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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

Chatwani and Shah Private Limited, Mumbai vs. Dy CIT Central Circle(1)(2), Mumbai

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

ITA 1482/MUM/2022[2014-2015]Status: DisposedITAT Mumbai07 Sept 2022AY 2014-2015

Bench: The Tribunal.

Section 14A

under rule 8D(2)(iii). The learned CIT(A) confirmed the disallowance and hence the assessee has filed this appeal before the Tribunal. 2 Chatwani & Shah Pvt. Ltd. 3. The Learned AR submitted that the assessee had made investments in the earlier years mainly in the units of mutual funds

Amc Cookware (India) Private Limited, Bangalore vs. Income Tax Officer, Ward-1(1)(1), Bangalore

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

ITA 429/BANG/2022[2017-18]Status: DisposedITAT Bangalore07 Sept 2022AY 2017-18

Bench: Shri N. V. Vasudevan & Ms. Padmavathy Sit(Tp)A No.429/Bang/2022 Assessment Year : 2017-18 M/S. Amc Cookware (India) Private Limited, Vs. Ito, No.1180, 12Th B Main, 1St Cross, Hal 2Nd Ward – 1(1)(1), Stage, Indira Nagar, Bengaluru. Bengaluru – 560 008. Pan : Aacca 4970 G Appellant Respondent Assessee By : Shri. K. P. Srinivas, Ca Revenue By : Shri. V. S. Chakrapani, Cit(Dr)(Itat), Bengaluru. Date Of Hearing : 01.09.2022 Date Of Pronouncement : 07.09.2022 O R D E R Per N. V. Vasudevan: This Is An Appeal By The Assessee Against The Final Order Of Assessment Dated 30.03.2022 Passed By The Ito, Ward – 1(1)(1) Of National Faceless Assessment Centre, Delhi, Passed Under Section 143(3) R.W.S. 144C(13) R.W.S. 144B Of The Income Tax Act, 1962 (Hereinafter Called ‘The Act’) In Relation To Assessment Year 2017-18. 2. The Only Dispute Raised By The Assessee In This Appeal Is As To Whether The Revenue Authorities Were Justified In Determining The Shortfall In Arm’S Length Price (Alp) Of An International Transaction At Rs.2,37,87,122/- & It(Tp)A No.429/Bang/2022 Page 2 Of 8

For Appellant: Shri. K. P. Srinivas, CAFor Respondent: Shri. V. S. Chakrapani, CIT(DR)(ITAT), Bengaluru
Section 143(3)Section 92

TNMM. The DRP, however, did not accept any of the contentions of the assessee. Hence, the assessee is in appeal before the Tribunal. 9. The learned Counsel for the assessee brought to our notice that the issue as to whether RPM should be adopted as the MAM or TNMM

Ms Salahuddin Haqani Salim, Chennai vs. DCIT Non Corporate Circle 10(1), Chennai

In the result, the appeal of the Assessee in I

ITA 261/CHNY/2022[2016-17]Status: DisposedITAT Chennai06 Sept 2022AY 2016-17

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A No.:261/Chny/2022 िनधा"रण वष"/ Assessment Year 2016 - 2017

For Appellant: Mr. Saroj Kumar Parida, AdvocateFor Respondent: Mr. M. Rajan, CIT
Section 142(1)Section 143(2)Section 143(3)Section 263Section 54Section 54F

reason. The Appellate order under challenge before the Tribunal was served to the Assessee on 25.03.2021 and the Assessee had filed the appeal before the Tribunal on 26.04.2022, thereby it means that there is a delay of 337 days, but as contended by the Assessee in the petition that ... Income Tax had never said that the assessment is erroneous or prejudicial to the interests of the revenue. Aggrieved, the Assessee came in appeal before the Tribunal. 6. Before us, the Assessee took us through paragraph No.5 of the order of the Principal Commissioner of Income Tax which reads

