“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

Ziva Jewellery Private Limited, Mumbai vs. The Assistant Commissioner of Income Tax Circle 3(3)(1) (Earlier 11(3)(2), Mumbai

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

ITA 2625/MUM/2024[2017-18]Status: DisposedITAT Mumbai23 Sept 2024AY 2017-18

Bench: Shri Anikesh Banerjee () & Miss. Padmavathy S. () Ziva Jewellery Private Limited Vs The Assistant Commissioner Of Gems Industries, Plot No.A/30, 2Nd Income-Tax,Circle 3(3)(1) [Earlier Floor, Road No.3, Midc, Andheri East, 11(3)(2), Mumbai Mumabai-400 093 Aayakar Bhavan, M.K. Road Pan : Aaacz2058C Mumbai-400 020 Appellant Respondent

Section 115BSection 115JSection 139Section 143(3)Section 145(3)Section 250Section 68

which did not find favour with the ld.CIT(A), who dismissed the appeal. Further aggrieved, the assessee has filed appeal before the Tribunal. 4. The ld.AR filed a written submission which is kept in record. The ld.AR has demonstrated that the cash was deposited during the demonetization period in Axis

Haldex Anand India Private Limited, Nashik vs. National Faceless Assessment Centre, Delhi

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

ITA 638/PUN/2024[2018-19]Status: DisposedITAT Pune20 Sept 2024AY 2018-19

Bench: Shri R.K. Panda & Ms. Astha Chandra

For Appellant: Shri R.D. OnkarFor Respondent: Shri Ramnath P. Murkunde

Section 115PSection 143Section 143(1)Section 143(2)Section 143(3)Section 144BSection 40A(2)(b)

account of failure on the part of the assessee in submitting the requisite details to substantiate its case. 5. Dissatisfied, the assessee in appeal before the Tribunal. 6. The ld. AR submitted that there was no intentional non-compliance of notice(s) issued by the Ld. CIT(A). He placed

Shri Gajanan Gramin Bigar Sheti Sahakari Patsanstha Maryadit Ajara, Kolhapur vs. ITO Ward 1(1), Kolhapur

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

ITA 1190/PUN/2024[2018-19]Status: DisposedITAT Pune20 Sept 2024AY 2018-19

Bench: Shri R. K. Panda & Ms Astha Chandraassessment Year : 2018-19

For Appellant: NoneFor Respondent: Shri Ramnath P Murkunde

Section 143(3)Section 270ASection 80P

NFAC dismissed the appeal filed by the assessee. 6. Aggrieved with such order of the CIT(A) / NFAC, the assessee is in appeal before the Tribunal. 7. The Ld. DR at the time of hearing filed a copy of the order of the Tribunal in assessee’s own case

Shrikrupa Nagari Sahakari Pathsanstha Maryadit, Alibaug vs. Income Tax Ward 3 Panvel, Panvel

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

ITA 1089/PUN/2024[2020-21]Status: DisposedITAT Pune20 Sept 2024AY 2020-21

Bench: Shri R. K. Panda & Shri S.S. Godaraassessment Year : 2020-21

For Appellant: Shri Ronak H. JainFor Respondent: Shri Arvind Desai, Addl CIT, DR

Section 143(3)Section 80PSection 80P(2)(a)Section 80P(2)(d)

merely making a deposit in Cooperative Banks/Commercial Banks.” 5. Aggrieved with such order of the CIT(A) / NFAC, the assessee is in appeal before the Tribunal. 6. We have heard the rival arguments made by both the sides, perused the orders of the Assessing Officer

Shubhlaxmi Land Developers, Nagpur vs. Income Tax Officer Ward 4(5), Nagpur

In the result, appeal filed by the assessee is allowed

ITA 362/NAG/2023[2015-16]Status: DisposedITAT Nagpur20 Sept 2024AY 2015-16

Bench: Shri V. Durga Rao

For Appellant: Shri Nilesh Shriram ToshniwalFor Respondent: Shri Abhay Y. Marathe

Section 250Section 43C

year 2015–16. 2. During the course of hearing, the Registry has pointed out a delay of 52 days in filing the present appeal before the Tribunal. While going through the record available before us, I find that the assessee has filed application dated nil for condonation of delay requesting ... fulfilment of the conditions mentioned in subsections 3 and 4 of Section 43CA in the appellant's case.” The assessee being unsuccessful, filed appeal before the Tribunal. 10. The learned A.R. appearing for the assessee submitted before us that there were sale deed registrations of 5 purchasers during

