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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

Sri.S.Baskar Sait, Trichur vs. The DCIT, Trichur

In the result, both the appeals are allowed for statistical purposes

ITA 225/COCH/2018[2002-03]Status: DisposedITAT Cochin02 Jan 2023AY 2002-03

Bench: Shri N. V. Vasudevan & Ms. Padmavathy S.

For Appellant: Shri Kittu Nair, AdvocateFor Respondent: Smt. J M Jamuna Devi, Sr. AR
Section 142(1)Section 143(2)Section 143(3)Section 148

upheld the decision of the AO on the ground that no further evidence was produced. Aggrieved, the assessee is in appeal before the Tribunal. 4. The assessee filed the following common grounds :- A. The order of the assessment to the extent objected to herein is illegal, arbitrary and unauthorized

Madresa Himayatul Islam Bachchon Ka Ghar, Bardoli vs. Income Tax Officer, Exemption Ward, Surat

In the result, the grounds of appeal raised by assessee are allowed for statistical purpose

ITA 279/SRT/2022[2017-18]Status: HeardITAT Surat02 Jan 2023AY 2017-18

Bench: Shri Pawan Singh(Physical Hearing) Madresa Himayatul Islam Bachchon Ka I.T.O. Ghar, Exemption Ward, Vs. Ground Floor Bachchon Ka Ghar, Surat. Kadod, Bardoli-394335. Pan No. Aadtm 1802 F Appellant/ Assessee Respondent/ Revenue

Section 115BSection 12ASection 133(6)Section 144Section 249Section 249(4)Section 254(1)Section 69A

returned income. The appeal of assessee was dismissed in limine without adjudicating the issues on merit. Further aggrieved, the assessee has filed this appeal before the Tribunal. 4. I have heard the submissions of learned Authorised Representative (ld. AR) of the assessee and the learned Senior Departmental Representative

Chandrakant Bhagwanji Popat, Surat vs. Dy. Commissioner of Income Tax, Cir. 1(3), Surat

In the result, grounds of appeal raised by the assessee is allowed

ITA 265/SRT/2022[2015-16]Status: HeardITAT Surat02 Jan 2023AY 2015-16

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini(Virtual Hearing) Chandrakant Bhagwanji Popat, D.C.I.T., 54, Dev Deep Society, Circle-1(3), Vs. Ichchhanath Road, Surat. Surat. Pan No. Abnpp 1088 R Appellant/ Assessee Respondent/ Revenue

Section 112Section 250(6)Section 254(1)Section 54F

fact and that it is not a fit case to interfere with the assessment order. Further aggrieved, the assessee has filed the present appeal before the Tribunal. 3 Chandrakant Bhagwanji Popat. Vs DCIT 4. We have heard the submissions of the learned Authorised Representative (ld. AR) of the assessee

Shree Hari Ram Charitable Trust, Surat vs. ITO Exemption, Surat

In the result, the appeal of assessee is treated as dismissed being infructuous

ITA 248/SRT/2022[2016-17]Status: HeardITAT Surat02 Jan 2023AY 2016-17

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini(Physical Hearing) Shree Hari Ram Charitable Trust, I.T.O.(Exemptions), 304, Meghdhanush Complex, Ward-Surat. Vs. Adajan Patia, Adajan Surat, Gujarat, India- 395009. Pan No. Aajts 1057 L Appellant/ Assessee Respondent/ Revenue

Section 10Section 11Section 11(1)(A)Section 12ASection 154Section 254(1)

appeal of assessee was dismissed by the ld. CIT(A) vide order dated 29/07/2022. Further aggrieved, the assessee has filed the present appeal before the Tribunal. 4. We have heard the submissions of the learned Authorised Representative (ld. AR) of the assessee and the learned Commissioner of Income ... survive and may be dismissed as infructuous. 6. We have considered the submission of both the parties and find that after filing present appeal before the Tribunal, the Assessing Officer/ITO(E) has passed the following order under Section 154 dated 05/09/2022: “ Rectification Order In this case, the assessee e-filed

