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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

Srinivasan Venkatasubramanian, Chennai vs. DCIT, Corporate Circle-4(1), Chennai

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

ITA 1175/CHNY/2023[2013-14]Status: DisposedITAT Chennai12 Jun 2024AY 2013-14

Bench: Shri Mahavir Singhand Shri Jagadish

For Appellant: Shri S. Sridhar, Advocate (Erode)For Respondent: Shri P. Sajit Kumar, JCIT
Section 143(3)Section 68

ground that the appellant is the majority share holder and Director of the company viz. Kgeyes Residency Pvt Ltd. Aggrieved, assessee is in appeal before the Tribunal. 6. Before us, the ld.counsel for the assessee Shri S.Sridhar, Advocate (Erode) argued and on the other hand, the ld. Senior DR, Shri

Muthiyah Ramakumarappan, Sivakasi vs. ITO, Ward - 2, Virudhunagar

In the result, the appeal filed by the assessee in ITA

ITA 1112/CHNY/2022[2013-2014]Status: DisposedITAT Chennai12 Jun 2024AY 2013-2014

Bench: Shri Mahavir Singhand Shri S.R. Raghunatha

For Appellant: Shri N. Arjun Raj, AdvocateFor Respondent: Shri N. Sanjay Gandhi, JCIT
Section 143(3)Section 69A

could not correlate the withdrawals. The CIT(A)-NFAC also not accepting the submissions of assessee, confirmed the addition. Aggrieved, assessee is in appeal before the Tribunal. 4. We have heard rival contentions and gone through facts and circumstances of the case. Before us, the ld.counsel for the assessee filed ... withdrawals. As the assessee could not correlate the nexus, the CIT(A)-NFAC also confirmed the action of the AO. Aggrieved, assessee preferred appeal before the Tribunal. 8. We have heard rival contentions and gone through facts and circumstances of the case. We noted that now the assessee has filed

Datta Prakash Waster, Belagavi vs. Income Tax Officer, Ward-1, Bijapur

In the result, the assessee’s appeal is allowed for statistical purposes

ITA 627/BANG/2024[2020-2021]Status: DisposedITAT Bangalore12 Jun 2024AY 2020-2021

Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahuassessment Year : 2020-21

For Appellant: Shri Chethan Chogule, CAFor Respondent: Shri Ganesh R. Gale, Standing Counsel

Apex Court in the case of Collector, Land Acquisition Vs. MST. Katiji and Others (1987) 167 ITR 471, delay in filing the appeal before the Tribunal is condoned. 6. The ld. AR submitted that assessee filed appeal before the CIT(Appeals) which was later on migrated to NFAC and notices

Krishan Gas Agency, Bangalore vs. Assisstant Commissioner of Income Tax, Circle-3 (2)(1), Bangalore

In the result, the appeal filed by assessee stands allowed for 11

ITA 540/BANG/2024[2017-18]Status: DisposedITAT Bangalore12 Jun 2024AY 2017-18

Bench: Shri Chandra Poojari & Shri Keshav Dubeykrishan Gas Agency Acit, Circle - 3(2)(1) No. B-6, Gda Shopping Complex Bmtc Building, 80 Feet Road Mrcr Layout, Vijaya Nagar Vs. 6Th Block, Koramangala Bangalore 560040 Bengaluru 560095 Pan – Aaffk4416P (Appellant) (Respondent) Assessee By: Smt. Suman Lunkar, Ca Revenue By: Shri V. Parithivel, Jcit Date Of Hearing: 07.05.2024 Date Of Pronouncement: 12.06.2024 O R D E R Per: Keshav Dubey, J.M. This Appeal At The Instance Of The Assessee Is Directed Against The Order Of The National Faceless Appeal Centre, Delhi (‘Learned Cit(A)’) Dated 29.01.2024 Vide Din & Order No. Itba/Nfac/S/250/2023-24/1060208638 (1) Passed Under Section 250 Of The Income Tax Act, 1961 (The Act) For The Assessment Year 2017-18. 2. The Assessee Has Raised The Following Grounds Of Appeal: - “1. The Learned Commissioner Of Income-Tax (Appeals) Has Erred In Partially Confirming The Order Passed By The Assessing Officer. The Appellate Order As Passed To The Extent Confirming He Assessment Order Is Bad In Law & Are Required To Be Quashed. 2. Without Prejudice, The Learned Cit(A) Has Erred In Partially Confirming The Addition Made By The Assessing Officer To The Extent

