“rule 46A”

AppealsRule 46ARule 46A2,967 judgments

The decision most relied on for rule 46A is CIT v. Divine Leasing & Finance Ltd. (299 ITR 268), cited in 426 judgments on BharatTax.

Leading authorities on rule 46A

CIT v. Divine Leasing & Finance Ltd.

299 ITR 268 · 2008 · High Court

426

citing judgments

The Assessing Officer cannot add share capital or share premium amounts if the assessee provides the identity and creditworthiness of the subscriber and establishes the genuineness of the transaction. The court may admit additional evidence under Rule 46A, such as the PAN identity of the creditor.

CIT v. Jansampark Advertising & Marketing (P.) Ltd.

56 Taxmann.com 286 · 2015 · High Court

196

citing judgments

The Commissioner of Income-tax (Appeals) has an independent statutory obligation to conduct proper inquiries and verify facts, especially when the Assessing Officer has failed to do so. The CIT(A) must ensure effective inquiry is carried out before deleting additions or accepting additional evidence.

Smt. Prabhavati S. Shah v. CIT

231 ITR 1 · 1998 · High Court

186

citing judgments

The first appellate authority must admit additional evidence if it is necessary for determining the true state of affairs and preventing undue hardship or a failure of justice, even without a specific request and particularly when the case falls under Rule 46A(1)(c).

CIT v. Manish Build Well (P) Ltd.

16 Taxmann.com 27 · 2011 · High Court

120

citing judgments

The CIT(A) must strictly comply with Rule 46A of the Income-tax Rules for admitting additional evidence, ensuring all prescribed conditions exist, reasons are recorded, and reasonable opportunity is provided to the Assessing Officer.

CIT v. Nikunj Eximp

216 Taxmann.com 171 · 2013 · High Court

103

citing judgments

The Assessing Officer must consider additional evidence produced before the CIT(A) under Rule 46A and cannot reject it without proper appreciation of the facts, especially when the assessee was prevented by sufficient cause from producing it earlier.

CIT v. Virgin Securities & Credits (P) Ltd.

332 ITR 396 · 2011 · High Court

citing judgments

The Commissioner of Income-tax (Appeals) must admit additional evidence if it is crucial for the proper disposal of the appeal, ensuring substantial justice to the appellant.

CIT v. Manish Buildwell (P) Ltd.

245 CTR 397 · 2011 · High Court

citing judgments

The production of fresh evidence at the appellate stage before the Commissioner (Appeals) is strictly governed by the conditions and procedures laid down in Rule 46A of the Income-tax Rules.

CIT v. Ranjit Kumar Choudhury

288 ITR 179 · 2007 · High Court

citing judgments

The appellate authority must follow Rule 46A of the Income Tax Rules when admitting additional evidence, which includes recording reasons for admission and providing the Assessing Officer an opportunity to verify or refute the evidence. Failure to do so violates principles of natural justice.

Judgments citing rule 46A

ACIT, Circle 1(2), Surat vs. M/S Nya International, Surat

In the result, ground nos

ITA 713/SRT/2018[2013-14]Status: DisposedITAT Surat22 Feb 2023AY 2013-14

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.713/Srt/2018 Assessment Year: (2013-14) (Virtual Court Hearing) The Acit, Circle-1(2), Vs. M/S. Nya International, Surat. Unit No. 360, Plot No. 239, Sez, Gidc, Sachin, Surat. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aahfn1681M (Revenue)/(Assessee) (Assessee)/(Respondent) आयकर अपील सं./Ita No.534/Srt/2019 Assessment Year: (2014-15) The Acit, Circle-1(2), Vs. M/S. Nya International, Surat. Unit No. 360, Plot No. 239, Sez, Gidc, Sachin, Surat. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aahfn1681M (Revenue)/(Assessee) (Assessee)/(Respondent) Shri Rasesh Shah, Ca Assessee By Respondent By Shri H. P. Meena, Cit(Dr) Date Of Hearing 30/12/2022 Date Of Pronouncement 22/02/2023

