal of Assessee is treated as allowed for statistical purposes

ITA 863/CHANDI/2023[2017-18]Status: DisposedITAT Chandigarh20 Aug 2024AY 2017-18

Bench: Shri Sanjay Garg & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 863/Chd/2023 "नधा"रण वष" / Assessment Year : 2017-18 बनाम Parveen Kumar, The Ito, Prop.Bombay Jewellers, Ward 3(1), Ludhiana Opp. Punjab National Bank, Rahon Road, Basti Jodhewal, Ludhiana "थायी लेखा सं./Pan No: Aicpk2556P अपीलाथ"/Appellant ""यथ"/Respondent ( Hybrid Hearing ) "नधा"रती क" ओर से/Assessee By : Shri Pankaj Bhalla, Ca राज"व क" ओर से/ Revenue By : Shri Vivek Vardhan, Jcit, Sr. Dr सुनवाई क" तार"ख/Date Of Hearing : 19.08.2024 उदघोषणा क" तार"ख/Date Of Pronouncement : 20.08.2024 आदेश/Order Per Sanjay Garg:

For Appellant: Shri Pankaj Bhalla, CAFor Respondent: Shri Vivek Vardhan, JCIT, Sr. DR

Section 69A

confined to a wheelchair for eight months and was unable to communicate with his counsel or provide the necessary information and documents for the first appeal proceedings. It has, therefore, been explained that due to the aforesaid reasons, which were beyond the control of the Assessee, the Assessee could

Dared Seva Sahkari Mandali Limited, Bhavanagar vs. ITO, Ward-1(1), Bhavnagar

In the result, appeal of the assessee in ITA no

ITA 885/AHD/2024[2019-20]Status: DisposedITAT Ahmedabad20 Aug 2024AY 2019-20

Bench: Income Tax Appellate Tribunal, Ahmedabad Bench, Ahmedabad Has Arisen From The Separate Appellate

For Appellant: Shri Bansi Thakrar, A.RFor Respondent: Shri Santosh Kumar, Sr. D.R

Section 139(1)Section 142(1)Section 144BSection 147Section 148Section 156Section 250Section 80P

passed by the AO u/s 147 read with Section 144B of the 1961 Act. 4. Assessee being aggrieved by the aforesaid reassessment order filed first appeal with the ld. CIT(A) , and the ld. CIT(A) dismissed the appeal of the I.T.A Nos. 884 & 885/Ahd/2024

Dared Seva Sahkari Mandali Limited, Bhavnagar, Gujarat vs. ITO, Ward-1(1), Bhavnagar

In the result, appeal of the assessee in ITA no

ITA 884/AHD/2024[2018-19]Status: DisposedITAT Ahmedabad20 Aug 2024AY 2018-19

Bench: Income Tax Appellate Tribunal, Ahmedabad Bench, Ahmedabad Has Arisen From The Separate Appellate

For Appellant: Shri Bansi Thakrar, A.RFor Respondent: Shri Santosh Kumar, Sr. D.R

Section 139(1)Section 142(1)Section 144BSection 147Section 148Section 156Section 250Section 80P

Summit Sports Pvt Ltd, Pune vs. Additional Director of Income Tax CPC, Banglore

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

ITA 620/PUN/2024[2019-20]Status: DisposedITAT Pune20 Aug 2024AY 2019-20

Bench: Shri Inturi Rama Rao & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.620/Pun/2024 िनधा"रण वष" / Assessment Year : 2019-20 Summit Sports Pvt. Ltd., Vs. Addl. Dit, Cpc, T-170, Midc, Bhosari, Banglore. Pune- 411026. Pan : Aatcs8122M Appellant Respondent Assessee By : Shri Akshay Shivaji Revenue By : Shri Akhilesh Srivastava Date Of Hearing : 04.07.2024 Date Of Pronouncement : 20.08.2024 आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 15.02.2024 Passed By Ld Addl./Jcit(A), Jodhpur For The Assessment Year 2019-20. 2. The Appellant Raised The Following Grounds Of Appeal :- “1. At The Time Of Assessment, Learned Assessing Authority Passed Assessment Order & Disallowed Claim Of Tds On Account Of Mismatch With 26As. 2. The Learned Assessing Authority Levied Excess Interest U/S 2234B & 234C Without Considering Tax Payment Which Is Unjustified. 3. At The First Hearing Of An Appeal, The Appellant Authority Dismissed The Appeal On Account Of Appeal Is Not Maintainable As There Is Inordinate Delay In Filing An Appeal Which Cannot Be Condoned Without Considering The Facts Of The Case Which Is Unjustified.”