For Appellant: Smt. Suman Lunkar, CAFor Respondent: Shri V. Parithivel, JCIT
Section 115BSection 143(3)Section 234BSection 250Section 68

addition to the tune of Rs.1,53,50,711/- is sustained. Aggrieved by the order of the CIT(A) the assessee is in appeal before the Tribunal. 5. Before us the learned A.R. of the assessee submitted that the learned CIT(A) erred in partially confirming the addition made

Mr. Shivakumar Mahadevaiah, Mysore vs. Income-Tax Officer, Ward-2(3), Mysore

In the result, the appeal of the revenue is dismissed

ITA 518/BANG/2024[2014-15]Status: DisposedITAT Bangalore12 Jun 2024AY 2014-15

Bench: Shri Chandra Poojari (Accountant Member), Shri Keshav Dubey (Judicial Member)

For Appellant: Shri Sukesh Patil, CAFor Respondent: Shri V. Parithivel, JCIT
Section 143(3)Section 250Section 271Section 271(1)(c)Section 274Section 68

penalty u/s. 271(1)(c) and dismiss the appeal.” Aggrieved by the order of the learned CIT(A) the assessee filed the present appeal before the Tribunal. 4 Mr. Shivakumar Mahadevaiah 6. The solitary issue that is raised whether the CIT(A) is justified in confirming the penalty

ITO Ward - 24(1), New Delhi vs. Solitaire Btn Solar Pvt Limited, New Delhi

In the result, the appeal of the Revenue is dismissed

ITA 1416/DEL/2020[2016-17]Status: DisposedITAT Delhi12 Jun 2024AY 2016-17

Bench: Shri Kul Bharat & Shri Pradip Kumar Kedia

For Appellant: Shri Gaurav Jain, AdvocateFor Respondent: Shri Gurpreet Singh, Sr.DR
Section 143(3)Section 250Section 56(2)(viib)

appeal of the appellant is partly allowed.” 5. Aggrieved by the reversal of additions made, the Revenue is in appeal before the Tribunal. 6. We have considered the rival submissions and perused the appellate order and the assessment order. The documents referred to as well as the case laws relied

Chemitech Engineers Pvt Ltd, New Delhi vs. ACIT Circle-6(1), New Delhi

In the result, the appeal of the assessee is allowed

ITA 9074/DEL/2019[2015-16]Status: DisposedITAT Delhi12 Jun 2024AY 2015-16

Bench: Shri Kul Bharat & Shri Pradip Kumar Kedia

For Appellant: Sh. Sanjay Kumar, Chartered AccountantFor Respondent: Ms. Sarita Kumar, CIT-DR
Section 143(3)Section 263Section 56(2)(viib)

consequent taxability under Section 52(2)(viib) of the Act. 6. Aggrieved by the aforesaid action of the Pr.CIT, the assessee is in appeal before the Tribunal. 7. Assailing the supervisory jurisdiction usurped by the Pr.CIT under Section 263 of the Act, the ld. counsel for the assessee broadly submitted

Jaymitra Suna, Sambalpur vs. Income Tax Officer Ward-1, Panvel

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

ITA 820/PUN/2024[2014-15]Status: DisposedITAT Pune11 Jun 2024AY 2014-15

Bench: Shri Inturi Rama Raoआयकर अपील सं. / Ita No.820/Pun/2024 "नधा"रण वष" / Assessment Year : 2014-15

For Appellant: Shri Dinesh NairFor Respondent: Shri Abdesh Kumar Jha
Section 12A(1)(ac)Section 139(1)Section 144Section 147Section 148Section 282(1)

vide impugned order confirmed the action of the AO for non-prosecution. 4. Being aggrieved, the appellant is in appeal before the Tribunal in the present appeal 5. I heard the rival submissions and perused the relevant material on record. At the outset, on going through the orders

Mahatma Gandhi Charitable Medical Trust, Kolhapur vs. The Income Tax Officer, Exemption Ward, Kolhapur