Yogesh Maganlal Chawda, Nagpur vs. ITO Ward 4(4), Nagpur

In the result, appeal filed by the assessee is allowed

ITA 304/NAG/2023[2015-16]Status: DisposedITAT Nagpur20 Sept 2024AY 2015-16

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Smt. Veena AgrawalFor Respondent: Shri Sandeep Salonkhe

Section 147Section 148Section 69

appeal of Appellant is Dismissed.” The assessee being not satisfied with the order so passed by the learned CIT(A), is in appeal before the Tribunal. 5. We have given a thoughtful consideration to the arguments made by the rival parties and perused the material available on record. The learned

Sushila Bhaurao Deshmukh, Amravati vs. Principal Commissioner of Income Tax-1, Nagpur

In the result, appeal filed by the assessee is allowed

ITA 76/NAG/2022[2017-18]Status: DisposedITAT Nagpur20 Sept 2024AY 2017-18

Bench: Shri V. Durgarao & Shrik.M. Roy, Accountant, Member

For Appellant: ShriK.P. DewaniFor Respondent: Shri Sandeep Salunke

Section 143(3)Section 263Section 263(1)Section 54BSection 54E

being heard to the assessee and conducting necessary inquiries.‖ The assessee being aggrieved with the order so passed by the learned PCIT preferred appeal before the Tribunal. 6. Before us, the learned Counsel for the assessee placed on record a detailed Paper Book containing the following documents to buttress

The Karimnagar District Co Operative Central Bank Limited, Karimnagar vs. ITO., Ward-2, Karimnagar

In the result, appeal of the assessee is allowed

ITA 701/HYD/2024[2018-19]Status: DisposedITAT Hyderabad20 Sept 2024AY 2018-19

Bench: Shri Prakash Chand Yadav & Shri Madhusudan Sawdiaआ.अपी.सं / Ita No.701/Hyd/2024 (निर्धारण वर्ा / Assessment Year: 2018-19) The Karimnagar District Cooperative Vs. Income Tax Officer Central Bank Limited Ward-2 Karimnagar Karimnagar [Pan :Aabat0905H] अपीलधर्थी / Appellant प्रत्‍यर्थी / Respondent निर्धाररती द्वधरध/Assessee By: Shri P.Murali Mohan Rao, Ar रधजस्‍व द्वधरध/Revenue By: Shri Ranjan Agarwala, Dr

For Appellant: Shri P.Murali Mohan Rao, ARFor Respondent: Shri Ranjan Agarwala, DR

Section 270A

Ld.CIT(A)”) dated 10.05.2024 and relates to assessment year 2018-19. 2. There is a delay of 14 days in filing the present appeal before the Tribunal. Explaining the reasons for the delay, the learned counsel for the assessee pointed out that the Principal Officer, who is the authorized signatory

Chundi Sukumar Reddy, Hyderabad vs. ITO(International Taxation)-1, Hyderabad

In the result, appeal filed by the assessee is allowed

ITA 132/HYD/2024[2015-16]Status: DisposedITAT Hyderabad20 Sept 2024AY 2015-16

Bench: Shri Manjunatha, G. & Shri Prakash Chand Yadavआ.अपी.सं /Ita No.132/Hyd/2024 (िनधा"रण वष"/Assessment Year: 2015-16) Shri Chundi Sukumar Vs. Income Tax Officer Reddy (International Taxation)-1 Hyderabad Hyderabad Pan:Bnqpc2445F (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri P Murali Mohan Rao, Ca राज" व "ारा/Revenue By:: Shri B. Balakrishna, Dr सुनवाई की तारीख/Date Of Hearing: 18/09/2024 घोषणा की तारीख/Pronouncement: 20/09/2024 आदेश/Order

For Appellant: Shri P Murali Mohan Rao, CAFor Respondent: : Shri B. Balakrishna, DR

Section 139(1)Section 144C(1)Section 144C(5)Section 147Section 148Section 153(2)

31/01/2024 and determined the total income at Rs.34,21,060/-. 5. Aggrieved by the final assessment order, the assessee is in appeal before the Tribunal. 6. The learned Counsel for the assessee submitted that this issue is squarely covered in favour of the assessee by the decision of the ITAT

DCIT, Central Circle-3(1), Hyderabad vs. Varsity Education Management Pvt Ltd, Mumbai

