“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

The Assistant Commissioner of Income-Tax-2(1)Bhilai, Bhilai(Cg) vs. M/S Sms Shivnath Infrasstructure Pvt Ltd., Durg, Durg(Cg)

In the result, appeal of the revenue in ITA No

ITA 87/BIL/2017[2012-13]Status: DisposedITAT Raipur27 Mar 2023AY 2012-13

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अऩीऱ सं./Ita No.87/Rpr/2017 (ननधाारण वषा / Assessment Year :2012-2013) Acit-2(1), Bhilai Vs M/S Sms Shivnath Infrastructure Pvt Ltd.,Toll Plaza, Near Dhamdhanaka, Durg. Pan No. :Aadcs 2258 Q (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) .. & आयकर अऩीऱ सं./Ita No.107/Rpr/2016 (ननधाारण वषा / Assessment Year :2012-2013) M/S Sms Shivnath Infrastructure Vs Pr.Cit-2, Raipur Pvt Ltd.,Toll Plaza, Near Dhamdhanaka, Durg. Pan No. :Aadcs 2258 Q (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) ..

For Appellant: Shri Kapil Hirani, Adv. & MukeshFor Respondent: Shri Debashis Lahiri, CIT-DR

Section 115JSection 143(3)Section 250(4)Section 36Section 80ISection 80l

assessment order on pages 32 - 38 of paper book. 7. The Assessee being aggrieved by the additions so made by the AO preferred first appeal before the CIT(A) - 11, Raipur who vide order dated 28.2.2017 allowed the appeal of the Assessee and deleted the addition made

M/S Sms Shivnath Infrastructure Pvt Ltd, Durg(Cg) vs. The Pr. Commissioner of Income Tax-2, Raipur (Cg)

In the result, appeal of the revenue in ITA No

ITA 107/BIL/2016[2011-12]Status: DisposedITAT Raipur27 Mar 2023AY 2011-12

For Appellant: Shri Kapil Hirani, Adv. & MukeshFor Respondent: Shri Debashis Lahiri, CIT-DR

Section 115JSection 143(3)Section 250(4)Section 36Section 80ISection 80l

Maruti Mills Private Limited, Balotra vs. ITO, Balotra

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

ITA 91/JODH/2020[2000-01]Status: DisposedITAT Jodhpur23 Mar 2023AY 2000-01

Bench: Shri Kul Bharat & Shri Manish Borad91/Jodh/2020 (Assessment Year- 2000-01) Vs The Ito M/S. Maruti Mills Private Ltd. G-58, Ist Phase, Industrial Balotra Area, Balotra (Appellant) (Respondent) Pan No. Aalcm 1247 M

Section 131(3)

page 3 of the assessment order and thus made addition of Rs.30,79,671/- to the total income of the assessee.’’ In first appeal, the ld CIT(A) observed that the assessee had himself shown GP 29.25% and 25% in the A.Y. 1998-99 and 1999-2000. Thus considering

Mithila Drugs Pvt. Ltd., Udaipur vs. ACIT, Circle-1, Udaipur

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

ITA 566/JODH/2018[2015-16]Status: DisposedITAT Jodhpur23 Mar 2023AY 2015-16

Bench: Shri Kul Bharatshri Manish Boradmithila Drugs Pvt.Ltd., Vs Acit, F-70, Road No.2, Circle-1, 102A, Mewar Industrial Area, Aaykar Bhawan, Sub Madri, Udaipur-313003. City Centre, Savina, Udaipur-313001. (Appellant) (Respondent) Pan No.Aaccm6767B Assessee By None (W/S) Revenue By Shri S.M.Joshi, Jcit Dr Date Of Hearing 22/03/2023 Date Of 23/03/2023 Pronouncement

Section 119(2)(b)Section 139(1)Section 143(3)Section 80

paper book were submitted before the below authorities. Whereas these are being firstly submitted before your honour as was not possessed till the first appeal proceeding. Pleader for the humble appellant.” 9. The Revenue has not disputed the fact that the business loss was not allowed to be carried forward