Section 10ASection 142(1)Section 144Section 68

furnished and therefore the assessing officer made the addition of Rs.7,30;70,996/-. During the appellate proceedings, the assessee submitted additional evidences, under Rule 46A of the IT Rules, before the ld CIT(A). Therefore, ld CIT(A) remitted these additional evidences to the assessing officer for verification

Singh Infrastructures India Pvt Ltd, Gurgaon vs. DCIT-Circle-24(2), New Delhi

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

ITA 2670/DEL/2019[2014-15]Status: DisposedITAT Delhi21 Feb 2023AY 2014-15

Bench: Shri Shamim Yahya & Shri C.M. Gargassessment Year: 2014-15 Singh Infrastructure India Pvt. Ltd., Vs. Dcit, 9, Bougain Villa Marg, Circle-24(2), Dlf Phase-2, New Delhi. Gurgaon, Haryana – 122001. Pan: Aajcs3083M (Appellant) (Respondent) Assessee By : Ms Ayushi Gupta, Ca & Shri Ajay Wadhwa, Advocate Revenue By : Shri Abhishek Kumar, Sr. Dr Date Of Hearing : 28.11.2023 Date Of Pronouncement : 21.02.2023 Order Per C.M. Garg, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 01.02.2019 Of The Cit(A)-8, New Delhi, Relating To Assessment Year 2014-15. 2. The Grounds Of Appeal Taken By The Assessee Read As Under:- “That The Order Of Ld. Cit(A) - 8, Dated 01/02/2019 Is Bad In Law • & On Facts. • That The Ld. Cit(A) Has Erred On Facts & In Law In Sustaining The Addition Of Rs. 2,86,50,000/- Representing Unsecured Loan Creditors U/S 68 Of The Income Tax Act, 1961. • The Ld. Cit(A) Has Erred On Facts & In Law In Holding That The Assessee Has Failed To Discharge The Onus Of Proving Credit-Worthiness Of Lenders. • That The Ld. Cit(A) Has Erred On Facts & In Law By Not Accepting The Application Under Rule 46A For Additional Evidence. • That The Ld. Cit(A) Has Erred On Facts By Stating That The Assessee Has Not Made Any Application U/R 46A For The Admission Of Additional Evidences. The Assessee Had Duly Filed An Application U/R 46A Dated 15/01/2019 For Additional Evidences Along With The Submissions & Other Evidences Which The Ld. Cit(A) Failed To Consider & Thereby Incorrectly Alleged At Pg. 8,1St Para, 3Rd Line That No Application U/R 46A Has Been Filed. • That The Appellant Craves To Amend/Alter/Modify The Grounds Of Appeal And/Or To Raise Additional Grounds Of Appeal.”

For Appellant: Ms Ayushi Gupta, CA &For Respondent: Shri Abhishek Kumar, Sr. DR

Section 68

proving credit-worthiness of lenders. • That the Ld. CIT(A) has erred on facts and in law by not accepting the application under rule 46A for additional evidence. • That the Ld. CIT(A) has erred on facts by stating that the assessee has not made any application u/r 46A ... ld.CIT(A) in para 8 of the first appellate order. However, he did not controvert the fact that the assessee duly filed application under Rule 46A of the Rules dated 15.01.2019 along with the submissions and other evidences wherein the assessee specifically stated that the documents could not be submitted

DCIT, Circle-1(1), Bhubanswar vs. M/S. Grid Corporation of Orissa Limited, Bhubaneswar

In the result, appeal of the revenue stands dismissed

ITA 328/CTK/2019[2012-13]Status: DisposedITAT Cuttack20 Feb 2023AY 2012-13

Bench: Before S/Shri George Mathan, Judicial & Arun Khodpia & Arun Khodpia & Arun Khodpiaassessment Year : 2012-13 Dcit, Dcit, Corporate Circle Corporate Circle - Vs. Grid Corporation Of O Grid Corporation Of Orissa 1(1), Bhubaneswar. 1(1), Bhubaneswar. Ltd., Ltd., Janapath, Janapath, Bhubanesw Bhubaneswar. Pan/Gir No. Pan/Gir No.Aabcg 5398 P (Appellant (Appellant) .. ( Respondent Respondent) Assessee By : S/Shri Ved Jain/P. Venugopal Rao, Ars Ved Jain/P. Venugopal Rao, Ars Revenue By : Shri M.K.Gautam, M.K.Gautam, Cit Dr Date Of Hearing : 20/0 02/2023 Date Of Pronouncement : 20/0 /02/2023 O R D E R Per Bench