In the result, appeal filed by the Revenue is dismissed

ITA 208/HYD/2023[2011-12]Status: DisposedITAT Hyderabad20 Sept 2024AY 2011-12

Bench: Shri Manjunatha, G. & Shri Prakash Chand Yadavआ.अपी.सं /Ita No. 208/Hyd/2023 (िनधा"रण वष"/Assessment Year: 2011-12) Deputy Commissioner Of Vs. Varsity Education Income Tax, Central Circle Management (P) Ltd 3(1) Hyderabad Hyderabad Pan:Aadcv6100E (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Advocate A.V. Raghuram राज" व "ारा/Revenue By:: Shri B. Balakrishna, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 18/09/2024 घोषणा की तारीख/Pronouncement: 20/09/2024 आदेश/Order

For Appellant: Advocate A.V. RaghuramFor Respondent: : Shri B. Balakrishna, CIT(DR)

Section 271(1)(c)Section 274Section 68

deleted the addition made by the Assessing Officer towards share premium u/s 68 of the I.T. Act, 1961. 5. The Revenue preferred further appeal before the Tribunal, against the order of the learned CIT (A) and the ITAT ‘F’ Bench of the Mumbai Benches in ITA No.6991/Mum/2016 dated 24.10.2018 reversed ... Being aggrieved by the order of the learned CIT (A), the Revenue is in appeal before the Tribunal. 10. The learned DR, submitted that the learned CIT (A) is erred in deleting penalty u/s 271(1)(c) of the Act, without appreciating the fact that the assessee has furnished inaccurate

Assistant Commissioner of Income Tax Ncc3(1) Chennai, Nungambakkam vs. Shri Venkatesh Meghraj Kathare, Alwarpet

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

ITA 974/CHNY/2024[2014-15]Status: DisposedITAT Chennai20 Sept 2024AY 2014-15

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwalआयकर अपील सं./Ita No.:974/Chny/2024 िनधा"रण वष"/Assessment Year:2014-15 The Assistant Commissioner Shri Venkatesh Meghraj Kathare, Of Income Tax, Vs. New No.205, Old No.128, Non-Corporate Circle 3(1), St. Mary Road, Chennai. Chennai – 600 018. Pan: Aadpk 5251E (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Ms. R. Anita, Addl.Cit ""यथ" क" ओर से/Respondent By : Shri G. Seetharaman, C.A. सुनवाई क" तारीख/Date Of Hearing : 18.09.2024 घोषणा क" तारीख/Date Of Pronouncement : 20.09.2024 आदेश /O R D E R Per Mahavir Singh: This Appeal By The Revenue Is Arising Out Of The Order Of The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre In Order No.Itba/Nfac/S/250/2023-24/1061041943(1) Dated 16.02.2024. The Assessment Was Framed By The Assistant Commissioner Of Income-Tax, Non-Corporate Circle 3, Chennai For The Assessment Year 2014-15 U/S. 143(3) Of The Income Tax Act, 1961 (Hereinafter The ‘Act’) Vide Order Dated 30.12.2016. 2. The First Issue In This Appeal Of Revenue Is Against The Order Of Cit(A) Treating The Sale Of Land At Tiruvottiyur High Road As Long Term Capital Gain As Against Assessed By Ao As Short Term Capital Gain. For This, Revenue Has Raised The Following Grounds:- 1) The Cit(A) Has Erred On The Facts Of The Case In Treating The Capital Gains On Sale Of Land At Tiruvottiyur High Road As Long Term Capital Gain Instead Of Short Term Capital Gain Without Appreciating That :

For Appellant: Ms. R. Anita, Addl.CITFor Respondent: Shri G. Seetharaman, C.A

Section 143(3)Section 2Section 2(47)Section 46(2)

issue is decided in favour of the appellant. According ground nos. 1(ii) and 1(iii) are allowed. Aggrieved, Revenue came in appeal before the Tribunal. 9. We have heard rival contentions and gone through facts and circumstances of the case. We noted that admittedly, the assessee received land

Income Tax Officer, Corporate Ward 2(1), Chennai vs. Electronics Corporation of Tamil Nadu Limited, Chennai

