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“appeal before the tribunal”

AppealsSection 253Section 25316,033 judgments

The decision most relied on for appeal before the tribunal is CIT v. Multiplan India Ltd. (38 ITD 320), cited in 2,267 judgments on BharatTax.

Leading authorities on appeal before the tribunal

CIT v. Multiplan India Ltd.
38 ITD 320 · 1991 · ITAT
2,267
citing judgments

An appeal before the Income Tax Appellate Tribunal can be dismissed for non-prosecution or treated as unadmitted when the appellant fails to appear, cooperate, or show diligence, in accordance with Rule 19(2) of the Income-tax (Appellate Tribunal) Rules. The law aids the vigilant, not those who sleep on their rights.

Estate of Late Tukojirao Holkar v. CWT
223 ITR 480 · 1997 · High Court
2,040
citing judgments

A court or tribunal is not bound to answer a reference or adjudicate an appeal on its merits if the party at whose instance the proceeding is made fails to appear at the hearing or take necessary steps for its proper conduct.

CIT v. Pruthvi Brokers & Shareholders
349 ITR 336 · 2012 · High Court
956
citing judgments

Appellate authorities can entertain fresh claims or revised computations of income made by an assessee, even if these were not submitted through a revised return of income.

National Thermal Power Co. Ltd. v. CIT
389 ITR 326 · 2016 · High Court
241
citing judgments

An appellate authority can admit and adjudicate additional grounds of appeal if they are legal in nature or go to the root of the matter, even if not raised before lower authorities or filed belatedly.

Commissioner of Income Tax Madras v. Chenniyappa Mudiliar
1 SCC 591 · 1985 · Reported
225
citing judgments

The appellate tribunal must render a proper decision on both facts and law, disposing of an appeal on its merits rather than dismissing it solely due to the appellant's absence. This obligation is derived from Section 33(4) of the Income Tax Act, 1922, and reflects principles of natural justice.

Otters Club v. DIT
392 ITR 244 · 2017 · High Court
202
citing judgments

The Bombay High Court did not approve an order being passed by the Tribunal beyond a period of 90 days.

CIT v. Bharat General Reinsurance Co Ltd.
81 ITR 303 · 1971 · High Court
202
citing judgments

Income received by an assessee for services rendered to an Indian company may not be taxable, particularly when the Revenue does not contest its non-taxability. This principle aligns with CBDT Circular No. 14 of 1955, which has been approved by the Supreme Court.

Shivsagar Veg Restaurant v. ACIT
317 ITR 433 · 2009 · High Court
202
citing judgments

Orders that are inordinately delayed are liable to be recalled and heard afresh, and the Appellate Tribunal President should frame guidelines for timely disposal of appeals.

Judgments citing appeal before the tribunal

Income Tax Officer Ward-1 Pandharpur, Income Tax Office Pandharpur vs. Yashoda Mahila Nagari Sahakari Patsanstha, Mangalwedha District Solapur

ITA 2741/PUN/2024[2022-23]Status: DisposedITAT Pune03 Jun 2025AY 2022-23
Section 143(2)Section 143(3)Section 80PSection 80P(2)(a)Section 80P(2)(d)

relying on various decisions passed by a coordinate bench of this Tribunal. It is this order against which the Revenue is in appeal before the Tribunal. 4. Ld. DR appearing from the side of the Revenue submitted before us that the order passed by Ld. CIT(A)/NFAC is unjustified

Tathwa Educational Society, Hyderabad vs. ITO, Exemption Ward-1(3), Hyderabad

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

ITA 357/HYD/2025[2023-24]Status: HeardITAT Hyderabad03 Jun 2025AY 2023-24

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Appellant: Shri SNSR Chinmai, AdvocateFor Respondent: Shri Narender Kumar Naik
Section 12A

learned CIT(E). 3 ITA.No.357/Hyd./2025 3. Aggrieved by the order of the learned CIT(E), the assessee-society is now in appeal before the Tribunal. 4. Shri SNSR Chinmai, Advocate-Learned Counsel for the Assessee, submitted that, the learned CIT(E) had simply rejected the application

Iiit-H Data I-Hub Foundation, Hyderabad vs. CIT (Exemption), Hyderabad

In the result, all the appeals filed by the assessees are allowed for statistical purposes

ITA 351/HYD/2025[2025-26]Status: DisposedITAT Hyderabad03 Jun 2025AY 2025-26

Bench: Shri Ravish Sood & Shri Madhusudan Sawdiasl.