The Dadabhai Kavasji Tata School Trust, Na

In the result, appeal filed by the assessee is allowed

ITA 1637/MUM/2022[2015-16]Status: DisposedITAT Mumbai06 Sept 2022AY 2015-16
Section 11Section 11(1)(a)Section 11(2)Section 12ASection 12A(1)(B)Section 12A(1)(b)Section 139(1)Section 139(4)Section 44A

that the remedy does not lie before him. Accordingly, he dismissed the appeal of the assessee. 4. Aggrieved, the assessee has filed this appeal before the Tribunal. 5. One of the trustees of the assessee trust appeared before us. He submitted that the provisions of section

Samaj Sampada Co.Op Ltdcredit Society, Mumbai vs. CIT(A) National Faceless Centreappeal, Delhi

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

ITA 1539/MUM/2022[2017-2018]Status: DisposedITAT Mumbai06 Sept 2022AY 2017-2018
Section 142(1)Section 144

also, the assessee did not appear and hence the first appellate authority confirmed the assessment order. Aggrieved, the assessee has filed this appeal before the Tribunal. 5. We noticed that the assessee is a credit co-operative deposit carrying on the business of accepting deposits from its members and lending

ACIT 1 (1)(1), Mumbai vs. M/S Dosti Realty Ltd., Mumbai

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

ITA 7374/MUM/2019[2014-15]Status: DisposedITAT Mumbai06 Sept 2022AY 2014-15

Bench: Shr Pramod Kumar, Vp & Shri Amit Shukla, Jm आयकरअपीलसं./ I.T.A. No. 7374/Mum/2019 (निर्धारणवर्ा / Assessment Year: 2014-15) Asst. Commissioner Of M/S Dosti Realty Ltd. (Formally Known As Friends Income Tax-1(1)(1), Development Corporation 579,Ayankar Bhavan, M.K बिधम/ (Imperia) Pvt. Ltd. Road, Mumbai-400020, 276,1St Floor, Lawrence & Vs. Mayo House, Mumbai - 400001, स्थायीलेखासं./जीआइआरसं./ Pan No Aabcf5801A (अपीलाथी/Appellant) (प्रत्यथी / Respondent) : अपीलाथीकीओरसे/ Appellant By : Shri P.R. Rastogi, Ld. Dr प्रत्यथीकीओरसे/Respondent By : Shri Dr.K.Shivaram & Rahul Hakani, Ld. Ar सुनवाईकीतारीख/ : 14.06.2022 Date Of Hearing घोषणाकीतारीख / : 06.09.2022 Date Of Pronouncement आदेश / O R D E R Per Amit Shukla: The Aforesaid Appeal Has Been Filed By The Revenue Against Order Dated 19.09.2019, Passed By Ld. Cit (Appeals)-2, Mumbai For The Quantum Of Assessment Passed U/S 143(3) For Ay 2014-2015. The Revenue Has Raised The Following Grounds:-

For Appellant: Shri P.R. Rastogi, Ld. DRFor Respondent: Shri Dr.K.Shivaram & Rahul
Section 143(3)Section 36(1)(iii)

also held that in AY 2012-13, similar disallowance was made which was deleted by the Ld. CIT(A), however revenue has filed appeal before the Tribunal. 8. Ld. CIT (A) in so far as issue relating to selling /brokerage expenses and advertisement expenses which has been raised vide Ground

Vinodkumar Lakshmipathi, Bangalore vs. Assistant Director of Income Tax, CPC, Bangalore

In the result, the appeal is allowed

ITA 680/BANG/2022[2018-19]Status: DisposedITAT Bangalore06 Sept 2022AY 2018-19

Bench: Shri Chandra Poojari & Shri George George K.Assessment Year: 2018-19

For Appellant: Shri Navaneeth Kini, A.RFor Respondent: Shri K.R. Narayana, D.R
Section 139Section 143(1)Section 90

noncompliance thereof does not disentitle the Assessee of the FTC. 7. Aggrieved by the order of the CIT(A), the Assessee is in appeal before the Tribunal. The learned counsel for the Assessee submitted that disallowance of FTC is bad in law. He submitted that Section