For Appellant: S/Shri Ved Jain/P. Venugopal Rao, ARsFor Respondent: Shri M.K.Gautam

Section 201(1)Section 40

merits in the submission of ld CIT DR insofar as the ground raised by the revenue does not contain anything regarding violation of Rule 46A of the I.T.Rules, 1962. This being so, it is noticed that the ld CIT(A) has followed the decision of the Co-ordinate Bench

Ramesh Jethi, New Delhi vs. ITO, Ward-35(3), New Delhi

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

ITA 1115/DEL/2022[2015-16]Status: DisposedITAT Delhi20 Feb 2023AY 2015-16

Bench: The Ld. Cit (A), Assessee Submitted That Custom Duty Paid

For Appellant: NoneFor Respondent: Shri K.K. Mishra, Sr. DR

Section 144Section 69

passed ex-parte Asstt. order. 3. That under the fact & circumstance, Ld. CIT (A) erred in law in not admitting Additional documents/evidences under Rule 46A. 4. That under the fact and circumstance, Ld. A.O. as well as Ld. CIT (A) erred in law in making and sustaining addition of Rs.67

Income Tax Officer (TDS), Kota vs. Zila Parishad, Sawai Madhopur

In the result, appeal of the revenue is dismissed

ITA 16/JPR/2023[2019-20]Status: DisposedITAT Jaipur20 Feb 2023AY 2019-20

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, AM vk;djvihy la-@ITA No.15 /JPR/2023 fu/kZkj.ko"kZ@Assessment Years :2018-19 Income Tax Officer, Kota. cuke Vs. Zila Parishad Sawaimadhopur. LFkk;hys[kk la-@thvkbZvkj la-@PAN/GIR No.: JDHZ00055G vihykFkhZ@Appellant izR;FkhZ@Respondent vk;djvihy la-@ITA No.16 /JPR/2023 fu/kZkj.ko"kZ@Assessment Years : 2019-20 Income Tax Officer(TDS), Kota. cuke Vs. Zila Parishad Sawaimadhopur. LFkk;hys[kk la-@thvkbZvkj la-@PAN/GIR No.: J

For Appellant: Sh. Neeraj Jain (C.A.)For Respondent: Sh. Jadish (JCIT) fu/kZkfjrh dh vksjls@

Section 194ASection 201Section 201(1)

NFAC, Delhi has erred in not allowing the Assessing Officer to examine the additional evidence admitted by him as per provisions under rule 46A(3) of the Income Tax Rules 1962 and t order passed by the CIT (A), NFAC Delhi on this issue is in violation of the rule

Income Tax Officer, Kota vs. Zila Parishad, Sawai Madhopur

In the result, appeal of the revenue is dismissed

ITA 15/JPR/2023[2018-19]Status: DisposedITAT Jaipur20 Feb 2023AY 2018-19

For Appellant: Sh. Neeraj Jain (C.A.)For Respondent: Sh. Jadish (JCIT) fu/kZkfjrh dh vksjls@

Section 194ASection 201Section 201(1)

DCIT, in. Tax. Circle-2(2)(2), New Delhi vs. Hotchand Teckchand Punjabi, New Delhi

In the result, the appeal is dismissed

ITA 1680/DEL/2021[2012-13]Status: PendingITAT Delhi17 Feb 2023AY 2012-13

Bench: Shri G.S. Pannu, Hon’Ble & Shri Saktijit Deyassessment Year: 2012-13 Dcit, Vs. Sh. Hotchand Techchand International Taxation, Punjabi, Circle -2(2)(2), C/O- Nidhi Goyal, Ca, A-3 New Delhi Mod Apartment 61, Vasundhara Enclave, Delhi Pan :Aqupp2417I (Appellant) (Respondent)