For Respondent: : Shri B. Bala Krishna, CIT-DR
Section 12ASection 80G

passed the impugned orders rejecting the said applications. Against the impugned orders of the Ld. CIT(E), all the assessees are in appeal before the Tribunal. 3. The Learned Authorised Representatives of the assessees submitted that, the impugned orders passed by the Ld. CIT(E) are non-speaking orders

Sri Lakshmi Narasimha Swamy Seva Sangham, Saipuram vs. CIT (Exempitons), Hyderabad

In the result, all the appeals filed by the assessees are allowed for statistical purposes

ITA 349/HYD/2025[2024-25]Status: DisposedITAT Hyderabad03 Jun 2025AY 2024-25

Bench: Shri Ravish Sood & Shri Madhusudan Sawdiasl.

For Respondent: : Shri B. Bala Krishna, CIT-DR
Section 12ASection 80G

passed the impugned orders rejecting the said applications. Against the impugned orders of the Ld. CIT(E), all the assessees are in appeal before the Tribunal. 3. The Learned Authorised Representatives of the assessees submitted that, the impugned orders passed by the Ld. CIT(E) are non-speaking orders

Sri Kartikeya Gana Sabha Trust, Hyderabad vs. CIT (Exemptions), Hyderabad

In the result, all the appeals filed by the assessees are allowed for statistical purposes

ITA 348/HYD/2025[2025-26]Status: DisposedITAT Hyderabad03 Jun 2025AY 2025-26

Bench: Shri Ravish Sood & Shri Madhusudan Sawdiasl.

For Respondent: : Shri B. Bala Krishna, CIT-DR
Section 12ASection 80G

passed the impugned orders rejecting the said applications. Against the impugned orders of the Ld. CIT(E), all the assessees are in appeal before the Tribunal. 3. The Learned Authorised Representatives of the assessees submitted that, the impugned orders passed by the Ld. CIT(E) are non-speaking orders

Jesus Grace Glory Gospel Ministries, Jangaon vs. CIT (Exemptions), Hyderabad

In the result, all the appeals filed by the assessees are allowed for statistical purposes

ITA 345/HYD/2025[2024-25]Status: DisposedITAT Hyderabad03 Jun 2025AY 2024-25

Bench: Shri Ravish Sood & Shri Madhusudan Sawdiasl.

For Respondent: : Shri B. Bala Krishna, CIT-DR
Section 12ASection 80G

passed the impugned orders rejecting the said applications. Against the impugned orders of the Ld. CIT(E), all the assessees are in appeal before the Tribunal. 3. The Learned Authorised Representatives of the assessees submitted that, the impugned orders passed by the Ld. CIT(E) are non-speaking orders

DCIT., Circle-1(1), Hyderabad vs. Rvr Enterprises (Successful Bidder of M/S Chadalavada Infratech Ltd.), Hyderabad

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

ITA 782/HYD/2024[2017-18]Status: DisposedITAT Hyderabad03 Jun 2025AY 2017-18

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Appellant: CA Satya DinakarFor Respondent: Shri Narender Kumar Naik
Section 143(3)

towards inter- corporate loan. 3 ITA.No.782/Hyd./2024 4. Aggrieved by the order of the learned CIT(A), the Revenue is now in appeal before the Tribunal. 5. Shri Narender Kumar Naik, learned CIT-DR for the Revenue submitted that, the learned CIT(A) erred in deleting the additions made