Mr. G R Chandrashekar Naidu, Bengaluru vs. Assistant Director of Income Tax, CPC, Bangalore

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

ITA 677/BANG/2022[2020-21]Status: HeardITAT Bangalore06 Sept 2022AY 2020-21

Bench: Shri Chandra Poojari, Am & Shri George George K, Jm

For Appellant: Smt.Suman Gala Ranga, AdvocateFor Respondent: Sri.K.R.Narayanan, Addl.CIT-DR
Section 139(1)Section 143(1)Section 36(1)Section 36(1)(va)Section 43B

I.T.Act by Finance Act, 2021, is clarificatory and has got retrospective operation. 5. Aggrieved, assessee has filed this appeal before the Tribunal. The learned AR relied on the ITAT’s Order in the case of M/s. Shakuntala Agarbathi Company Vs. DICT in ITA No.385/Bang/2021 (order dated 21.10.2021). 6. The learned

Cerner Healthcare Solutions India Private Limited (Earlier Known As Cerner India Health Services Private Limited), Bangalore vs. Deputy Commissioner of Income Tax, Circle-2(1)(1), Bangalore

In the result, the appeal by the assessee is allowed

ITA 274/BANG/2022[2017-18]Status: DisposedITAT Bangalore06 Sept 2022AY 2017-18

Bench: Shri N.V. Vasudevan, Vice Preseident & Shri Padmavathy S

For Appellant: Shri Sumeet Khurana, CAFor Respondent: Shri V S Chakrapani, CIT(DR)(ITAT), Bengaluru
Section 37Section 43B

assessment order. In accordance with the directions of the DRP, the AO passed the final assessment order against which the assessee is in appeal before the Tribunal. Page 3 of 12 4. The assessee has entered into Advance Pricing Agreement [APA] and therefore did not raise any grounds pertaining

M/S. Subex Limited, Bangalore vs. The Joint Commissioner of Income Tax (OSD), Cirlce- 12(3), Bangalore

ITA 2638/BANG/2019[2008-09]Status: DisposedITAT Bangalore06 Sept 2022AY 2008-09

Bench: Shri George George K, Jm & Ms.Padmavathy S, Am

For Respondent: Smt.Vandana Sagar, CIT-DR
Section 143(2)Section 143(3)Section 195Section 260ASection 40Section 92C

required to be deducted at source. 6. Aggrieved by the order of the CIT(A), the assessee preferred appeal before the Tribunal. As mentioned earlier, the Tribunal disposed of the matter in favour of the assessee by holding that the payment was merely a journal entry, hence, there

M/S Subex Technologies Limited, Bangalore vs. JCIT, Bangalore

ITA 715/BANG/2014[2008-09]Status: DisposedITAT Bangalore06 Sept 2022AY 2008-09

Bench: Shri George George K, Jm & Ms.Padmavathy S, Am

For Respondent: Smt.Vandana Sagar, CIT-DR
Section 143(2)Section 143(3)Section 195Section 260ASection 40Section 92C

required to be deducted at source. 6. Aggrieved by the order of the CIT(A), the assessee preferred appeal before the Tribunal. As mentioned earlier, the Tribunal disposed of the matter in favour of the assessee by holding that the payment was merely a journal entry, hence, there

Sri. M. Nagaraja, Mysore vs. The Deputy Commissioner of Income Tax, Circle- 2(1), Mysore

In the result, appeal of the assessee is dismissed

ITA 1905/BANG/2019[1999-2000]Status: DisposedITAT Bangalore05 Sept 2022AY 1999-2000

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year : 1999-2000

For Respondent: Shri S. Parthasarathi
Section 139(1)Section 139(4)Section 139(5)Section 143(2)Section 143(3)Section 147Section 148Section 154Section 234BSection 263