For Appellant: Shri Akshay ShivajiFor Respondent: Shri Akhilesh Srivastava

Section 143(1)Section 223

present appeal, the son of the director of the company appeared & requested for short adjournment. We find that the order dismissing the first appeal of the assessee on the ground of delayed filing of the appeal is unjustified. We therefore reject the request for adjournment & proceed to decide the appeal ... pandemic situation the order could not be seen by the assessee & thereafter as soon as the order came into knowledge of the assessee the first appeal was filed belatedly. In the grounds of appeal it was requested before the bench to set-aside the order passed

Millenium Buildhome Private Limited, Kota vs. ITO(TDS), Kota

In the result, the appeal of the assessee is stands partly allowed with no 6

ITA 866/JPR/2024[2016-17,2017-18,2018-19]Status: DisposedITAT Jaipur20 Aug 2024

For Appellant: Shri Rajendra Sisodiya, AdvFor Respondent: Mrs. Monisha Choudhary, Addl. CIT-DR

Section 194Section 201Section 201(1)

default u/s 201(1) and raised a demand in respect of the TDS not deducted on account of interest paid to HCCSL. In first appeal, the ld. CIT(A) has dismissed the appeal of the assessee holding that ‘’No fault is found in the order of the ITO, TDS with

Indra Kumar Narwani, Jaipur vs. ITO WD 5(3), Jpr, Jaipur

In the result, the appeal of the assessee is allowed with no orders as to costs

ITA 564/JPR/2024[2017-18]Status: DisposedITAT Jaipur20 Aug 2024AY 2017-18

Bench: SHRI SANDEEP GOSAIN (Judicial Member)

For Appellant: Shri Deepak Sharma, AdvocateFor Respondent: Mrs. Monisha Choudhary, Addl. CIT-DR

Section 131Section 132(4)Section 133Section 133ASection 143(3)Section 69Section 69A

INDRA KUMAR NARWANI VS ITO, WARD 5(3), JAIPUR shown by the assessee thus resulting into trading addition of Rs.4,37,289/-. In the first appeal, the addition so made was sustained by Ld.CIT(A). 3.2 During the course of hearing the ld. AR of the assessee filed the written

Dedhia Associates, Mumbai vs. DCIT42(1)(1), Mumbai

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

ITA 3236/MUM/2024[2013-14]Status: DisposedITAT Mumbai20 Aug 2024AY 2013-14

Bench: Shri Narendra Kumar Billaiya, Hon’Ble & Shri Sandeep Singh Karhail, Hon’Ble

For Appellant: Shri Anuj Kisnadwala, A/RFor Respondent: Smt. Mahita Nair, Sr. D/R

Section 143(3)Section 147Section 148Section 234BSection 35

NFAC/S/62/2022- 23/1046555671(1) A.Y. - 2013-14 With reference to our Appeal filed for the A.Y. 2013-14, we have to state as under:- (1) First Appeal (Addition of Rs. 43,75,000 - Disallowance U/s. 35 (i)(ii) Appeal filed against Order U/s. 143(3) of Income Tax Act 1961 dated

Smt. Pashiben Prajapati Family Trust (Disc), Ahmedabad vs. The Income Tax Officer, Ward-3(3)(5), Ahmedabad

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

ITA 305/AHD/2024[2021-22]Status: DisposedITAT Ahmedabad16 Aug 2024AY 2021-22

Bench: Ld. Cit(A) Has In-Turn Arisen From The Intimation Dated 07.12.2022 Issued By Cpc, Bengaluru, U/S.154(Cpc/2122/U5/ 314311772) Of The Act.

For Appellant: Shri Rupesh R Shah, AdvocateFor Respondent: Shri Sanjay Jain, Sr. D.R

Section 154Section 164(1)Section 250Section 80Section 80C

assessee at maximum marginal rate and TDS credit was also not given as per 26AS submitted by the assesse. 4. The assessee filed first appeal before Ld.CIT(A), and raised as many as five grounds of appeal. In the grounds of appeal and SOF filed by the assessee with

Pareshkumar Punamchand Shah, Ahmedabad vs. The Income Tax Officer, Ward-2(2)(4), Ahmedabad

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

ITA 1096/AHD/2023[2011-12]Status: DisposedITAT Ahmedabad16 Aug 2024AY 2011-12

Bench: Shri Ramit Kochar (Accountant Member)