Sri Lakshmi Kantha Spinners Limited, Hyderabad vs. DCIT, Circle-3(2), Hyderabad

In the result, appeal of the assessee is dismissed

ITA 19/HYD/2024[2012-13]Status: DisposedITAT Hyderabad03 Jun 2025AY 2012-13

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Appellant: -None-For Respondent: Dr. Sachin Kumar, Sr. AR
Section 133(6)Section 143(3)Section 144

ITA.No.19/Hyd./2024 4. Aggrieved by the order of the learned CIT(A), the appellant-company is now in appeal before the Tribunal. 5. None appeared for the appellant-company. We have heard Learned DR and perused the material available on record. Initially notices were sent to the appellant- company

Smh Medical & Educational Trust, Kanchipuram vs. CIT, Exemptions, Chennai

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

ITA 685/CHNY/2025[-]Status: DisposedITAT Chennai03 Jun 2025

Bench: Shri George George Kand Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 685/Chny/2025

For Appellant: Shri J. Saravanan, AdvocateFor Respondent: Ms. E. Pavuna Sundari, CIT
Section 12ASection 12A(1)(ac)

filed petition for condonation of delay. On perusal of the same, we find there is sufficient reason for delay in filing this appeal before the Tribunal. Hence, we condone the delay in filing the appeal and proceed to dispose off the appeal on merits. 3. At the very outset

K864 Murali Chennampatti Primary Agriculture Co-Op Credit Society, Erode vs. Income Tax Officer, Ward 2(1), Erode

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

ITA 681/CHNY/2025[2012-13]Status: DisposedITAT Chennai03 Jun 2025AY 2012-13

Bench: Shri George George Kand Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 681/Chny/2025 िनधा"रण वष"/Assessment Year:2012-13 K864 Murali Chennampatti Primary The Income Tax Officer, Agricultural Co-Op Credit Society, Vs. Ward 2(1), Murali, Murali Post, Erode. Anthiyur Taluk, Erode District – 638 504. Pan: Aabak 3671M (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Ms. A. Vijayalakshmi, Ca (Through Virtual Mode) ""यथ" क" ओर से/Respondent By : Ms. Pryati Sharma, Jcit सुनवाई क" तारीख/Date Of Hearing : 03.06.2025 घोषणा क" तारीख/Date Of Pronouncement : 03.06.2025

For Appellant: Ms. A. Vijayalakshmi, CAFor Respondent: Ms. Pryati Sharma, JCIT
Section 139Section 143(3)Section 148Section 2(16)Section 250Section 271(1)(c)Section 80A(5)Section 80PSection 80P(2)(a)Section 80P(2)(d)

Therefore, the CIT(A) enhanced the income assessed. 5. Aggrieved by the order of the CIT(A), the assessee has filed the present appeal before the Tribunal. The Ld.AR submitted that the AO is not justified in rejecting the claim of deduction u/s.80P

Chandran Saravanan, Salem vs. ITO, Ward-1(8), Salem

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

ITA 661/CHNY/2025[2017-18]Status: DisposedITAT Chennai03 Jun 2025AY 2017-18

Bench: Shri George George Kand Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 661/Chny/2025 िनधा"रण वष"/Assessment Year:2017-18 Shri Chandran Saravanan, The Income Tax Officer, 3/20, Kuthiraikaran Pudur, Vs. Ward 1(8), Banapuram Post, Salem. Mecheri (Via), Salem – 636 451. Pan: Eeops 5129Q (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri N. Arjun Raj, Advocate ""यथ" क" ओर से/Respondent By : Ms. Pryati Sharma, Jcit सुनवाई क" तारीख/Date Of Hearing : 03.06.2025 घोषणा क" तारीख/Date Of Pronouncement : 03.06.2025

For Appellant: Shri N. Arjun Raj, AdvocateFor Respondent: Ms. Pryati Sharma, JCIT
Section 250

Chartered Accountant noticed the order passed by the First Appellate Authority and immediately steps were taken by the assessee to file the appeal before the Tribunal, which has resulted in delay of 520 days. On perusal of the aforesaid reason stated, we are of the view that the assessee cannot