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

ITA 95/CHNY/2024[2016-17]Status: DisposedITAT Chennai20 Sept 2024AY 2016-17

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwalआयकर अपील सं./Ita No.:95/Chny/2024 िनधा"रण वष"/Assessment Year:2016-17 The Income Tax Officer, The Electronics Corporation Of Tamil Nadu Limited, Corporate Ward 2(1), Vs. No.692, Mhu Complex, Chennai. 2Nd Floor, Anna Salai, Nandanam, Chennai – 600 035. Pan: Aaace 1670K (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri R. Clement Ramesh Kumar, Cit ""यथ" क" ओर से/Respondent By : Shri S. Sridhar, Advocate

For Appellant: Shri R. Clement Ramesh Kumar, CITFor Respondent: Shri S. Sridhar, Advocate

Section 143(3)

dated 03.03.2020 and as per Form No.36, the impugned order was communicated to the office of CIT on 12.06.2020. The appeal before the Tribunal was filed on 12.01.2024. The limitation period from 12.06.2020 (the date of communication of impugned order) will start from 11.08.2020 and thereby, there is a delay ... Revenue is generic in nature and particularly that due to inherent and unavoidable administrative delays, this office was unable to file the appeal before the Tribunal, this was the only plea of the revenue. We noted that exactly on similar circumstances, the Hon’ble Supreme Court in the case

Deputy Commissioner of Income Tax, Trichy vs. Dalmia Cement (Bharat) Limited, Trichy

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

ITA 1260/CHNY/2024[2019-20]Status: DisposedITAT Chennai20 Sept 2024AY 2019-20

Bench: SHRI MAHAVIR SINGH (Vice President), SHRI MANOJ KUMAR AGGARWAL (Accountant Member)

For Appellant: Shri R. Clement Ramesh Kumar, CITFor Respondent: Shri Soumen Adak, CA

Section 143(3)Section 153Section 153(1)Section 153(4)Section 92C

valid. As a result, the assessment order in the present case to be treated as barred by time limit. Aggrieved, Revenue is in appeal before the Tribunal. 4. We have heard rival contentions and gone through facts and circumstances of the case. We noted from the arguments of ld.AR

DCIT, CC-2(4), Chennai vs. V.Baskaran, Chennai

In the result, the appeal filed by the assessee in IT(SS)A No

ITA 604/CHNY/2021[2017-18]Status: DisposedITAT Chennai20 Sept 2024AY 2017-18

Bench: Shri Mahavir Singhand Shri S.R. Raghunatha

For Appellant: Shri K. Ravi, AdvocateFor Respondent: Shri A.P. Srinivas, Sr. Standing Counsel

Section 132Section 142(1)Section 143(3)Section 144Section 158B

ground of non-payment of self-assessment tax on admitted liability. The assessee paid the admitted tax on 09.09.1998 and filed an appeal before the Tribunal, which has been numbered as ITA No.160 of 1998. Apart from that on 10.02.2002, the assessee filed miscellaneous application in MP.No ... hands of the assessee for the assessment year 1997-98 falling in the block period. Aggrieved, assessee came in appeal before the Tribunal. IT(SS)A No.3/Chny/2017 & 8. We have heard rival contentions and gone through facts and circumstances of the case. We noted that the assessee before

Jaimin Jewellery Exports Private Limited, Mumbai vs. ACIT-19(2), Mumbai

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

ITA 765/MUM/2024[2008-09]Status: DisposedITAT Mumbai20 Sept 2024AY 2008-09

Bench: Ms. Kavitha Rajagopal, Jm & Ms. Padmavathy S, Am Jaimin Jewellery Exports Private Acit-19(2) Limited Dcit, Circle-5(2)(1), Marine Lines, 52, Marble Arch, 5Th Floor, Mumbai-400 021 Vs. Dr. G. Deshmukh Marg, Pedder Road, Mumbai-400 026

For Appellant: Shri Madhur Agrawal/Fenil BhattFor Respondent: Shri G. J. Ninawe

Section 133ASection 143(1)Section 143(2)Section 143(3)Section 250

time. Furthermore, the ld. AR contended that on receipt of the ld. CIT(A)’s order, the assessee had promptly filed an appeal before the Tribunal pursuant to the said notice. The ld. AR prayed that the delay, if any, shall be condoned. The learned Departmental Representative ... reason and along with the other reasons, the assessee had stated that there was “sufficient cause” for the said delay in filing the appeal before the Tribunal. 10. Upon hearing the rival contentions and on perusal of the materials available on record, it is observed that the Tribunal

The Mangalorean Garden Homes Co Operative Housing Society Limited, Mumbai vs. ITO Ward 23(3)(4), Mumbai