For Appellant: CA Preyashi TatedFor Respondent: Shri Hrishikesh Hemant Patki, Sr. D.R

Section 144Section 250Section 253(3)

making additions to the tune of Rs.29,93,000/- to the income of the assessee towards undisclosed cash deposits. 4. Aggrieved, the assessee filed first appeal before the Ld.CIT(A), who adjudicated the appeal of the assessee , by holding as under: “4.4 Decision 4.4.1 It is an admitted fact that ... loss of Rs. 62,71,285/- incurred by the assessee in commodities transactions through MCX was ignored. The assessee filed first appeal before the Ld.CIT(A), who partly allowed the appeal of the assessee by confirming the order of the AO to the tune of Rs.24,83,000/- being unexplained

Deputy Commissioner of Income Tax, Central Circle-1, Faridabad, Income Tax Department vs. Ludhiana Sangrur Infra Road Private Limited, Hisar

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

ITA 3179/DEL/2023[2016-17]Status: DisposedITAT Delhi16 Aug 2024AY 2016-17

Bench: the Ld. Commissioner of Income Tax (Appeals)-3, Gurugram and the Ld. Commissioner of Income Tax (Appeals)-3, vide order dated 16/08/2023 decided the appeal and accepted the contention of the Assessee. Reference is drawn to para 4.4 at pg.98 of his order.

Section 132Section 133ASection 148Section 40A(3)

Supreme Court held as under: "The appellate Court has jurisdiction to reverse or affirm the findings of the trial Court. First appeal is a valuable right of the parties and unless restricted by law, the whole case is therein open for hearing both on questions of fact

Deputy Commissioner of Income Tax, Aurangabad vs. Sandeep Bipinchandra Jhaveri, Mumbai

In the result, the appeal filed by the Revenue stands dismissed

ITA 1185/PUN/2023[2013-14]Status: DisposedITAT Pune14 Aug 2024AY 2013-14

Bench: Shri R. K. Panda & Shri Vinay Bhamoresl.

For Appellant: Shri Deepak ShahFor Respondent: Shri Sourabh Nayak

Section 132Section 143(3)Section 153ASection 153C

filed before the Ld. CIT(A), who vide impugned order dated 26.09.2023 allowed the appeal of the assessee. 5. Being aggrieved with the above first appeal order, Revenue is in appeal before this Tribunal. 6. LD DR submitted before us that LD CIT(A), Pune erred in allowing the appeal

Sri Rangasamy Gounder Jewellery, Erode vs. ITO Ward 2(1), Erode

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

ITA 1364/CHNY/2024[2017-18]Status: DisposedITAT Chennai14 Aug 2024AY 2017-18

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm आयकरअपील सं./ Ita No.1364/Chny/2024 (िनधा"रणवष" / Assessment Year: 2017-2018) Sri Rangasamy Gounder Jewellary, Vs. The Income Tax Officer, No.281/173, 416/682, Ward 2(1) Nambiyur Main Road, Erode Gobichettipalayam, Erode 638 458. [Pan: Adafs 7892M] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Shri. N.C. Ravikrishnan, Advocate ""यथ" क" ओर से /Respondent By : Ms. Gouthami Manivasagam, Irs, Jcit. सुनवाई क" तार"ख/Date Of Hearing : 13.08.2024 घोषणा क" तार"ख /Date Of Pronouncement : 14.08.2024 आदेश / O R D E R Per Manu Kumar Giri ()

For Appellant: Shri. N.C. Ravikrishnan, AdvocateFor Respondent: Ms. Gouthami Manivasagam, IRS, JCIT

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

dated 28.12.2019 before the Ld. CIT(A) wherein the assessee did not file any documents/evidence clarifying the source for cash deposits before the first appeal authority. Accordingly, the assessment was confirmed on merits against which assessee is in further appeal before us. 4. At the outset, Ld. Counsel

