“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

Walvoil Fluid Power India Private Limited, Bangalore vs. Deputy Commissioner of Income Tax Circle-7(1)(2), Bangalore

In the result, appeal of the assesee is partly allowed

ITA 1901/BANG/2017[2013-14]Status: DisposedITAT Bangalore21 Mar 2022AY 2013-14

Bench: Shri George George K & Ms. Padmavathy S

For Appellant: Shri R.E Balasubramanyam, C.AFor Respondent: Shri A Sreenivasa Rao, CIT(DR)

Section 143(2)Section 143(3)Section 92C

force. Consequently, the objection of the assessee cannot be accepted. 14. Aggrieved by the order of the DRP, the assessee is in appeal before the Tribunal. 15. The ld.AR submitted that the assessee manufactures hydraulic valves that are used in heavy-duty machinery and vehicle such as construction of earth

Gm Overseas, New Delhi vs. ACIT Circle-48(1), New Delhi

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

ITA 1891/DEL/2020[2010-11]Status: DisposedITAT Delhi21 Mar 2022AY 2010-11

For Appellant: Shri Suresh Gupta, CAFor Respondent: Shri Hemant Gupta, Sr. DR

Section 131ASection 133ASection 143(3)Section 147

reassessment proceedings and also sustained the addition on merit. 5. Aggrieved with such order of the CIT(A), the assessee is in appeal before the Tribunal by raising the following grounds:- “ 1. The impugned assessment is invalid and without jurisdiction as the said assessment is completed without complying with legal

M/S. Prestige Estates Projects Limited, Bangalore vs. Deputy Commissioner of Income Tax, Central Circle-1(1), Bangalore

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

ITA 68/BANG/2022[2013-14]Status: DisposedITAT Bangalore18 Mar 2022AY 2013-14

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

For Appellant: Sri.Sudheendra B.R., AdvocateFor Respondent: Sri.A.Sreenivasa Rao, CIT-DR

Section 153ASection 154Section 3(1)(b)

relied on various judicial pronouncements cited in para 4.1 to 4.3 of the impugned order. 5. Aggrieved, the assessee has filed appeals before the Tribunal. The learned AR reiterated the submissions made before the Income Tax Authorities. 6. The learned Departmental Representative supported the order ... required to be decided on merits and not on merely technicalities. Hence, on these grounds appeal is allowed. The delay in filing the appeal before the Tribunal is condoned." 6 ITA Nos.67-68/Bang/2022 M/s.Prestige Estates Projects Limited. 7.4 The following judicial pronouncements had held that the delay ought to be condoned

M/S. Prestige Estates Projects Limited, Bangalore vs. Deputy Commissioner of Income Tax, Central Circle-1(1), Bangalore

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

ITA 67/BANG/2022[2012-13]Status: DisposedITAT Bangalore18 Mar 2022AY 2012-13

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

For Appellant: Sri.Sudheendra B.R., AdvocateFor Respondent: Sri.A.Sreenivasa Rao, CIT-DR

Section 153ASection 154Section 3(1)(b)

Sri. Joison Kundu Kulam Johny, Bengaluru vs. Income Tax Officer, Ward- 5(3)(6), Bangalore

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

ITA 308/BANG/2021[2015-16]Status: DisposedITAT Bangalore18 Mar 2022AY 2015-16

Bench: Shri N.V. Vasudevan & Shri B. R. Baskaranassessment Year :2015-16 Shri. Joison Kundu Kulamjohny, Vs. Ito, No.11, Ephrathah Villa, 2Nd Cross, Ward – 5(3)(6), Sathya Colony, B Narayanapura Bengaluru. Dooravani Nagar, Bengaluru–560 016. Pan : Aetpj 6642 N Appellant Respondent Assessee By : Shri. Narendra Kumar Jain, Ca Revenue By : Shri. Sankar Ganesh K, Jcit(Dr)(Itat), Bengaluru. Date Of Hearing : 15.03.2022 Date Of Pronouncement : 18.03.2022 O R D E R

For Appellant: Shri. Narendra Kumar Jain, CAFor Respondent: Shri. Sankar Ganesh K, JCIT(DR)(ITAT), Bengaluru