Section 133(6)Section 142(1)Section 144Section 147Section 148Section 2Section 295(2)Section 69B

remand report from the assessing officer which is in clear violation of Section 295(2) (mm) of the Income Tax Act, 1961 read with Rule 46A of the Income Tax Rule, 1962. 2. Whether Ld. CIT(A) has inadventently erred in accepting the genuineness of the source of investments ... remand repot from the assessing officers which is in clear violation of Section 295(2) (mm) of the Income Tax Act, 1961 read with Rule 46A of the Income Tax Rules, 1962. 3. As could be seen from the grounds raised, the basic grievance of the Revenue is against admission

Sanjeev Kalia, Kapurthala vs. Income Tax Officer, Ward-2, Phagwara

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

ITA 229/ASR/2018[2009-10]Status: DisposedITAT Amritsar17 Feb 2023AY 2009-10

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

For Appellant: Sh. J. S. Bhasin, AdvFor Respondent: Mrs. Kanchan Garg, Sr. DR

Section 147Section 148Section 19Section 19(1)(b)Section 250(6)

Rs.70.23.565/- with total income of assessee. Aggrieved assessee filed an appeal before the ld. CIT(A) and submitted the documents as additional documents under Rule 46A of the Income Tax Rule, 1962. The remand report was called for but the ld. CIT(A) was not satisfied with the submissions

M/S Bajrang Agrotech(I) Pvt. Ltd, Durg(Cg) vs. The Income Tax Officer, Ward-2(1), Bhilai, Bhilai(Cg)

In the result the appeal of the assessee is allowed in terms of our observations as above for statistical purposes

ITA 43/BIL/2017[2012-13]Status: DisposedITAT Raipur17 Feb 2023AY 2012-13

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अऩीऱ सं./Ita No.43/Rpr/2017 (ननधाारण वषा / Assessment Year :2012-2013) M/S Bajrang Agrotech (I) Pvt. Ltd., Vs Ito-2(1), Bhilai (C.G.) Village Samoda, Dhamdha Road, Durg (C.G.) Pan No. :Aaccb 2444 G (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) ..

For Appellant: Shri S.R.Rao, Advocate & Nilesh Jain, CAFor Respondent: Shri Choudhary N.C.Roy, Sr. DR

Section 143(2)Section 143(3)Section 145Section 68Section 69Section 69C

providing the same to ld. AO, as is visible that during appellate proceedings before the Ld CIT(A), some details were submitted under Rule 46A of the Income Tax Rules, 1962 and now before ITAT under rule 29 of the of Income Tax (Appellate Tribunal) Rules, 1963. Thus, benefit

Shri Milap Hareshkumar Somaiya, Jamnagar vs. The ACIT, Circle-1, Jamnagar

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

ITA 20/RJT/2020[2016-17]Status: DisposedITAT Rajkot17 Feb 2023AY 2016-17

Bench: Shri Waseem Ahmed (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

Section 143(3)Section 24Section 68

before Ld. CIT(A). The Ld. CIT(A) called for Remand Report from the A.O. and partly admitted documents filed by the assessee under Rule 46A namely on house loan interest receipts u/s. 24(b) and 80C deductions and partly allowed the appeal filed by the assessee. However ... follows: “We pray before Your Honour to kindly allow us to request your Honours to consider the additional evidence within the scope of Rule 46A of the IT. Rules to support our argument and bring on record the correct fact relating to grounds of appeal raised in the appeal memo

Peerless Consultancy Services Pvt Ltd, New Delhi vs. ACIT Central Circle-16, New Delhi

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

ITA 9750/DEL/2019[2017-18]Status: DisposedITAT Delhi16 Feb 2023AY 2017-18

Bench: Dr. B. R. R. Kumar & Shri Yogesh Kumar U.S.

Section 69C

creditors are field during the assessment proceedings. During the appellate proceedings before the Ld.CIT(A) the assessee filed confirmation from the creditors as per Rule 46A of the Income Tax Rule, 1962. The Ld.CIT(A) has also called for remand report from the AO who in turn has called information

Peerless Consultancy Services P.Ltd, New Delhi vs. ACIT, Central Circle-16, New Delhi

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

ITA 9748/DEL/2019[2015-16]Status: DisposedITAT Delhi16 Feb 2023AY 2015-16

Bench: Dr. B. R. R. Kumar & Shri Yogesh Kumar U.S.