Deputy Commissioner of Income Tax, Aurangabad vs. Marsh Fincom Pvt. Ltd., Mumbai

In the result, the appeal filed by the Revenue stands dismissed

ITA 1342/PUN/2023[2010-11]Status: DisposedITAT Pune13 Aug 2024AY 2010-11

Bench: Shri R. K. Panda & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1342/Pun/2023 िनधा"रण वष" / Assessment Year: 2010-11 Dcit, Aurangabad. Vs. Marsh Fincom Pvt. Ltd., 9Th Floor, Gold Crest, Ns Road No.10, Jvpd Scheme, Vile Parle (W), Mumbai- 400049. Pan : Aabck0760B Appellant Respondent Assessee By : Shri Deepak Shah Revenue By : Shri Sourabh Nayak Date Of Hearing : 26.06.2024 Date Of Pronouncement : 13.08.2024 आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Revenue Is Directed Against The Order Dated 07.09.2023 Passed By Ld Cit(A)-12, Pune For The Assessment Year 2010-11. 2. The Revenue Has Raised The Following Grounds Of Appeal :- “1. Whether On The Facts & In The Circumstances Of The Case & In Law, The Ld. Cit(A) Has Erred In Law & In Facts By Quashing Proceedings U/S. 153A In Respect Of Assessee Where The Assessee’S Case Was Covered Under Section 132 Of The Act Dated 20.08.2014. 2. Whether On The Facts & In The Circumstances Of The Case & In Law, The Ld. Cit(A) Has Erred In Holding That The Ao Has Made

For Appellant: Shri Deepak ShahFor Respondent: Shri Sourabh Nayak

Section 132Section 132(4)Section 143(3)Section 153ASection 68

filed before the Ld. CIT(A), who vide impugned order dated 07.09.2023 allowed the appeal of the assessee. 5. Being aggrieved with the above first appeal order, the Revenue is in appeal before this Tribunal. 6. LD DR submitted before us that LD CIT(A), Pune erred in allowing

ITO 17(3)(1), Bkc, Bandra(E) vs. Hakimuddin Saleh Porbunderwala, Mumbai

In the result, the appeal filed by the Revenue Department stands dismissed

ITA 3248/MUM/2024[2021-22]Status: DisposedITAT Mumbai13 Aug 2024AY 2021-22

Bench: Shri Narender Kumar Choudhry & Shri Ratnesh Nandan Sahayassessment Year: 2021-22

For Appellant: NoneFor Respondent: Shri P.D. Chougule, (Addl. CIT) Sr. DR

Section 133(6)Section 143(3)Section 250Section 271ASection 69C

expenditure. Penalty proceedings u/s 271AAC (1) is also initiated.” 4. The assessee, being aggrieved, challenged the aforesaid addition of Rs.45,03,453/- by filing first appeal before the Ld. Commissioner, who out of total addition of Rs.5,18,276/-, partly deleted the addition to the extent of Rs.39

Tara Dayalal Jain, Mumbai vs. ITO - 23(3)(7), Mumbai, Presently Jurisdiction With ITO - 23(3)(6)

In the result, the appeal filed by the Assessee stands allowed for statistical purposes

ITA 3640/MUM/2023[2012-13]Status: DisposedITAT Mumbai13 Aug 2024AY 2012-13

Bench: Shri Narender Kumar Choudhry & Shri Ratnesh Nandan Sahayassessment Year: 2012-13

For Appellant: Ms. Samruddhi Tawde, A.RFor Respondent: Shri P.D. Chougule, (Addl. CIT) Sr. DR

Section 143(3)Section 147Section 250Section 69

appeal of the Assessee as ex-parte and ultimately dismissed the same and consequently affirmed the aforesaid addition. 3. We observe that the first appeal before the Ld. Commissioner was instituted on 14.01.2020 and first notice for due compliance was sent on 21.01.2021 for 19.04.2021 admittedly during the Covid

Inder Pal Singh Legal Heir of Deceased Satnam Singh 171789, Street No.8, Guru Teg Bahadur Jagraon, Punjab vs. The Income Tax Officer Ward-1 Jagraon, Punjab

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

ITA 43/CHANDI/2024[2018-2019]Status: DisposedITAT Chandigarh12 Aug 2024AY 2018-2019

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member), SHRI. PARESH M. JOSHI (Judicial Member)

For Appellant: Shri Kushal Chopra, C.AFor Respondent: Shri Rohit Sharma, CIT DR

Section 250Section 253Section 269SSection 271Section 271DSection 274

levied u/s. 271 DA of the l.T. Act. 7. The assessee being aggrieved by the order of Ld. AO dated 16/03/2022 preferred first appeal before the Ld. CIT(A) who by impugned order has sustained the order of Ld. AO dt. 16.03.2022. 8. The assessee being aggrieved by the impugned

Saket M Jain (HUF), Ahmedabad vs. The Income Tax Officer, Ward-5(2)(4), Ahmedabad