Parveen Gupta, Delhi vs. ACIT, Central Circle-15, Delhi

Appeal is disposed of by remitting the issue to the file of the Ld

ITA 5610/DEL/2024[2021-22]Status: DisposedITAT Delhi03 Jun 2025AY 2021-22

Bench: Ms. Madhumita Roy & Shri Khettra Mohan Royassessment Year: 2021-22

Section 143(3)Section 271ASection 32Section 68

271AAB(1A) (b) of the Income Tax Act.” 3. As per office report there is delay of 35 days in filing the appeal before the Tribunal. The assessee has filed condonation application describing the reasons for delay in filing the appeal. Considering the averments made in the condonation application ... delay in filing the appeal before the Tribunal is condoned and the appeal is taken up for hearing. 4. Ld. Counsel appearing on behalf of the assessee at the outset submitted that the Ld. First Appellate Authority has proceeded with the appeal and finalized the same ex parte

Income Tax Officer, Delhi vs. Gsp Power Systems Pvt. Ltd., Delhi

Accordingly, the appeal fails and is dismissed

ITA 1273/DEL/2024[2018-19]Status: DisposedITAT Delhi03 Jun 2025AY 2018-19

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalassessment Year: 2018-19 Vs. Gsp Power Systems Pvt. Ltd., Income Tax Officer, New Delhi 22, 3Rd Floor, Main Market, Moti Nagar, New Delhi Pan: Aaccg0581H (Appellant) (Respondent) With C.O. No.40/Del/2024 [Arising Out Of Ita No.1273/Del/2024] Assessment Year: 2018-19 Gsp Power Systems Pvt. Vs. Income Tax Officer, Ltd., Ward-10(1), 22, 3Rd Floor, Main Market, New Delhi Moti Nagar, New Delhi Pan: Aaccg0581H (Appellant) (Respondent) Assessee By Dr. Rakesh Gupta, Adv. Sh. Somil Agarwal, Adv. Department By Ms. Suman Malik, Cit(Dr) Date Of Hearing 03.06.2025 Date Of Pronouncement 03.06.2025 Order Per Satbeer Singh Godara, Jm This Revenue’S Appeal Ita No.1273/Del/2024 & Assessee’S Cross Objection C.O. No. 40/Del/2024 For Assessment Year 2018- 19, Arises Against The Commissioner Of Income Tax (Appeals)/National Faceless Appeal Centre [In Short, The “Cit(A)/Nfac”], Delhi’S Din & Order No. Itba/Nfac/S/250/2023-24/1060727888(1), Dated 09.02.2024, Involving Proceedings Under Section 143(3) Of The Income-Tax Act, 1961 (Hereinafter Referred To As ‘The Act’). Heard Both The Parties. Case Files Perused. 2. We Notice At The Outset That The Assessee’S Cross Objection Herein C.O. No. 40/Del/2024 Goes To The Root Of The Matter Since Challenging Validity Of The Impugned Assessment Itself Framed By The Learned Assessing Authority On 31St May, 2021. This Is For The Precise Reason That The Assessee’S Case Was Taken Up For Scrutiny On The Twin Issues Of Non-Furnishing Of Quantitative Details & “Investments/Advances/Loans” Whereas It Ended Up In Adding An Amount Of Rs.12,59,97,711/- As Unexplained Cash Credits Under Section 68/69A Of The Act, Which Stands Deleted In The Lower Appellate Discussion. This Is What Leaves The Revenue & The Assessee Aggrieved Who Have Filed Their Instant Appeal & Cross Objection; Respectively.