Rs.39,79,665 3. At the time of hearing, it is noticed that there was a delay of 2111 days in filing the appeal before this Tribunal. 4. The Ld.AR submitted vide note dated 30/07/2022 as under: “1. In the case of the Appellant, a survey was conducted ... order dated 21.02.2005 dismissed the same. A copy of the order is enclosed at Page Nos.30-35 of the Paper Book. The Appellant filed appeal before the Tribunal against the said order and the Tribunal vide order dated 21.04.2006 allowed the appeal wherein the impugned addition towards cost of construction

ACIT- CC-4(4) Cr. 4, Pr. CIT- (C)- 2, Mumbai vs. Umax Packaging Ltd, Mumbai

In the result, this appeal is dismissed as withdrawn

ITA 2554/MUM/2021[2013-14]Status: DisposedITAT Mumbai02 Sept 2022AY 2013-14

Bench: The Tribunal Stands Enhanced & Departmental Appeal Is Not Be Filed Before The Tribunal In Cases Where The Tax Effect Does Not Exceed The Specified Monetary Limits Of Inr 50 Lakhs. The Tax Effect In The Present Appeal Below The Aforesaid Specified Monetary Limit & Therefore, The Present Appeal Is Dismissed As ‘Withdrawn/Not Pressed’ In Terms Of The Above-Said Circular.

For Appellant: NoneFor Respondent: Shri Achal Sharma
Section 143(3)Section 153A

Circular No. 17 of 2019, dated 08.08.2019, issued by the Central Board of Direct Taxes (CBDT) the monetary limit for filing departmental appeal before the Tribunal stands enhanced and departmental appeal is not be filed before the Tribunal in cases where the tax effect does not exceed the specified monetary

The ACIT Cent. Cir -5(4), Mumbai vs. Shri Nitan Chhatwal, Mumbai

In the result, the both the appeals of the revenue are dismissed

ITA 2244/MUM/2021[2015-16]Status: DisposedITAT Mumbai02 Sept 2022AY 2015-16
Section 132Section 139(1)Section 143(3)Section 153ASection 68

Bombay High Court in yet another case of Gurinder Singh Bawa (2017)(70 taxmann.com 398) as under:- “5. On further appeal before the Tribunal, the assessee interalia challenged the validity of the assessment made under Section 153A of the Act. This on account of the fact that no assessment ... No.5039/Mum/2018. Following the same, the Ld CIT(A) deleted the above said addition made by the AO. Aggrieved, the revenue has filed appeal before the Tribunal. 19 Nitan Chhatwal 29. The assessee had challenged the validity of reopening of assessment before Ld CIT(A) on the ground that there

ACIT Cent. Cir -5(4), Mumbai vs. Shri Nitan Chhatwal, Mumbai

In the result, the both the appeals of the revenue are dismissed

ITA 2243/MUM/2021[2013-14]Status: DisposedITAT Mumbai02 Sept 2022AY 2013-14
Section 132Section 139(1)Section 143(3)Section 153ASection 68

Bombay High Court in yet another case of Gurinder Singh Bawa (2017)(70 taxmann.com 398) as under:- “5. On further appeal before the Tribunal, the assessee interalia challenged the validity of the assessment made under Section 153A of the Act. This on account of the fact that no assessment ... No.5039/Mum/2018. Following the same, the Ld CIT(A) deleted the above said addition made by the AO. Aggrieved, the revenue has filed appeal before the Tribunal. 19 Nitan Chhatwal 29. The assessee had challenged the validity of reopening of assessment before Ld CIT(A) on the ground that there

Cma Cgm Sa, Mumbai vs. ACIT, (International Taxation)- 2(1)(1), Mumbai

In the result, appeal by assessee is partly allowed

ITA 5998/MUM/2019[2016-17]Status: DisposedITAT Mumbai02 Sept 2022AY 2016-17
For Appellant: S/Shri M.P. Lohia and Nikhil TiwariFor Respondent: S/Shri Miland Chavan and C.T. Mathews
Section 115ASection 143(3)Section 271(1)(c)

taxable in the light of beneficial provisions of India-France DTAA. 15. The reason given by the assessee for raising additional grounds of appeal before the Tribunal as per the application (supra) is reproduced herein below: “With regard to the additional ground relating to non-taxability of FTS received