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

ITA 819/PUN/2024[2017-18]Status: DisposedITAT Pune11 Jun 2024AY 2017-18

Bench: Shri Inturi Rama Raoआयकर अपील सं. / Ita No.819/Pun/2024 "नधा"रण वष" / Assessment Year : 2017-18

For Appellant: NoneFor Respondent: Shri Abdesh Kumar Jha
Section 11Section 12ASection 139(1)Section 142(1)Section 144Section 68

action of the AO for non-prosecution without going into the merits of the issue. 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

Chededeepu Srinivas, Hyderabad vs. Income-Tax Officer, Ward-14(3), Hyderabad

In the result, appeal of the assessee is dismissed

ITA 209/HYD/2024[2018-2019]Status: DisposedITAT Hyderabad11 Jun 2024AY 2018-2019

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

For Appellant: Shri Yeshwanth Reddy, AR appeared for Shri Santi Pavan Kumar, ARFor Respondent: Ms. Sheetal Sarin, DR
Section 139(1)Section 234BSection 36Section 37

filing of this appeal is condoned and the appeal is admitted for adjudication. 3. The assessee has raised the following grounds of appeal before the Tribunal: “1. The impugned order of the learned Assessing Officer in so far as it is against the appellant is opposed to law, weight

Income Tax Bar Association Calcutta, Kolkata vs. CIT(Exemption), Kolkata

The appeal of the assessee is allowed

ITA 205/KOL/2024[00]Status: DisposedITAT Kolkata11 Jun 2024

Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Sanjay Awasthi

Section 12ASection 12A(1)Section 80G(5)Section 80G(5)(iii)Section 80G(5)(iv)Section 80G(5)(vi)

hearing: April 16, 2024 Date of pronouncing the order: June 11, 2024 ORDER Per Rajpal Yadav, Vice-President (KZ):- The assessee is in appeal before the Tribunal against the order of ld. Commissioner of Income Tax (Exemption), Kolkata dated 21st December, 2023, vide which application for grant

M/S. Primary Co-Operative Agriculture and Rural Develpment, Shimoga vs. Income Tax Officer, Ward-3, Shimoga

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

ITA 726/BANG/2024[2017-18]Status: DisposedITAT Bangalore11 Jun 2024AY 2017-18

Bench: Shri George George K & Shri Waseem Ahmedr Assessment Year : 2017-18 M/S. Primary Co-Operative Agriculture & Vs. Ito, Rural Development, Ward – 3, Near Raghavendraswamy Mutt, Sagar, Shimoga. Shimoga District – 577 401. Pan : Aaaap 2556 R Appellant Respondent Assessee By : Smt. Sunaiana Bhatia, Ca Revenue By : Shri. Ganesh R Ghale, Standing Counsel For Department. Date Of Hearing : 11.06.2024 Date Of Pronouncement : 11.06.2024

For Appellant: Smt. Sunaiana Bhatia, CAFor Respondent: Shri. Ganesh R Ghale, Standing Counsel for Department
Section 115BSection 144Section 250Section 69ASection 80P

dismissed the appeal of the assessee in limine. 5. Aggrieved by the Order of the CIT(A), assessee has filed the present appeal before the Tribunal. The learned AR has placed on record the medical report of the Manager of the assessee society. It was contended by the learned

Mr. Sonappa Srirama, Bangalore vs. Income Tax Officer, Ward-4(2)(3), Bangalore

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

ITA 647/BANG/2024[2017-18]Status: DisposedITAT Bangalore11 Jun 2024AY 2017-18

Bench: Shri George George K & Shri Waseem Ahmedr Assessment Year : 2017-18 Shri. Sonnappa Srirama, Vs. Ito, No.23, Ground Floor, 8Th Cross, Ward – 4(2)(3), Kaggadaspura, C. V. Raman Nagar Post, Bengaluru. Bengaluru – 560 093. Pan : Cyjps 8049 E Appellant Respondent Assessee By : Shri. Gopi Krishna, Ca Revenue By : Shri. Ganesh R Ghale, Standing Counsel For Department. Date Of Hearing : 11.06.2024 Date Of Pronouncement : 11.06.2024