Section 131Section 132Section 132(4)Section 143(1)Section 147Section 148Section 156Section 271(1)(c)Section 274

confirmed the order of the AO against which order of CIT(A) the assessee has preferred the present appeal before the Tribunal. 6. Before us, the learned Counsel for the assessee submitted that the case was mishandled by one Mr. Nagesh Shastry, Income Tax Practitioner, who has been indulging

M/S. Sasken Technologies Limited, Bangalore vs. Joint Commissioner of Income Tax, Special Range - 6, Bangalore

In the result, appeal of the assessee is partly allowed

ITA 2546/BANG/2019[2016-17]Status: DisposedITAT Bangalore18 Mar 2022AY 2016-17

Bench: Shri N.V. Vasudevan & Shri B. R. Baskaranassessment Year : 2016-17 M/S. Sasken Technologies Limited, Vs. Jcit, No.139/25, Ring Road, Domlur, Special Range – 6, Bengaluru-560071. Bengaluru. Pan : Aaecs 6424 R Appellant Respondent Appellant By : Shri. Padam Chand Khincha, Ca Respondent By : Shri. Sumer Singh Meena, Cit(Dr)(Itat), Bengaluru. Date Of Hearing : 09.03.2022 Date Of Pronouncement : 16.03.2022 O R D E R Per N.V. Vasudevanthis Is An Appeal By The Assessee Against The Order Dated 27.11.2019 Of Cit(A), Bengaluru -10, Relating To Assessment Year 2016-17. 2. Ground No.1 Raised By The Assessee Is General & Calls For No Specific Adjudication. Grounds Nos.2 & 3 Raised By The Assessee Is With Regard To The Issue Whether The Gain On Sale / Assignment Of Intellectual Property Rights (Ipr) Is Assessable To Tax At All & If So Assessable To Tax Whether It Has To Be Assessed To Tax Under The Head “Income From Business Or Profession” Or “Capital Gain”. Page 2 Of 31

For Appellant: Shri. Padam Chand Khincha, CAFor Respondent: Shri. Sumer Singh Meena, CIT(DR)(ITAT), Bengaluru

Section 1

business income. 17. The CIT(A)confirmed the order of the AO. Aggrieved by the order of CIT(A), the assessee is in appeal before the Tribunal. 18. The learned Counsel for the assessee submitted that the source code and technical documents in the Foreground and Background IPR constitutes

M/S Flight Raja Travels Pvt Ltd, Bangalore vs. The Assistant Commissioner of Income Tax Circle-3(1)(1), Bangalore

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

ITA 1354/BANG/2018[2013-14]Status: DisposedITAT Bangalore18 Mar 2022AY 2013-14

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

For Appellant: Smt.Sheetal Borkar, AdvocateFor Respondent: Sri.Kannan Narayanan, Addl.CIT-DR

Section 143(2)Section 37

para 4.5 of the impugned order of CIT(A)] 5. Aggrieved by the order of the CIT(A), the assessee has filed this appeal before the Tribunal. The assessee has filed a paper book comprising of 19 pages enclosing therein the financial statement of the assessee for the relevant assessment