Micro Ankur Developers, Mumbai vs. DCIT - CC - 3(4), Mumbai

In the result, the appeals of the assessee for AYs 2010-11, 2011-12 & 2012-

ITA 1050/MUM/2019[2014-15]Status: DisposedITAT Mumbai02 Sept 2022AY 2014-15

Bench: Shri Aby T. Varkey, Jm & Shri Gagan Goyal, Am आयकरअपीलसं/ I.T.A. No.1046/Mum/2019 (निर्धारणवर्ा / Assessment Year: 2010-11) & आयकरअपीलसं/ I.T.A. No.1047/Mum/2019 (निर्धारणवर्ा / Assessment Year: 2011-12) & आयकरअपीलसं/ I.T.A. No.1048/Mum/2019 (निर्धारणवर्ा / Assessment Year: 2012-13) & आयकरअपीलसं/ I.T.A. No.1049/Mum/2019 (निर्धारणवर्ा / Assessment Year: 2013-14) & आयकरअपीलसं/ I.T.A. No.1050/Mum/2019 (निर्धारणवर्ा / Assessment Year: 2014-15) Micro Ankur Developers बिधम/ Dcit-Cc, 3(4) C/O Rajendra & Associates 19Th Floor, Air India Vs. 317, Prasad Chamber, Opera Building, Nariman Point, Mumbai-400021. House, Charni Road, Mumbai-400004. स्थधयीलेखधसं./जीआइआरसं./Pan/Gir No. : Aanfm4634P (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent)

For Appellant: Shri Bharat KumarFor Respondent: Dr. Mahesh Akhade (DR)
Section 132(4)Section 139Section 143(2)Section 153A

gifts aggregating to Rs. 93.70 lakhs is concerned, the CIT(A) did not disturb the finding of the Assessing Officer. 5. On further appeal before the Tribunal, the assessee interalia challenged the validity of the assessment made under Section 153A of the Act. This on account of the fact that

Micro Ankur Developers, Mumbai vs. DCIT - CC - 3(4), Mumbai

In the result, the appeals of the assessee for AYs 2010-11, 2011-12 & 2012-

ITA 1049/MUM/2019[2013-14]Status: DisposedITAT Mumbai02 Sept 2022AY 2013-14

Bench: Shri Aby T. Varkey, Jm & Shri Gagan Goyal, Am आयकरअपीलसं/ I.T.A. No.1046/Mum/2019 (निर्धारणवर्ा / Assessment Year: 2010-11) & आयकरअपीलसं/ I.T.A. No.1047/Mum/2019 (निर्धारणवर्ा / Assessment Year: 2011-12) & आयकरअपीलसं/ I.T.A. No.1048/Mum/2019 (निर्धारणवर्ा / Assessment Year: 2012-13) & आयकरअपीलसं/ I.T.A. No.1049/Mum/2019 (निर्धारणवर्ा / Assessment Year: 2013-14) & आयकरअपीलसं/ I.T.A. No.1050/Mum/2019 (निर्धारणवर्ा / Assessment Year: 2014-15) Micro Ankur Developers बिधम/ Dcit-Cc, 3(4) C/O Rajendra & Associates 19Th Floor, Air India Vs. 317, Prasad Chamber, Opera Building, Nariman Point, Mumbai-400021. House, Charni Road, Mumbai-400004. स्थधयीलेखधसं./जीआइआरसं./Pan/Gir No. : Aanfm4634P (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent)

For Appellant: Shri Bharat KumarFor Respondent: Dr. Mahesh Akhade (DR)
Section 132(4)Section 139Section 143(2)Section 153A

gifts aggregating to Rs. 93.70 lakhs is concerned, the CIT(A) did not disturb the finding of the Assessing Officer. 5. On further appeal before the Tribunal, the assessee interalia challenged the validity of the assessment made under Section 153A of the Act. This on account of the fact that