Dura Line India Private Limited, Bangalore vs. ACIT Circle-7(2), New Delhi

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

ITA 1757/DEL/2020[2016-17]Status: DisposedITAT Delhi23 Mar 2023AY 2016-17

Bench: Shri Shamim Yahya & Shri C.M. Gargassessment Year: 2016-17 Dura Line India Private Ltd., Vs. Acit, 7Th Floor, Tower Neil, Circle-7(2), Neil Rao Towers, Road No.3, New Delhi. Epip Phase I, Whitefield, Bangalore – 560 066. Pan: Aabcd4024B (Appellant) (Respondent) Assessee By : Ms Preeti Goel, Ar Revenue By : Shri Pankaj Khanna, Sr. Dr Date Of Hearing : 27.02.2023 Date Of Pronouncement : 23.03.2023 Order Per C.M. Garg, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 04.02.2020 Of The Cit(A)-3, New Delhi, Relating To Assessment Year 2016-17. 2. Apropos Ground No.1, The Ld. Assessee’S Representative Submitted That The Order Of The Ld.Cit(A) Has Been Passed On Incorrect Interpretation Of Law & Facts & By Wrongly Stating That The Assessee Had Not Complied With The Notice Dated 10Th January, 2020. The Ld. Ar, Drawing Our Attention To The First Appellate Order, Submitted That The Ld.Cit(A) Has Dismissed The Appeal Of The Assessee On The Allegation Of Non-Prosecution Of Appeal Without Adjudicating The Grounds Of The Assessee Raised In Form No.35 Of The First Appeal Keeping Aside The Submissions & Explanation Of The Assessee. Therefore, The Ld. Ar Submitted That The Assessee Was Not Provided Due Opportunity Of Hearing Before The Ld.Cit(A) & The Impugned First Appellate Order Has Been Passed In Violation Of Principles Of Natural Justice.

For Appellant: Ms Preeti Goel, ARFor Respondent: Shri Pankaj Khanna, Sr. DR

Section 250

assessee on the allegation of non-prosecution of appeal without adjudicating the grounds of the assessee raised in Form No.35 of the first appeal keeping aside the submissions and explanation of the assessee. Therefore, the ld. AR submitted that the assessee was not provided due opportunity of hearing before

M.P.Vidhyut Mandal Karamchari Sahkarisakh Sansthan Ltd, Indore vs. The ACIT 4(1), Indore

ITA 349/IND/2022[2014-15]Status: DisposedITAT Indore23 Mar 2023AY 2014-15

Bench: Ms. Suchitra Kamble & Shri B.M. Biyani(Conducted Through Virtual Court) Assessment Year: 2014-15 M.P. Vidhyut Mandal Acit, 4(1) Karamchari Sahkarisakh Indore बनाम/ Sansthan Ltd. Vs. Indore (Appellant / Assessee) (Respondent / Revenue) Pan: Aaaam 0580 C Assessee By Shri Vijay Bansal, Ar Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 15.03.2023 Date Of Pronouncement 23.03.2023 आदेश / O R D E R

Section 143(3)Section 250(6)

आयकर अपीलीय अिधकरण, इंदौर "ायपीठ, इंदौर IN THE INCOME TAX APPELLATE TRIBUNAL INDORE BENCH, INDORE BEFORE MS. SUCHITRA KAMBLE, JUDICIAL

Lalit Johari, Jodhpur vs. ACIT, Central Circle-2, Jodhpur

In the result, the appeal of the assessee is allowed

ITA 40/JODH/2019[2014-15]Status: DisposedITAT Jodhpur22 Mar 2023AY 2014-15

Bench: Shri Kul Bharat & Shri Manish Borad40/Jodh/2019 (Assessment Year- 2014-15) Vs The Acit Shri Lalit Johri 65-A, Bank Colony, Rai Central Circle-2 Ka Bagh, Jodhpur Jodhpur (Appellant) (Respondent) Pan No. Agfpj 5542 H

Section 1Section 139(1)Section 143Section 143(1)Section 144Section 147Section 148Section 153ASection 154Section 234A

passed on 31-102017 wherein interest u/s 234A was levied for the period 3-09-2014 till 12-03-2015. 2.2 In first appeal, the ld. CIT(A) confirmed the levy of interest of Rs.7,83,201/- u/s. 234A of the Act by observing as under:- ‘’6. I have considered

Udaipur Sahakari Uphokta Thok Bhandar Ltd., Udaipur vs. ACIT, Circle-2, Udaipur

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

ITA 441/JODH/2018[2014-15]Status: DisposedITAT Jodhpur22 Mar 2023AY 2014-15

Bench: Shri Kul Bharat & Shri Manish Borad441/Jodh/2018 (Assessment Year- 2014-15) Udaipur Sahakari Upbhokta Vs The Acit Thok Bhandar Ltd. Circle-2 Ist Floor, Shastri Circle, Uddaipur Udaipur (Appellant) (Respondent) Pan No. Aaaau 0159 K