In the result, appeal filed by the assessee is allowed in the above terms

ITA 1696/MUM/2024[2017-18]Status: DisposedITAT Mumbai20 Sept 2024AY 2017-18

Bench: Shri. Amarjit Singh & Shri. Raj Kumar Chauhanthe Mangalorean Garden Homes Vs. Ito Ward 23(3)(4) Co-Operative Housing Society Room No. 119, 1St Floor, Matru Limited Mandir, Tardeo Road, Rebello House, 132, Hill Road, Mumbai – 400007. Bandra (W), Mumbai - 400050. Pan: Aaaat3420G (Appellant) (Respondent)

Section 250Section 80P(2)(d)

Mangalorean Gardens Homes Co-operative Hsg. Soc. Ltd.; A.Y. 2017-18 4. Since there is a delay of 161 days in filing this appeal before the Tribunal, an application for condonation of delay has been filed alongwith supporting affidavit by the appellant society. In the delay condonation application

Latabai Vijay Jadhav, Shahada vs. Income Tax Officer NFAC Delhi, Delhi

In the result, the appeal filed by the assessee stands partly allowed

ITA 1522/PUN/2024[2018-19]Status: DisposedITAT Pune19 Sept 2024AY 2018-19

Bench: Shri Inturi Rama Raoआयकर अपील सं. / Ita No.1522/Pun/2024 "नधा"रण वष" / Assessment Year : 2018-19

For Appellant: NoneFor Respondent: Shri B.S.Rajpurohit

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

dismissed the appeal in limine for non prosecution, without discussing anything on merits of the disallowance. 4. Being aggrieved, the appellant is in appeal before the Tribunal in the present appeal. 5. When the appeal was called on, none appeared on behalf of the appellant despite due service of notice

Maharashtra Swayamrojgar Prashikshan Mandal, Nashik, Maharashtra vs. ITO (Exemption), Ward-1, Nashik

In the result, the appeal filed by the appellant trust stands partly allowed for statistical purposes

ITA 1512/PUN/2024[2015-16]Status: DisposedITAT Pune19 Sept 2024AY 2015-16

Bench: Shri Inturi Rama Raoआयकर अपील सं. / Ita No.1512/Pun/2024 "नधा"रण वष" / Assessment Year : 2015-16

For Appellant: NoneFor Respondent: Shri B.S.Rajpurohit

Section 143(1)Section 143(2)Section 143(3)Section 40A(3)

Virendra Singh Saini, Haryana vs. Asst. Director of Income Tax, CPC, Bangalore, Bengalore

In the result, the appeal filed by the assessee stands partly allowed

ITA 1483/PUN/2024[2019-20]Status: HeardITAT Pune19 Sept 2024AY 2019-20

Bench: Shri Inturi Rama Raoआयकर अपील सं. / Ita No.1483/Pun/2024 "नधा"रण वष" / Assessment Year : 2019-20

For Appellant: NoneFor Respondent: Shri B.S.Rajpurohit

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

thereby, the NFAC confirmed the intimation making adjustment of Employees contribution to ESI and EPF. 4 8. Being aggrieved, the appellant is in appeal before the Tribunal in the present appeal. 9. When the appeal was called on, none appeared on behalf of the appellant despite due service of notice ... thereby, the NFAC confirmed the intimation making adjustment of Employees contribution to ESI and EPF. 4 8. Being aggrieved, the appellant is in appeal before the Tribunal in the present appeal. 9. When the appeal was called on, none appeared on behalf of the appellant despite due service of notice

Ishwar Education and Charitable Trust, Pune vs. ITO, Exemption Ward 1(2), Pune

In the result, the appeal filed by the appellant trust is allowed

ITA 1479/PUN/2024[2015-2016]Status: DisposedITAT Pune19 Sept 2024AY 2015-2016

Bench: Shri Inturi Rama Raoआयकर अपील सं. / Ita No.1479/Pun/2024 "नधा"रण वष" / Assessment Year : 2015-16

For Appellant: Shri S.L. TareFor Respondent: Shri B.S.Rajpurohit

Section 11Section 12Section 12ASection 13Section 13(1)(d)Section 147Section 148ASection 164Section 164(2)Section 2

Association of Persons (AOP) and chargeable to tax at the Maximum Marginal rate of tax. 4. Being aggrieved, the appellant is in appeal before the Tribunal in the present appeal. 5. I heard the rival submissions and perused the material on record. The solitary issue that arises for my consideration