Micro Ankur Developers, Mumbai vs. DCIT - CC - 3(4), Mumbai

In the result, the appeals of the assessee for AYs 2010-11, 2011-12 & 2012-

ITA 1048/MUM/2019[2012-13]Status: DisposedITAT Mumbai02 Sept 2022AY 2012-13

Bench: Shri Aby T. Varkey, Jm & Shri Gagan Goyal, Am आयकरअपीलसं/ I.T.A. No.1046/Mum/2019 (निर्धारणवर्ा / Assessment Year: 2010-11) & आयकरअपीलसं/ I.T.A. No.1047/Mum/2019 (निर्धारणवर्ा / Assessment Year: 2011-12) & आयकरअपीलसं/ I.T.A. No.1048/Mum/2019 (निर्धारणवर्ा / Assessment Year: 2012-13) & आयकरअपीलसं/ I.T.A. No.1049/Mum/2019 (निर्धारणवर्ा / Assessment Year: 2013-14) & आयकरअपीलसं/ I.T.A. No.1050/Mum/2019 (निर्धारणवर्ा / Assessment Year: 2014-15) Micro Ankur Developers बिधम/ Dcit-Cc, 3(4) C/O Rajendra & Associates 19Th Floor, Air India Vs. 317, Prasad Chamber, Opera Building, Nariman Point, Mumbai-400021. House, Charni Road, Mumbai-400004. स्थधयीलेखधसं./जीआइआरसं./Pan/Gir No. : Aanfm4634P (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent)

For Appellant: Shri Bharat KumarFor Respondent: Dr. Mahesh Akhade (DR)
Section 132(4)Section 139Section 143(2)Section 153A

gifts aggregating to Rs. 93.70 lakhs is concerned, the CIT(A) did not disturb the finding of the Assessing Officer. 5. On further appeal before the Tribunal, the assessee interalia challenged the validity of the assessment made under Section 153A of the Act. This on account of the fact that

Micro Ankur Developers, Mumbai vs. DCIT -CC - 3 (4), Mumbai

In the result, the appeals of the assessee for AYs 2010-11, 2011-12 & 2012-

ITA 1047/MUM/2019[2011-12]Status: DisposedITAT Mumbai02 Sept 2022AY 2011-12

Bench: Shri Aby T. Varkey, Jm & Shri Gagan Goyal, Am आयकरअपीलसं/ I.T.A. No.1046/Mum/2019 (निर्धारणवर्ा / Assessment Year: 2010-11) & आयकरअपीलसं/ I.T.A. No.1047/Mum/2019 (निर्धारणवर्ा / Assessment Year: 2011-12) & आयकरअपीलसं/ I.T.A. No.1048/Mum/2019 (निर्धारणवर्ा / Assessment Year: 2012-13) & आयकरअपीलसं/ I.T.A. No.1049/Mum/2019 (निर्धारणवर्ा / Assessment Year: 2013-14) & आयकरअपीलसं/ I.T.A. No.1050/Mum/2019 (निर्धारणवर्ा / Assessment Year: 2014-15) Micro Ankur Developers बिधम/ Dcit-Cc, 3(4) C/O Rajendra & Associates 19Th Floor, Air India Vs. 317, Prasad Chamber, Opera Building, Nariman Point, Mumbai-400021. House, Charni Road, Mumbai-400004. स्थधयीलेखधसं./जीआइआरसं./Pan/Gir No. : Aanfm4634P (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent)

For Appellant: Shri Bharat KumarFor Respondent: Dr. Mahesh Akhade (DR)
Section 132(4)Section 139Section 143(2)Section 153A

gifts aggregating to Rs. 93.70 lakhs is concerned, the CIT(A) did not disturb the finding of the Assessing Officer. 5. On further appeal before the Tribunal, the assessee interalia challenged the validity of the assessment made under Section 153A of the Act. This on account of the fact that