Section 143(2)Section 36(1)(iii)

disallowed claim of interest of Rs.4,52,908/-. 4 UDAIPUR SAHAKARI UPBHOKTA THOK BHANDAR LTD VS ACIT, CIRCLE-2, UDAIPUR 2.2 In first appeal, the ld. CIT(A), partly disallowed interest of Rs.4,33,408/- by observing as under:- ‘’10 I have considered the submission of the appellant ... project and the assessee has not complied with the conditions of the loan for the purpose it was sanctioned by the ICDP which in first appeal was reduced to Rs.4,33,408 by the ld. CIT(A) by holding as under:-. ‘’…Thus, as per the above proviso to section

Shri Shashikant Bhagvanjibhai Rajpara, Rajkot vs. The Pr. CIT-1, Rajkot

In the result, the appeal of the assessee is allowed

ITA 59/RJT/2022[2017-18]Status: DisposedITAT Rajkot22 Mar 2023AY 2017-18

Bench: Smt.Annapurna Gupta & Shri T.R. Senthil Kumarassessment Year :2017-18 Shashikant Bhavajjibhai Rajpara Vs. The Pr.Cit-1 409, Aadarsh Plaza, Rajkot. 150 Ft. Ring Road Rajkot. Pan : Abipr 9935 Q अपीलाथ"/ (Appellant) "" यथ"/(Respondent) Assessee By : Shri D.M. Rindani, Ld.Ar Revenue By : Shri Shramdeep Sinha, Ld.Cit(Dr) सुनवाई क" तार"ख/Date Of Hearing : 13/03/2023 घोषणा क" तार"ख /Date Of Pronouncement: 22/03/2023 आदेश/O R D E R Per Annapurna Guptapresent Appeal Has Been Filed By The Assessee Against Order Passed By The Ld.Pr.Commissioner Of Income Tax-I, Rajkot [Hereinafter Referred To As “Ld.Pr.Cit Under Section 263 Of The Income Tax Act, 1961 ("The Act" For Short) Dated 7.2.2022 Pertaining To The Asst.Year2017-18. 2. The Grounds Raised By The Assessee In Appeal Are As Under: “1. The Learned Principal Commissioner Of Income-Tax - Rajkot -1, Rajkot Erred In Assuming Jurisdiction U/S 263 Of The Act, Particularly In The Light Of Reasons Stated By Him In The Show Cause Notice & In The Order Passed U/S 263 Of The Act & Hence The Impugned Order Is Bad In Law. 2. The Learned Principal Commissioner Of Income-Tax, Rajkot - 1, Rajkot Erred In Setting Aside The Assessment Order Framed U/S 143(3)Of The Act By Holding That The Ao Has Not Properly Examined The Facts Of The Case In 2

For Appellant: Shri D.M. Rindani, ld.ARFor Respondent: Shri Shramdeep Sinha, Ld.CIT(DR)

Section 115BSection 143Section 143(3)Section 263Section 69C

assessment proceedings u/s 143(3) of the Act, 3. The learned Principal Commissioner of Income-tax, Rajkot - 1, Rajkot failed to appreciate that the first appeal of the Appellant against addition made in the assessment order on impugned issues were pending before the Commissioner (Appeals) and therefore the order

Sarita Jain, Jaipur vs. ITO, WD-1(1), Jaipur

In the result, appeal of the assessee is dismissed

ITA 403/JPR/2022[2014-15]Status: FixedITAT Jaipur22 Mar 2023AY 2014-15

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Sh. Ashok Kanodia (CA)For Respondent: Sh. James Kurian (CIT)

Section 143(3)Section 253(3)Section 5

impugned order is set aside. Consequently, the application for condonation of delay filed in the High Court would stand rejected and the miscellaneous first appeal shall stand dismissed as barred by time. No costs.’ 12. Based on these detailed observations we are of the considered view that the assessee failed

The Assistant Commr. of Income Tax, Junagadh Circle, Junagadh vs. M/S Shanti Structure P. Ltd., Junagadh

In the result, the appeal of the Department is dismissed

ITA 281/RJT/2017[2013-14]Status: DisposedITAT Rajkot21 Mar 2023AY 2013-14

Bench: Or During The Proceedings Before The Hon'Ble Itat.