For Appellant: Shri. Gopi Krishna, CAFor Respondent: Shri. Ganesh R Ghale, Standing Counsel for Department
Section 115BSection 250Section 69A

final opportunity to explain the source of cash deposit. 6. Aggrieved by the Order of the CIT(A), assessee has filed the present appeal before the Tribunal. Assessee has filed a Paper Book enclosing therein the application for admission of additional evidence. The learned AR submitted that additional evidence

Swastika Investmart Limited, Mumbai vs. ACIT-4(2), Mumbai

In the result, the appeal is allowed

ITA 535/MUM/2024[2007-08]Status: DisposedITAT Mumbai11 Jun 2024AY 2007-08

Bench: Ms Padmavathy S, Am & Shri Raj Kumar Chauhan, Jm

For Appellant: Ms. Nisha Lohati-CA & VijayFor Respondent: 06.06.2024
Section 143(3)

Card. The CIT(A) thus sustained the disallowance of depreciation made by the AO. Both the assessee and the revenue went on further appeal before the Tribunal and the Tribunal restored both the appeals by the assessee and the Department back to the CIT(A) since ... sustained the additions made by the AO towards depreciation on BSE Card and also disallowance of depreciation on software. The assessee is in appeal before the Tribunal for the second time contending only the issue of disallowance of depreciation on software. 4 ITA No. 535/ Mum 2024- Swastika Investment

M/S Shivam Construction Co., Panvel vs. Deputy Commissioner of Income Tax, Panvel Circle, Panvel

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

ITA 810/PUN/2024[2009-10]Status: DisposedITAT Pune10 Jun 2024AY 2009-10

Bench: Shri Inturi Rama Raoआयकर अपील सं. / Ita No.810/Pun/2024 "नधा"रण वष" / Assessment Year : 2009-10 M/S. Shivam Construction Co., Vs. Dcit, 5, At Nhavda Phata, Panvel Circle, Midc, Taloja, Panvel – 410 208 Panvel Maharashtra Pan : Aaefm8600L Appellant Respondent

For Appellant: Shri Hari KrishanFor Respondent: Shri Abdesh Kumar Jha
Section 142(1)Section 143(3)Section 144Section 148

/NFAC who vide impugned order confirmed the addition for non-prosecution, accordingly dismissed the appeal. 5. Being aggrieved, the appellant is in appeal before the Tribunal in the present appeal. 6. When the matter was called on Shri Hari Krishan, Authorised Representative had filed the petition seeking adjournment ... circumstances, I am of the considered opinion that there was no sufficient and reasonable cause for delay in filing the appeal before the Tribunal. Therefore, it is not a fit case for condonation of delay and the appeal is dismissed in limine. 9. In the result, the appeal filed

Pmr Warehousing, Hyderabad vs. ITO., Ward-11(1), Hydrabad

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

ITA 356/HYD/2024[2018-2019]Status: DisposedITAT Hyderabad10 Jun 2024AY 2018-2019

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.356/Hyd/2024 (िनधा"रण वष"/Assessment Year: 2018-19) Pmr Wardehousing Vs. Income Tax Officer Hyderabad Ward 11(1) Pan:Aaufp6369H Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri P. Vinod, Advocate राज" व "ारा/Revenue By:: Smt. Sheetal Sarin Dr सुनवाई की तारीख/Date Of Hearing: 06/06/2024 घोषणा की तारीख/Pronouncement: 10/06/2024 आदेश/Order

For Appellant: Shri P. Vinod, AdvocateFor Respondent: : Smt. Sheetal Sarin DR
Section 115BSection 142(1)Section 143(2)Section 271ASection 68

appeal filed by the assessee and upheld the additions so made by the Assessing Officer. 7. Feeling aggrieved, the assessee is in appeal before the Tribunal. 8. The learned Counsel for the assessee submitted that the learned CIT (A) NFAC erred in not considering the pre-requisite for invoking

Zameer Shaik, Adilabad vs. Income Tax Officer, Ward-1, Adilabad

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

ITA 346/HYD/2024[2017-18]Status: DisposedITAT Hyderabad10 Jun 2024AY 2017-18

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.346/Hyd/2024 (िनधा"रण वष"/Assessment Year: 2017-18) Shri Zameer Shaik Vs. Income Tax Officer Adilabad Ward 1 Pan:Gghps6632F Adilabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri A.V. Raghuram, Advocate राज" व "ारा/Revenue By:: Smt. Sheetal Sarin Dr सुनवाई की तारीख/Date Of Hearing: 05/06/2024 घोषणा की तारीख/Pronouncement: 10/06/2024 आदेश/Order