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

ITA 314/AHD/2023[2013-14]Status: DisposedITAT Ahmedabad12 Aug 2024AY 2013-14

Bench: Income Tax Appellate Tribunal, Ahmedabad Division Bench, Ahmedabad Has Arisen From The Appellate Order Dated 24.03.2023 Passed By Ld. Cit(A), Nfac, Delhi U/S.250 Of The Income-Tax Act,1961

For Appellant: None(Adjournment Application-Rejected)For Respondent: Shri Ashok Kumar Suthar, Sr.DR

Section 133(6)Section 142(1)Section 143Section 143(1)Section 143(2)Section 145Section 250

assessee, on account of interest income received by the assessee on Income tax refund granted by the Revenue. 4. Aggrieved , the assesee filed first appeal before Ld.CIT(A) who dismissed the appeal of the assessee on grounds of non 7 I.T.A No.314/Ahd/2023 A.Y. 2013-14 Page No. Saket M Jain ... assessment order, there was no reasons for 11 I.T.A No.314/Ahd/2023 A.Y. 2013-14 Page No. Saket M Jain(HUF) the assessee to have filed first appeal before ld. CIT(A) and also further second appeal before us. The assessee had infact sought adjournment on the last date of hearing

Sandip Kumar Agarwal, Kolkata vs. I.T.O., Ward - 45(2), Kolkata

The appeal of the assessee is allowed for statistical purposes

ITA 1057/KOL/2024[2015-2016]Status: HeardITAT Kolkata08 Aug 2024AY 2015-2016

Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Rajesh Kumari.T.A. No. 1057/Kol/2024 Assessment Year: 2015-2016 Sandip Kumar Agarwal,………….…..…………Appellant P-19/1, Vip Road, Scheme-Vii M, Kolkata-700054 [Pan:Admpa3225G] -Vs.- Income Tax Officer,………………………………Respondent Ward-45(2), Kolkata

Section 155Section 50CSection 56(2)(vii)

Officer, he should make a reference to the DVO for the just decision of the appeal. The objective of the ld. Commissioner in the first appeal ought to have been to resolve the controversy in a fair manner according to the position of law and not to legalize injustice

Rafeena Sulthana, Pollachi vs. Commissioner of Incometax (Appeals), Delhi

The appeal stand allowed for statistical purposes

ITA 1340/CHNY/2024[2013-2014]Status: DisposedITAT Chennai08 Aug 2024AY 2013-2014

Bench: Hon’Ble Shri Mahavir Singh, Vp & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं./ Ita No.1340/Chny/2024 (िनधा)रण वष) / Assessment Year: 2013-14) Sahul Hameed Rafeena Sulthana Ito बनाम/ 72, Thirunilakandar Street, Che-W(63)(95) Vs. Pollachi-642 001. Chennai. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Axnpr-5371-D (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri D.Anand (Advocate)-Ld. Ar " थ"कीओरसे/Respondent By : Ms. Samantha Mullamudi (Addl.Cit) -Ld. Sr. Dr सुनवाईकीतारीख/Date Of Hearing : 22-07-2024 घोषणाकीतारीख /Date Of Pronouncement : 08-08-2024 आदेश / O R D E R Manoj Kumar Aggarwal ()

For Appellant: Shri D.Anand (Advocate)-Ld. ARFor Respondent: Ms. Samantha Mullamudi (Addl.CIT) -Ld. Sr. DR

Section 147

that the assessment has been framed on best judgment basis making addition of cash deposits of Rs.63.63 Lacs. The assessee failed to appear during first appeal proceedings and accordingly, the assessment was confirmed. Aggrieved, the assessee is in further appeal before us. 2. The Ld.AR has submitted that the assessee

K.S. Distributors, Jaipur vs. ITO, Ward-3(2), Jaipur

In the result, the appeal of the assessee is partly allowed with no orders as to costs

ITA 428/JPR/2024[2016-17]Status: DisposedITAT Jaipur08 Aug 2024AY 2016-17

For Appellant: Shri P.C. Parwal, CAFor Respondent: Mrs. Monisha Choudhary, Addl. CIT-DR

Section 144Section 243(2)

Thus the AO disallowed 20% of the expenses claimed of Rs.25,11,784/- and made addition of Rs.5,02,357/- . 3.2 In first appeal, the ld. CIT(A) has confirmed the action of the AO by dismissing the appeal of the assessee. 3.3 During the course of hearing