M/S. Ibm India Private Limited, Bangalore vs. Joint Commissioner of Income Tax, Special Range-4, Bangalore

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

ITA 2588/BANG/2019[2006-07]Status: DisposedITAT Bangalore30 Dec 2022AY 2006-07

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Respondent: Shri Percy Pardiwala, Sr

said DAO, the Ld.AO continued to make adjustments in relation to the issues which were not part the subject matter of the original appeal before the Tribunal. 3. Aggrieved by the actions of the Ld.AO/ TPO, the assessee filed objections before the DRP. The DRP upheld the DAO passed ... Ld.AO, and accordingly, the Ld.AO passed the Final Assessment Order on 28/10/2019. 4. Aggrieved by the same, the assessee preferred an appeal before the Tribunal. 4.1 The Ld.AR submitted that under no circumstances should a specific remand by the Tribunal be construed as 'setting aside of the entire transfer pricing

Amrit Breeder Farms Pvt. Ltd., Kolkata vs. A.C.I.T., Circle-11(1), Kolkata

In the result, appeal of the assessee is allowed

ITA 594/KOL/2022[2019-2020]Status: DisposedITAT Kolkata29 Dec 2022AY 2019-2020

Bench: Shri Rajpal Yadav & Shri Girish Agrawalassessment Year: 2019-20

For Appellant: Shri Anil Kochar, AdvocateFor Respondent: Shri P. P. Barman, Addl. CIT
Section 269SSection 271Section 271DSection 274Section 285BSection 44A

assessee preferred an appeal before the Ld. CIT(A), who confirmed the action of the AO. Aggrieved, assessee is in appeal before the Tribunal. 4. Before us, ld. Counsel reiterated the above facts and contentions to submit that penalty imposed is to be deleted. He also strongly submitted by referring

B.E.Billimoria & Company Limited, Mumbai vs. The Dy. Commissioner of Income Tax, Circle-1(1)(1), Mumbai

In the result, the appeal filed by the ass

ITA 2788/MUM/2022[2017-18]Status: DisposedITAT Mumbai29 Dec 2022AY 2017-18

Bench: Shri Aby T Varkey () & Shri Om Prakash Kant () Assessment Year: 2017-18 B.E. Billimoria & Company Ltd., The Dy. Cit, Circle-1(1)(1), Shiv Sagar Estate, Block-A 2Nd Aayakar Bhavan, Maharshi Floor, Dr. A.B. Road, Worli Vs. Karve Road, Mumbai-400018. Mumbai-400020. Pan No. Aaacb 1542 P Appellant Respondent : Assessee By None : Revenue By Mr. Chetan M. Kacha, Dr Date Of Hearing : 26/12/2022 : Date Of Pronouncement 29/12/2022

For Respondent: Assessee by None
Section 139Section 144Section 14ASection 36(1)(va)

Aggrieved, the assessee is in appeal before the disallowance. Aggrieved, the assessee is in appeal before the disallowance. Aggrieved, the assessee is in appeal before the Tribunal raising the grounds as reproduced above. Tribunal raising the grounds as reproduced above. 3. We have heard rival submission of the parties

Dy.CIT 7(1) (1), Mumbai vs. M/S. Mattel Toys (India) Pvt. Ltd, Mumbai

In the result, the appeal of the Revenue is dismissed, whereas,

ITA 2304/MUM/2021[2012-13]Status: DisposedITAT Mumbai29 Dec 2022AY 2012-13

Bench: Shri Vikas Awasthy () & Shri Om Prakash Kant () Assessment Year: 2012-13 Dy. Cit, Circle-7(1)(1), M/S Mattel Toys (India) Pvt. Ltd., Room No. 126, 1St Floor, Phoenix House, B-Wing, 4Th Floor, Vs. Aayakar Bhavan, M.K. Road, 462, Senapati Bapat Marg, Lower Mumbai-400020. Parel, Mumbai-400013. Pan No. Aaccm 2563 P Appellant Respondent