Section 69C

Serco India Pvt. Ltd., Pune vs. ACIT, Circle-4(1), Gurgaon

In the result, the appeal of the assessee is dismissed

ITA 1187/DEL/2018[2014-15]Status: DisposedITAT Delhi16 Feb 2023AY 2014-15

Bench: Shri Chandra Mohan Garg & Shri Pradip Kumar Kedia

For Appellant: Shri Suraj Bhan Nain, AdvFor Respondent: Shri Kumar Pranav, Sr.DR

Section 115BSection 143(3)Section 271(1)(c)Section 68

loss declared by the Appellant; 2. That the Ld. CIT(A) has erred in not accepting the additional evidences submitted by the appellant under Rule 46A of the Income Tax Rules, 1962. 3. That the Ld. CIT(A) has erred on facts and in law in confirming ... documents in the form of copy of agreements, lease deeds, etc. evidencing bonafides of I.T.A No.1187/Del/2018 8 expenses and urged the CIT(A) under Rule 46A of the Income Tax Rules to admit the fresh evidences which was nonetheless declined. The Ld. Counsel thus vociferously contended that due to existence

ITO3(1), Indore vs. M/S Parametric Trading P Ltd, Mumbai

In the result, Revenue’s appeal is dismissed

ITA 543/IND/2018[11-12]Status: DisposedITAT Indore14 Feb 2023

Bench: Ms. Madhumita Roy & Shri Bhagirath Mal Biyani

For Appellant: Respondent byFor Respondent: Shri Sumit Nema, Sr. Advocate

Section 143(2)Section 143(3)Section 68

hereinafter referred as to ‘the Act’) for Assessment Year 2011- 12. 2. The Revenue has questioned the admission of additional evidence under Rule 46A of IT Rules by the Ld. CIT(A). ITA No. 543/Ind/2018 [ITO vs. M/s. Parametric Trading Pvt. Ltd.] Asst.Year.– 2011-12 - 2 - 3. On this aspect ... both the parties. We do not find any strong submission on behalf of the Revenue on this count of admission of additional evidence under Rule 46A of the IT Rules. Rather the Ld. DR chose to counter the order passed by the Ld. CIT(A) on merit. Hence, this ground

ACIT, Akola Circle, Akola vs. M/S. Shaheen Frozen Foods, Akola

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

ITA 196/NAG/2017[2013-14]Status: DisposedITAT Nagpur13 Feb 2023AY 2013-14

Bench: S.S.Godara & Dr. Dipak P. Ripoteआयकरअपीलसं. / Ita No.196/Nag/2017 िनधा"रणवष" / Assessment Year : 2013-14 The Assistant M/S.Shaheen Frozen Foods, Commissioner Of Income Vs C/O.Syedainuddin Khatib, Tax, Akola Circle, Akola. Syed Pur, Ward No.19, Balapur, Dist.Akola – 444302. Pan: Abtfs 3422 J Appellant/ Revenue Respondent /Assessee

Section 143(3)Section 35A

Copy of Certificate of Maharashtra Pollution Control Board and Director of Industries without giving any opportunity to the Assessing Officer. This is violation of Rule 46A of the Income Tax Rules. 7. On perusal of the copy of the acknowledgment issued by ITA No.196/NAG/2017 for A.Y.2013-14 M/s.Shaheen Frozen Foods ... this case, many of the evidences have been considered by the ld.CIT(A) without giving opportunity to the AO which is violation of Rule 46A. Many facts remained to be verified. Therefore, in the interest of justice, we set-aside the issue of eligibility of the assessee for deduction under

Ram Mehar, Panipat vs. ITO, Ward- 1, Panipat

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

ITA 1147/DEL/2018[2011-12]Status: DisposedITAT Delhi09 Feb 2023AY 2011-12

Bench: Shri Challa Nagendra Prasad & Shri Pradip Kumar Kediaआ.अ.सं/.I.T.A No.1147/Del/2018 िनधा"रणवष"/Assessment Year: 2011-12 बनाम Ram Mehar Ito Vs. C/O R K Gaur, 7/204, Aditya Ward-1, Complex, Community Centre, Panipat Preet Vihar, New Delhi. Pan No. Ajopm0184G अपीलाथ" Appellant ""यथ"/Respondent