For Appellant: Shri A.V. Raghuram, AdvocateFor Respondent: : Smt. Sheetal Sarin DR
Section 143(2)Section 69A

assessee despite granting ample opportunities to the assessee. 4. Aggrieved with such order of the learned CIT (A) the assessee is in appeal before the Tribunal. 5. The learned Counsel for the assessee submitted that the lower authorities has not followed the principles of natural justice since the notices issued

Sharad Mathur, Hyderabad vs. DCIT., Circle 12(1), Hyderabad

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

ITA 332/HYD/2024[2021-22]Status: DisposedITAT Hyderabad10 Jun 2024AY 2021-22

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdiaआ.अपी.सं /Ita Nos.331 & 332/Hyd/2024 (िनधा"रण वष"/Assessment Years:2019-20 & 2021-22) Shri Sharad Mathur Vs. Dy. C. I. T. Hyderabad Circle 12(2) Pan:Aogpm3520B Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri B.Satyanarayana Murthy,Ca राज" व "ारा/Revenue By:: Smt. Sheetal Sarin, Dr सुनवाई की तारीख/Date Of Hearing: 03/06/2024 घोषणा की तारीख/Pronouncement: /06/2024 आदेश/Order

For Appellant: Shri B.Satyanarayana Murthy,CAFor Respondent: : Smt. Sheetal Sarin, DR
Section 139(1)Section 154Section 90Section 91

done in that manner and in other manner”. 4. Aggrieved with such order of the learned CIT (A) the assessee is in appeal before the Tribunal. 5. The learned Counsel for the assessee referring to page volume of the paper book drew the attention of the Bench to the acknowledgement

Meena Kovoor, Hyderabad vs. Income Tax Officer, Ward 4(1), Hyderabad

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

ITA 223/HYD/2024[2011-12]Status: DisposedITAT Hyderabad10 Jun 2024AY 2011-12

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.223/Hyd/2024 (िनधा"रण वष"/Assessment Year: 2011-12) Meena Kovoor Vs. Income Tax Officer Hyderabad Ward 4(1) Pan:Blhpk5744G Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Kumar Pal Tated, Ca राज" व "ारा/Revenue By:: Smt. Sheetal Sarin, Dr सुनवाई की तारीख/Date Of Hearing: 05/06/2024 घोषणा की तारीख/Pronouncement: 10/06/2024

For Appellant: Shri Kumar Pal Tated, CAFor Respondent: : Smt. Sheetal Sarin, DR
Section 142(1)Section 144Section 156Section 50

granted sufficient opportunities to pursue its appeal. 4. Aggrieved with such order of the learned CIT (A) NFAC, the assessee is in appeal before the Tribunal. 5. The learned Counsel for the assessee submitted that AO ought not to have solely relied on the JDA and two other sale deed

Prasad Nimmagadda, Hyderabad vs. Asst. Commissioner of Income Tax, Central Circle -2(2), Hyderabad

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

ITA 185/HYD/2024[2018-19]Status: DisposedITAT Hyderabad10 Jun 2024AY 2018-19

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.185/Hyd/2024 (िनधा"रण वष"/Assessment Year: 2018-19) Shri Prasad Nimmagadda Vs. Asstt. C. I. T. Hyderabad Central Circle 2(2) Pan:Abkpn3078N Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri K.A. Sai Prasad, Ca राज" व "ारा/Revenue By:: Smt. Sheetal Sarin, Dr सुनवाई की तारीख/Date Of Hearing: 06/06/2024 घोषणा की तारीख/Pronouncement: 10/06/2024 आदेश/Order

For Appellant: Shri K.A. Sai Prasad, CAFor Respondent: : Smt. Sheetal Sarin, DR
Section 143(2)Section 5

return filed for the A.Y 2018-19. 5. Aggrieved with such order of the learned CIT (A) the assessee is in appeal before the Tribunal. Page 3 of 5 ITA No 185 of 2024 Prasad Nimmagadda 6. The learned Counsel for the assessee submitted that the Assessing Officer