For Respondent: Assessee by Mr. Ketan Ved, AR

Toys (India) Pvt. Ltd. 5 ITA No. 2304/M/2021 & CO No. 124/M/2022 ITA No. 2304/M/2021 & CO No. 124/M/2022 dispute. Aggrieved the Revenue is in appeal before the Tribunal and the Revenue is in appeal before the Tribunal and the Revenue is in appeal before the Tribunal and the assessee

Deputy Commissioner of Income Tax, Central Circle-8(1), Mumbai vs. Raymond Ltd, Mumbai

In the result, appeal filed by the Revenue is dismissed

ITA 4082/MUM/2018[2012-13]Status: DisposedITAT Mumbai28 Dec 2022AY 2012-13

Bench: Shri Amit Shukla, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

For Appellant: Shri Madhur Agrawal &For Respondent: Shri T. Shankar
Section 143(3)Section 14ASection 23Section 40A(2)(b)

said order, the assessee filed an appeal before the Commissioner (Appeals). The Commissioner (Appeals) dismissed the appeal. The assessee thereupon filed second appeal before the Tribunal but the Tribunal also confirmed the disallowance and dismissed the appeal. The learned advocate Shri Manish Shah, appearing for the assessee, has submitted that ... Tribunal and the said decision was not challenged. The Tribunal has, in our view unfortunately, upheld the order of the Commissioner (Appeals) wherein the Tribunal's earlier orders in the assessee's own case have been distinguished by giving reasons which are, to say the least, unwarranted. The earlier orders

Deputy Commissioner of Income Tax, Central Circle-8(1), Mumbai vs. Raymond Ltd, Mumbai

In the result, appeal filed by the Revenue is dismissed

ITA 4073/MUM/2018[2011-12]Status: DisposedITAT Mumbai28 Dec 2022AY 2011-12

Bench: Shri Amit Shukla, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

For Appellant: Shri Madhur Agrawal &For Respondent: Shri T. Shankar
Section 143(3)Section 14ASection 23Section 40A(2)(b)

said order, the assessee filed an appeal before the Commissioner (Appeals). The Commissioner (Appeals) dismissed the appeal. The assessee thereupon filed second appeal before the Tribunal but the Tribunal also confirmed the disallowance and dismissed the appeal. The learned advocate Shri Manish Shah, appearing for the assessee, has submitted that ... Tribunal and the said decision was not challenged. The Tribunal has, in our view unfortunately, upheld the order of the Commissioner (Appeals) wherein the Tribunal's earlier orders in the assessee's own case have been distinguished by giving reasons which are, to say the least, unwarranted. The earlier orders

Deputy Commissioner of Income Tax, Central Circle-8(1), Mumbai vs. Raymond Ltd, Mumbai

In the result, appeal filed by the Revenue is dismissed

ITA 4072/MUM/2018[2010-11]Status: DisposedITAT Mumbai28 Dec 2022AY 2010-11

Bench: Shri Amit Shukla, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

For Appellant: Shri Madhur Agrawal &For Respondent: Shri T. Shankar
Section 143(3)Section 14ASection 23Section 40A(2)(b)

said order, the assessee filed an appeal before the Commissioner (Appeals). The Commissioner (Appeals) dismissed the appeal. The assessee thereupon filed second appeal before the Tribunal but the Tribunal also confirmed the disallowance and dismissed the appeal. The learned advocate Shri Manish Shah, appearing for the assessee, has submitted that ... Tribunal and the said decision was not challenged. The Tribunal has, in our view unfortunately, upheld the order of the Commissioner (Appeals) wherein the Tribunal's earlier orders in the assessee's own case have been distinguished by giving reasons which are, to say the least, unwarranted. The earlier orders