For Appellant: Shri Vipul Dattani, A.RFor Respondent: Shri B.D. Gupta, Sr. D.R

Section 145(3)Section 250Section 44A

wherein also the books of accounts were rejected and income of the assessee was estimated by the AO on identical contentions. In the first appeal for all the said three years before CIT(Appeals), it was held by his predecessor CIT(A) that rejection of books of accounts was improper

M/S Panchsheel Colonizers Private Limited, Jaipur vs. Income Tax Oifficer, Jaipur

In the result, appeal of the assessee is allowed

ITA 7/JPR/2023[2015-2016]Status: DisposedITAT Jaipur21 Mar 2023AY 2015-2016

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Manish Agarwal (C.A.)For Respondent: Smt Monisha Chaudhary (Addl. CIT) a

Section 142(1)Section 143(2)Section 143(3)Section 249(2)

submitted that similar action was taken by ld. AO for Assessment Year 2007-08, 2009-10 and 2010-11 also, wherein in first appeal, the treatment as done by assessee was allowed by Ld. CIT(A) and such orders have been affirmed by Hon'ble ITAT vide order dated

Devraj Beharnani, Jodhpur vs. ACIT, C-3, Jodhpur/ CPC, Bengaluru, Jodhpur

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

ITA 149/JODH/2022[2020-21]Status: DisposedITAT Jodhpur20 Mar 2023AY 2020-21

Bench: Shri Kul Bharat & Shri Manish Borad149/Jodh/2022 (Assessment Year- 2020-21) Shri Devraj Beharnani Vs The Acit Atmaram Building Circle-3 Outside Sojati Gate Jodhpur Jodhpur (Appellant) (Respondent) Pan No. Adtpb 0305 M

Section 143(1)Section 36(1)Section 36(1)(va)Section 43B

ACIT, CIRCLE-3, JODHPUR income of during the course of assessment proceedings u/s 143(1) of the Act by the AO. 2.3 In first appeal, the ld. CIT(A) has dismissed the appeal of the assessee by observing as under:- ‘’5.29 From the above judicial decisions and also the unambiguous

Rajkumar Meena, Jaipur vs. Income Tax Officer, Jaipur

In the result, the appeal of the assessee is allowed

ITA 251/JPR/2022[2015-16]Status: DisposedITAT Jaipur20 Mar 2023AY 2015-16

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Manish Agarwal (C.A.)For Respondent: Ms Monisha Chaudhary (JCIT)

Section 148Section 271(1)(c)Section 69ASection 69C

Addl:- Unexplained expenditure u/s 69C Rs. 7,48,900/- Total taxable income Rs. 20,32,240/- 5. In first appeal the ld. CIT(A) who confirmed the disallowance made by AO by observing as under:- “ 5.1.1 I have considered the submission of the assesse and given a careful thought

Globus Construction Private Limited, Noida vs. DCIT Circle-1, Ghaziabad

In the result appeal of assessee is allowed for statistical purposes

ITA 1414/DEL/2020[2015-16]Status: DisposedITAT Delhi17 Mar 2023AY 2015-16

Bench: Shri Chandra Mohan Garg & Shri Pradip Kumar Kediaassessment Year: 2015-16 Globus Construction P. Ltd. The Dcit, Circle 1, C/O The 3C Company, Tech Ghaziabad Boulevard, Central Block, Vs. Plot No-6, Sec-127, Noida, Up 201301 Pan Aaecg 8128 L (Appellant) (Respondent) For Assessee : Shri Rohit Tiwari, Advocate For Revenue : Shri T. James Singson, Cit-Dr

For Appellant: Shri Rohit Tiwari, AdvocateFor Respondent: Shri T. James Singson, CIT-DR

Section 139Section 143(3)Section 249

counsel submitted that the matter may kindly be restored to the file of Ld. Page 3 of 4 CIT(A) for proper adjudication of first appeal after considering the correct and relevant facts. 3. Replying to the above the learned CIT(DR) submitted that there was gross negligence ... influenced with the earlier first appellate order and after being satisfied about the compliance of assessee pertaining to relevant provisions of filing of first appeal including compliance of sub section (4)of section 249 of the Act. 5. In the result appeal of assessee is allowed for statistical purposes. Order

P M Nargunam, Ghaziabad vs. ACIT Central Circle-6, New Delhi

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

ITA 304/DEL/2020[2014-15]Status: DisposedITAT Delhi16 Mar 2023AY 2014-15

Bench: Shri Pradip Kumar Kedia & Shri Yogesh Kumar U.S.I.T.A. No. 304/Del/2020 (A.Y 2014-15) बनाम P M Nargunam, Acit No. 1, Santosh Nagar, Vs. Central Circle-6, Pratap Vihar, New Delhi. Ghaziabad, Uttar Pradesh. Pan No. Aaepn9976E अपीलाथ" Appellant ""यथ"/Respondent