Section 148

facts and circumstances of the case and in law learned CIT (A) erred in not appreciating the additional evidence filed under Rule 46A. 5. On the facts and circumstances of the case and in law, order of the AO is bad in law and against the tenets of natural justice

ACIT, New Delhi vs. M/S. Tirupati Buildings & Officers Pvt. Ltd., New Delhi

ITA 2405/DEL/2016[2010-11]Status: DisposedITAT Delhi09 Feb 2023AY 2010-11

Bench: Shri Anil Chaturvedi & Shri Chandra Mohan Gargassessment Year: 2010-11 The Acit, Central M/S. Tirupati Buildings & Circle-18, Jhandewalan, Offices Pvt. Ltd., New Delhi 110055 Vs. Plot No. 3, Dwarka City Centre Sector-10, Dwarka, New Delhi 110017 Pan Aacct7060J (Appellant) (Respondent) For Revenue : Shri Amaresh Singh, Cit Dr For Assessee : Shri Mahavir Singh, Advocate

For Appellant: Shri Mahavir Singh, AdvocateFor Respondent: Shri Amaresh Singh, CIT DR

Section 133(6)Section 250Section 4Section 68

correct. 6. That the commissioner of Income Tax (Appeals) has erred in law and on facts of the case in admitting additional evidences under Rule 46A of Income Tax rules. M/s. Tirupati Buildings & Offices Pvt. Ltd. Page 3 of 58 7. That the commissioner of Income Tax (Appeals) has erred ... assessment order, written submissions of the appellant, remand report of the Assessing Officer, rejoinder of the appellant and also the additional evidences filed under Rule 46A of the Income Tax Rules, 1962 during the course of appellate proceedings. I have also perused the case laws relied upon by appellant company

ACIT, Circle- 26(2), New Delhi vs. Vishal Chain & Jewellery Pvt. Ltd., New Delhi

In the result, the appeal of the Revenue is dismissed

ITA 5542/DEL/2019[2006-07]Status: DisposedITAT Delhi08 Feb 2023AY 2006-07

Bench: N.K. Billaiya & Ms. Astha Chandraasstt. Year: 2006-07

For Appellant: Shri Y P Rawala, CAFor Respondent: Shri Vivek Vardhan, Sr. DR

Section 131Section 143(1)Section 143(3)

with the specific direction from the Hon'ble ITAT to the file of the CIT(A) to provide opportunity to the AO as per Rule 46A, as the CIT(A) has admitted the additional evidences without providing opportunity to the AO. CIT(A) has provided opportunity ... were treated by the Tribunal to be additional evidence which the Ld. CIT(A) had admitted and relied upon without following the mandate of rule 46A of the Income Tax Rules, 1962 which prompted the Tribunal to set aside the matter for decision afresh after providing opportunity of hearing

ACIT, Circle Karnal, Karnal vs. Liberty Shoes Ltd., Karnal

In the result, the appeals of the assessee and the Revenue are partly allowed for statistical purpose

ITA 1979/DEL/2018[2014-15]Status: DisposedITAT Delhi08 Feb 2023AY 2014-15

Bench: Dr. B. R. R. Kumarsh. Yogesh Kumar Us

For Appellant: Sh. Satish Kumar Goel, AdvFor Respondent: Sh. Amit Shukla, Sr. DR

Section 14A

from trading and manufacturing of School Bags by admitting the evidence in the form of the order of Special Commercial Court (ADJ), Gurgaon under Rule 46A of the I.T. Rules without even caring to call for a report from the Assessing officer. ITA Nos. 1235 & 1979/Del/2018 4 Liberty Shoes

Liberty Shoes Ltd., Karnal vs. ACIT, Circle Karnal, Karnal

In the result, the appeals of the assessee and the Revenue are partly allowed for statistical purpose

ITA 1235/DEL/2018[2014-15]Status: DisposedITAT Delhi08 Feb 2023AY 2014-15

Bench: Dr. B. R. R. Kumarsh. Yogesh Kumar Us

For Appellant: Sh. Satish Kumar Goel, AdvFor Respondent: Sh. Amit Shukla, Sr. DR

Section 14A