Deputy Commissioner of Income Tax, Central Circle-8(1), Mumbai vs. Raymond Ltd, Mumbai

In the result, appeal filed by the Revenue is dismissed

ITA 202/MUM/2018[2009-10]Status: DisposedITAT Mumbai28 Dec 2022AY 2009-10

Bench: Shri Amit Shukla, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

For Appellant: Shri Madhur Agrawal &For Respondent: Shri T. Shankar
Section 143(3)Section 14ASection 23Section 40A(2)(b)

said order, the assessee filed an appeal before the Commissioner (Appeals). The Commissioner (Appeals) dismissed the appeal. The assessee thereupon filed second appeal before the Tribunal but the Tribunal also confirmed the disallowance and dismissed the appeal. The learned advocate Shri Manish Shah, appearing for the assessee, has submitted that ... Tribunal and the said decision was not challenged. The Tribunal has, in our view unfortunately, upheld the order of the Commissioner (Appeals) wherein the Tribunal's earlier orders in the assessee's own case have been distinguished by giving reasons which are, to say the least, unwarranted. The earlier orders

Shambanna Jattappa Hadimani, Hubli vs. Income Tax Officer, Ward-1(3), Hubli

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

ITA 556/BANG/2022[2017-18]Status: DisposedITAT Bangalore28 Dec 2022AY 2017-18

Bench: Shri Chandra Poojariassessment Year: 2017-18

For Appellant: Shri V. Srinivasan, A.RFor Respondent: Shri Ganesh R. Gale, Standing Counsel for Department
Section 250

confirmed the disallowance made by AO at Rs.3.96 lakhs. 4. There was a delay of 282 days in filing the appeal before this Tribunal. The assessee explained that out of 282 days, 238 days delay was due to Covid period i.e. from 15.3.2020 to 28.02.2022 and extended further period ... submitted that the assessee has given the appeal papers to one Mr. Adinavar, Chartered Accountant that the option to file the appeal before the Tribunal was not yet enabled in the e- filing portal of I.T. Department where the impugned order was uploaded under the mistaken belief and notion that

Prerak Goel, Mumbai vs. Pr. CIT -19, Mumbai

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

ITA 787/MUM/2022[2016-17]Status: DisposedITAT Mumbai27 Dec 2022AY 2016-17
Section 143(3)Section 2(47)(v)Section 263Section 53ASection 54F

assessee is aggrieved by the revision order so passed by Ld PCIT and hence he has filed this appeal before the Tribunal. 5. The Ld A.R submitted that the assessing officer has made due enquiries with regard to the claim made u/s 54F of the Act. He submitted that

M/S Golden Seams Textiles P. Ltd., Mumbai vs. Dy CIT, Central Circle-5, Mumbai

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

ITA 2019/MUM/2020[2010-11]Status: DisposedITAT Mumbai27 Dec 2022AY 2010-11

Bench: Shri Om Prakash Kant () & Shri Rahul Chaudhary () Assessment Year: 2010-11 M/S Golden Seams Textiles Pvt. Dcit, Central Circle-5, Ltd., Old Cgo Bldg., Room No. 14, Peninsula Centre, Dr. S.S. Vs. 901, Annexe, 9Th Floor, M.K. Rao Road, Parel, Road, Mumbai-400012. Mumbai-400020. Pan No. Aaccg 1114 E Appellant Respondent : Assessee By Mr. Dharan Gandhi/Vipul J. Revenue By : Mr. Sanjay Vishwas Rao Deshmukh, Cit-Dr : Date Of Hearing 02/11/2022 Date Of Pronouncement : 27/12/2022

For Respondent: Assessee by Mr. Dharan Gandhi/Vipul J
Section 132(1)Section 153ASection 153C

balance addition and balance addition was deleted. Aggrieved with the addition sustained the addition sustained, the assessee is in appeal assessee is in appeal before the Tribunal raising the grounds as reproduced above. before the Tribunal raising the grounds as reproduced above. before the Tribunal raising the grounds as reproduced

Late Shri Nazmin Jamal(Through Its Legal Heir), Mumbai vs. ITO 20(3)(5), Mumbai

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

ITA 2838/MUM/2016[2005-06]Status: DisposedITAT Mumbai27 Dec 2022AY 2005-06

Bench: The Tribunal.