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

order dated 14th January, 2019. The assessee being aggrieved by the disallowed portion of the order passed by the CIT(A) preferred appeal before the Tribunal and in the appeal additional ground was raised contending that the action of the CIT(A) in confirming the action of the Assessing Officer

Shrivastava Associates, Raipur vs. Income Tax Officer-3(1), Raipur

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

ITA 283/RPR/2023[2016-17]Status: DisposedITAT Raipur02 Jun 2025AY 2016-17

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.283/Rpr/2023 "नधा"रण वष" /Assessment Year : 2016-17 Shrivastava Associates 8, Shopping Complex, Ring Road No.1 Priyadarshini Nagar, Raipur-492 001 Pan: Abefs6510J .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer-3(1), Raipur (C.G.) ……""यथ" / Respondent

For Appellant: Shri Nikhilesh Begani, AdvocateFor Respondent: Dr. Priyanka Patel, Sr. DR

Pronouncement : 02.06.2025 2 Shrivastava Associates Vs. ITO-3(1), Raipur आदेश / ORDER PER PARTHA SARATHI CHAUDHURY, JM This is the second round of appeal before the Tribunal as the matter has been remanded back by the Hon’ble Jurisdictional High Court vide its order passed in TAXC No.230

Ibrahim Yakub Doba, Surat vs. ITO, Ward-2(2)(2), Surat

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

ITA 337/SRT/2024[2014-15]Status: DisposedITAT Surat02 Jun 2025AY 2014-15

Bench: Shri T. R. Senthil Kumar & Shri Bijayananda Prusethआयकर अपील सं./Ita No.337/Srt/2024 Assessment Year: (2014-15) (Hybrid Hearing) Ibrahim Yakub Doba, Vs. The Ito, 11, Mayat Faliya, Kathor, Surat – Ward - 2(2)(2), 394150 Surat "थायीलेखासं./जीआइआरसं./Pan/Gir No: Bbvpd5652A (अपीलाथ"/Appellant) (""थ" /Respondent) Appellant By Shri P. M. Jagasheth, Ca Respondent By Ms. Neerja Sharma, Sr. Dr Date Of Hearing 06/05/2025 Date Of Pronouncement 02/06/2025

Section 250Section 54BSection 56(2)(vii)

Rs.41,00,208/- u/s 56(2)(vii)(b) of the Act. 5. Aggrieved by the order of CIT(A), the assessee filed appeal before the Tribunal. At the outset, the learned Authorized Representative (ld. AR) of the assessee has requested to admit the following additional grounds of appeal

Tirumalasetty Nagaraju, Guntur vs. The Income-Tax Officer, Ward-1(1), Guntur

In the result, appeal filed by the assessee is allowed for statistical purposes as indicated herein above

ITA 190/VIZ/2025[2013-14]Status: DisposedITAT Visakhapatnam02 Jun 2025AY 2013-14

Bench: Shri V. Durga Rao, Hon’Ble & Shri S Balakrishnan, Hon’Ble(Through Hybrid Hearing) आयकरअपीलसं./I.T.A. No. 190/Viz/2025 (निर्गारण वर्ा/ Assessment Year: 2013-14) Tirumalasetty Nagaraju, V. Income Tax Officer, Guntur. Ward-1(1), Guntur. Pan: Aeupn1070R (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

Section 143(1)Section 143(2)Section 143(3)Section 144Section 263

dismissed the appeal in limine without condoning the delay. Aggrieved by the order of the Ld. CIT(A), the assessee is in appeal before the Tribunal by raising the following grounds of appeal: “1. The order of the Ld. CIT(A) is contrary to the facts and also

Income Tax Officer, Patiala vs. Raj Autos, Patiala

In the result, Cross Objection of the assessee is allowed whereas appeal of the Revenue is dismissed

ITA 829/CHANDI/2024[2016-17]Status: DisposedITAT Chandigarh02 Jun 2025AY 2016-17

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 829/Chd/2024 "नधा"रण वष" / Assessment Year: 2016-17 The Ito, Vs Raj Autos, Patiala. Opp. Bhagat Volkswagen Showroom, Sirhind Byepass Road, Patiala. "थायी लेखा सं./Pan No: Aaner8138F अपीलाथ"/Appellant ""यथ"/Respondent C.O. No. 36/Chd/2024 In आयकर अपील सं./ Ita No. 829/Chd/2024 "नधा"रण वष" / Assessment Year: 2016-17 Raj Autos, Vs The Ito, Ward-5, Opp. Bhagat Volkswagen Showroom, Patiala. Sirhind Byepass Road, Patiala. "थायी लेखा सं./Pan No: Aaner8138F अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Ashwani Kumar, Ca & Ms. Deepali Aggarwal,Ca Revenue By : Smt. Kusum Bansal, Cit,Dr Date Of Hearing : 23.04.2025 Date Of Pronouncement : 02.06.2025 Hybrid Hearing O R D E R Per Raj Pal Yadav, Vp