Section 131Section 68

drawn by AO to make addition ofRs 185,00,000 which is impugned here before us. In first appeal, before Ld CIT(A) confirmed the order of the AO has rejected assessee’s detailed submissions challenging reopening action u/s 148 of the Act and while confirming the addition made

Mr. Jagmohan Singh, New Delhi vs. ACIT, New Delhi

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

ITA 559/DEL/2016[2011-12]Status: DisposedITAT Delhi16 Mar 2023AY 2011-12

Bench: Shri Anil Chaturvedi & Shri Narender Kumar Choudhry[Assessment Year: 2011-12

Section 250Section 271Section 271(1)(c)Section 274

addition of Rs.23,37,500/-. 3. The Assessee being aggrieved by the penalty order dated 26.09.2014 passed by the Assessing Officer, preferred first appeal before the learned Commissioner, who by impugned order dated 03.12.2015 dismissed the appeal of the Assessee. 4. Being aggrieved with the impugned order, the Assessee

Kusum Agarwal, Ajmer vs. ITO Ward 2(1), Ajmer

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

ITA 58/JPR/2022[2012-13]Status: DisposedITAT Jaipur14 Mar 2023AY 2012-13

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Devang Gargieya (Adv.)For Respondent: Ms Monisha Choudhary(Addl.CIT)

Section 143(3)Section 147Section 148Section 234A

assessee during the appellate proceedings, without giving an opportunity the case was dismissed in limine. Therefore, the impugned first appeal order passed by the ld. CIT(A)deserves to be set aside and the matter is fit for remand to the file of ld. CIT(A) for a proper adjudication

Pvr Pictures Ltd., New Delhi vs. DCIT, Circle- 19(2), New Delhi

In the result, the appeal of the assessee is allowed

ITA 3843/DEL/2017[2012-13]Status: DisposedITAT Delhi10 Mar 2023AY 2012-13

Bench: Shri Pradip Kumar Kedia & Shri Yogesh Kumar Us

For Appellant: Shri V.K. Garg, Adv. & Shri ParveenFor Respondent: Ms. Beenu, Sr.DR

Section 115JSection 143(3)

determined by the assessee at Rs.1,10,12,730/-. The Assessing Officer computed the tax liability on such book profits accordingly. (ii) In the first appeal, the assessee contended that it is entitled to adjust the book profit by way of brought forward loss or depreciation as per books ... account whichever is less in terms of clause (iii) of Explanation-1 to Section 115JB(2) of the Act. 4. In the first appeal, the assessee reiterated adjustment of carried forward business loss or unabsorbed depreciation whichever is lower, against ‘Book Profit’ for the purposes of Section 115JB

Rafeek, Kerala vs. The Income Tax Officer, Ward-3, Alappuzha

In the result, the appeal filed by the assesee is allowed for statistical purposes and the Stay Application is dismissed

ITA 861/COCH/2022[2017-18]Status: DisposedITAT Cochin08 Mar 2023AY 2017-18

Bench: Shri George George K. & Ms. Padmavathy S. & Sa.No.58/Coch/2022 (Arising Out Of Ita No.861/Coch/2022) (Assessment Year: 2017-18) Rafeek Vs Ito, Ward-3 Kochukaleeckal A.N.Puram Krishnapuram Alappuzha Kappilmekku Kerala-688 011 Alappuzha-690 533 Pan – Akjpr2342F (Appellant) (Respondent) Assessee By: Sri Suresh Varma, Ca Revenue By: Smt. J.M. Jamuna Devi, Sr. Ar Date Of Hearing: 02.03.2023 Date Of Pronouncement: 08 .03.2023 O R D E R Per: George George K., J.M. This Appeal At The Instance Of The Assessee Is Directed Against The Order Of The Cit(A)/Nfac, Delhi Dated 13.09.2021. The Relevant Assessment Year Is 2017-18. The Assessee Also Filed A Stay Application Seeking To Stay The Recovery Of Outstanding Tax Arrears.

For Appellant: Sri Suresh Varma, CAFor Respondent: Smt. J.M. Jamuna Devi, Sr. AR

Section 115BSection 143(3)Section 250Section 44ASection 68Section 69

explained with evidences with respect to deposit of Rs.23,48,500/- 6. It is humbly prayed that the Grounds of appeal pertaining to the first appeal may kindly be considered as part of these grounds of appeal. For these and other grounds that may be urged at the time