Section 132Section 132(4)Section 147

making addition of Rs. 60 lakhs. The learned CIT(A) in the first round deleted the addition and hence the revenue filed the appeal before the Tribunal. 3. The ITAT, vide its order dated 22.2.2013 passed in ITA No. 2828/Mum/2011 reversed the order passed by the learned

Madhu Kumar Patel, Hyderabad vs. ADIT, (Int. Taxn)-2, Hyderabad

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

ITA 395/HYD/2022[2015-16]Status: DisposedITAT Hyderabad26 Dec 2022AY 2015-16

Bench: Shri R.K. Panda & Shri K. Narasimha Charyassessment Year:2015-16 Shri Madhu Kumar Patel Vs. A.D.I.T (Intl.Taxation)-2 Hyderabad Hyderabad Pan:Bvdpp3797G (Appellant) (Respondent) Assessee By: Shri K.A. Sai Prasad, Ca Revenue By: Shri Rajendra Kumar, Cit(Dr) Date Of Hearing: 10/11/2022 Date Of Pronouncement: 26/12/2022 Order Per R.K. Panda, A.M This Appeal Filed By The Assessee Is Directed Against The Order Dated 19.7.2022 Passed U/S 147 R.W.S. 144C(13) Of The I.T. Act For The A.Y 2015-16. 2. Facts Of The Case, In Brief, Are That The Assessee Is An Individual & A Resident Of The U.K. He Filed His Return Of Income On 31.08.2015 Declaring Total Income At Rs.2,91,07,000/- As Income From Long Term Capital Gain.

For Appellant: Shri K.A. Sai Prasad, CAFor Respondent: Shri Rajendra Kumar, CIT(DR)
Section 147Section 148Section 2(47)(v)

flats amounting to Rs.2,99,46,438/-. 9. Aggrieved with such order of the Assessing Officer/DRP, the assessee is in appeal before the Tribunal by raising the following grounds of appeal: “1. The order u/s.147 r.w.s 144C(13) dt. 19-07-2022 passed by the Ld. Assessing Officer pursuant

Mylan Pharmaceuticals Private Limited, Hyderabad vs. ITO Ward-16(3), Hyderabad

In the result, appeal filed by the assessee is allowed

ITA 122/HYD/2022[2016-17]Status: DisposedITAT Hyderabad26 Dec 2022AY 2016-17

Bench: Shri Rama Kanta Panda & Shri Laliet Kumarassessment Year: 2016-17 Mylan Pharmaceuticals Vs. Ito,Ward-16(3) Private Limited I.T.Towers, Ac Guards Plot No.564/A/22, Masab Tank Road No.92 Hyderabad-500 004 Jubillee Hills, Hyderabad Telangana-500 096

For Appellant: Shri P.V.S.S.Prasad, CAFor Respondent: Shri Jeevan Lal Lavidiya,CIT-DR
Section 143(2)Section 143(3)Section 263Section 37(1)

pass the order in accordance with law after due verification. 7. Aggrieved with such order of the ld.PCIT, the assessee is in appeal before the Tribunal by raising the following grounds 1.1 On the facts and in the circumstances of the case and in law, the learned Principal Commissioner