For Appellant: Shri Ashwani Kumar, CA and Ms. Deepali Aggarwal,CAFor Respondent: Smt. Kusum Bansal, CIT,DR
Section 147Section 148

Hearing : 23.04.2025 Date of Pronouncement : 02.06.2025 HYBRID HEARING O R D E R PER RAJ PAL YADAV, VP The Revenue is in appeal before the Tribunal against the order of ld. CIT(Appeals) dated 21.06.2024 passed for assessment year 2016-17. On receipt of notice in the ITA No.829/CHD/2024

Shreeji Infratech, Vadodara vs. The Pr. CIT-1, Vadodara

ITA 117/AHD/2022[2017-18]Status: DisposedITAT Ahmedabad02 Jun 2025AY 2017-18

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra R. Kamblem/S. Shreeji Infratech, Vs. Pcit, 110, Near Silver Wood Society, Vadodara-1, Opp. Billabong School, Vadodara Nr. Vadsar Bridge, Vadsar, Vadodara-390010 [Pan : Acwfs 1409 F] M/S. Shreeji Infra, Vs. Pcit, 344, 375, Opp. Cm Patel Farm Vadodara-1, House, Nr. Sidheswar Complex, Vadodara Kalali, Vadodara-390012 [Pan : Acrfs 5269 C] (Appellant) .. (Respondent) Appellant By : Shri S.N. Soparkar, Sr. Advocate & Shri Parin Shah, Ar Respondent By: Shri V. Nandakumar, Cit-Dr Date Of Hearing 16.04.2025 Date Of Pronouncement 02.06.2025 O R D E R Per Dr. B.R.R. Kumar, Vice-:-

For Appellant: Shri S.N. Soparkar, Sr. Advocate &For Respondent: Shri V. Nandakumar, CIT-DR
Section 133ASection 142(1)Section 143(3)Section 263Section 269SSection 69A

order u/s 263 of the Act. 6. Aggrieved by the order of the Ld. PCIT, the assessee is now in appeal before the Tribunal. 7. Before us, the Ld. AR supported the order of the Assessing Officer and the Ld. DR supported the order of the Ld. PCIT

Sri Vijayawada Gosamrakshana Trust, Vijayawada vs. CIT (Exemption), Hyderabad

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

ITA 129/HYD/2025[2024-25]Status: DisposedITAT Hyderabad02 Jun 2025AY 2024-25

Bench: Shri Ravish Sood & Shri Madhusudan Sawdia

For Appellant: NoneFor Respondent: : Shri B. Balakrishna, CIT-DR
Section 80G

compliance of the assessee to the final notice. 4. Aggrieved with the order of Ld. CIT(E), the assessee has filed the present appeal before the Tribunal. None appeared on behalf of the assessee. Therefore, we proceed to adjudicate the issue in the absence of assessee after considering the submission

Jitendra Kantilal Shah, Khetwadi Lane, Charni Road, Mumbai vs. ACIT-19(2), Mumbai, Piramal Chamber, Lal Baug, Parel

ITA 350/MUM/2025[2013-14]Status: DisposedITAT Mumbai02 Jun 2025AY 2013-14

Bench: SHRI OM PRAKASH KANT, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Rajkumar SinghFor Respondent: Ms. Kavita P. Kaushik
Section 143(3)Section 250

hereinafter referred to as ‘the Proprietorship’]. In appeal, the CIT(A) confirmed the disallowance. Being aggrieved, the Assessee has not preferred the present appeal before the Tribunal on the grounds reproduced in paragraph 2 above. 4. We have heard both the sides, perused the material on record. 2 Assessment Year