ACIT, Central Circle - 2(2), Kolkata vs. M/S Magnetic Niryat Pvt. Ltd., Kolkata

In the result, the appeal of the Revenue is dismissed

ITA 347/KOL/2022[2012-2013]Status: DisposedITAT Kolkata23 Dec 2022AY 2012-2013

Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Rajesh Kumari.T.A. No. 347/Kol/2022 Assessment Year: 2012-2013 Assistant Commissioner Of Income Tax,......Appellant Central Circle-2(2), Kolkata, Aayakar Bhawan Poorva, 4Th Floor, 110, Shantipally, E.M. Bypass, Kolkata-700107 -Vs.- M/S. Magnetic Niryat Pvt. Limited,............Respondent 9, Vivekanand Road, Kolkata-700007 [Pan:Aagcm4047E] Appearances By: N O N E, Appeared On Behalf Of The Assessee Shri Sudipta Guha, Cit (Dr), Appeared On Behalf Of The Revenue

Section 132Section 132(1)Section 153ASection 68

Date of pronouncing the order : December 23, 2022 O R D E R Per Rajpal Yadav, Vice-President (KZ):- The Revenue is in appeal before the Tribunal against the order of ld. Commissioner of Income Tax (Appeals)- 20, Kolkata dated 29.10.2021 passed for A.Y. 2012-13. 1 Assessment Year

Kathiravan Srinivasan, Perambalur vs. DCIT, Circle -1, Tiruchirapalli

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

ITA 172/CHNY/2022[2011-2012]Status: DisposedITAT Chennai23 Dec 2022AY 2011-2012

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwalआयकरअपील सं./Ita Nos.: 170 & 171/Chny/2022 िनधा"रण वष" / Assessment Year: 2010-11 & आयकरअपील सं./Ita No.: 172/Chny/2022 िनधा"रण वष" / Assessment Year: 2011-12 Shri Kathiravan Srinivasan, Vs The Dcit, No.274C, Thuraiyur Road, Circle-1, 2Nd Perambalur – 621 212. Main Building, Floor, New No.44, Old No.4, Williams Road, Cantonment, Pan: Ajspk 6687Q Trichirapalli-620 001. (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri G. Baskar, Advocate ""यथ" क" ओर से/Respondent By : Shri Darzakhum Songate, Cit सुनवाई क" तार"ख/Date Of Hearing : 18.10.2022 घोषणा क" तार"ख/Date Of Pronouncement : 23.12.2022 आदेश /O R D E R Per Mahavir Singh, Vp: These Three Appeals By The Assessee Are Arising Out Of Two Different Orders Of The Commissioner Of Income Tax (Appeals)-19, Chennai In Ita Nos.581 & 582/Chny/19-20 Dated 03.03.2022. The Assessments In Ita Nos.170 & 172/Chny/2022 Were Framed By The Jcit, Range 1, Trichy For The Assessment Years 2010-11 & 2011-12 U/S.143(3) Of The Income Tax Act, 1961 (Hereinafter The ‘Act’) Vide Orders Dated 31.03.2013 & 31.03.2014 Respectively. The Third Appeal In Ita No.171/Chny/2022 Is Against The Assessment Order Framed In Consequence To Revision Order Passed By Pcit U/S.263 Of The Act & Consequent Order Of The Ao For The Assessment Year 2010-11 U/S.143(3) R.W.S. 263 Of The Act Dated 12.03.2015 Passed By The Dcit, Circle-1, Trichy.

For Appellant: Shri G. Baskar, AdvocateFor Respondent: Shri Darzakhum Songate, CIT
Section 143(3)Section 263Section 68

hereby dismissed and the addition made u/s.68 of Rs.1,98,00,000/- are sustained. Aggrieved, in both the years, the assessee came in appeal before the Tribunal. 5. We have heard rival contentions and gone through facts and circumstances of the case. We have also perused the paper-book filed ... same to short term capital gains. The CIT(A) exactly on identical facts dismissed the claim of assessee. Aggrieved, now assessee is in appeal before the Tribunal for both the years. 8. Before us the ld.counsel for the assessee filed copy of sale deeds executed in regard to these agricultural