Tech Mahindra Ltd., Mumbai vs. ACIT, Circle - 2(3)(1), Mumbai

In the result, appeal by the assessee is allowed

ITA 6573/MUM/2019[2012-13]Status: DisposedITAT Mumbai17 Mar 2022AY 2012-13

Bench: Shri Vikas Awasthy & Shri Prashant Maharishiआअसं. 6573/मुं/2019 ("न. व. 2012-13 ) Tech Mahindra Limited, Gateway Building, Apollo Bunder, Mumbai – 400 001 Pan: Aaacm-3484-F ...... अपीलाथ" /Appellant बनाम Vs. Acit, Cir. 2(3)(1), Aaykar Bhavan, M.K.Road, Mumbai 400 020 ..... ""तवाद"/Respondent अपीलाथ" "वारा/ Appellant By : Shri J.D.Mistri, Sr. Advocate ""तवाद" "वारा/Respondent By : Shri Rajesh Damor सुनवाई क" "त"थ/ Date Of Hearing : 20/12/2021 घोषणा क" "त"थ/ Date Of Pronouncement : 17/03/2022 आदेश/ Order Per Vikas Awasthy, Jm: 6573/Mum/2019 This Appeal By The Assessee Is Directed Against The Order Of Commissioner Of Income Tax(Appeals)-6, Mumbai [In Short 'The Cit(A)’] Dated 04/09/2019 For The Assessment Year 2012-13. 2. Shri J.D.Mistri, Sr.Advocate Appearing On Behalf Of The Assessee Submitted At The Outset That The Assessee Has Raised Additional Grounds Of 2 Appeal Assailing Jurisdiction Assumed By The Assessing Officer U/S. 147 Of The Income Tax Act,1961 ( In Short 'The Act') & Validity Of The Order Passed U/S. 143(3) R.W.S. 147 Of The Act. At This Stage He Would Be Confirning His Submissions On The Additional Grounds Raised.

For Appellant: Shri J.D.Mistri, Sr. AdvocateFor Respondent: Shri Rajesh Damor

Section 115JSection 143(3)Section 147Section 148Section 68

Assessment Year 2012-13. The assessee assailed reopening of assessment. After being unsuccessful before the CIT(A), the assessee carried the issue in appeal before the Tribunal in ITA No.6572/Mum/2019. The Tribunal vide order dated 18/08/2021 after examining the facts held reopening of assessment as invalid. The facts

M/S. Zion Hospitals and Research Centre Private Limited, Bengaluru vs. The Deputy Commissioner of Income Tax, Circle-7(1)(2), Bengaluru

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

ITA 448/BANG/2021[2019-20]Status: DisposedITAT Bangalore17 Mar 2022AY 2019-20

Bench: Shri. Chandra Poojari & Smt. Beena Pillaiassessment Year : 2019-20 M/S. Zion Hospitals & Research Centre Pvt. Ltd., The Deputy No. 9, “Le Villa”, Commissioner Of Kirti Layout, Income Tax, Kammanahalli Main Road, Circle – 7 [1][2], Bangalore – 560 084. Vs. Bangalore. Pan: Aaacz4369G Appellant Respondent Assessee By : Shri V. Srinivasan, Advocate : Shri Priyadarshi Mishra, Addl. Revenue By Cit (Dr) Date Of Hearing : 17-03-2022 Date Of Pronouncement : 17-03-2022 Order Per Beena Pillaipresent Appeal By The Assessee Has Been Filed By Assessee Against The Order Dated 31.08.2021 U/S. 250 Passed By The National Faceless Appeal Centre (Nfac), Delhi Relating To Assessment Year 2019-20 On Following Grounds Of Appeal: “1. The Orders Of The Authorities Below In So Far As They Are Against The Appellant Are Opposed To Law. Equity, Weight Of Evidence, Probabilities, Facts & Circumstances Of The Case. 2. The Learned Commissioner Of Income Tax [Appeals] / National Faceless Appeal Centre [Nfac For Short] Is Not Justified In Upholding The Determination Of Total Loss Of Appellant In The Intimation U/S. 143[1] Of The Act, At Rs. 63,89,502/-As Against The Returned Loss Of Rs.

For Appellant: Shri V. Srinivasan, Advocate

Section 139(1)Section 143Section 143(1)Section 234BSection 250Section 36Section 43B

relied on the amendment brought about to section 36(1)(va) and 43B of the I.T.Act. 4. Aggrieved, the assessee has filed this appeal before the Tribunal. 4.1 The Ld.AR submitted that an identical issue is decided in favour of the assessee by the coordinate Bench of this Tribunal

Jsw Steel Limited, Mumbai vs. Addlcit, Bangalore

858/M/2011

ITA 858/BANG/2011[2007-08]Status: DisposedITAT Mumbai16 Mar 2022AY 2007-08

Bench: Shri Om Prakash Kant () & Shri Amarjit Singh () Assessment Year: 2007-08 Jsw Steel Limited, The Addl. Cit, Range 11, Jindal Mansion, 5A, Vs. Bangalore. Dr. G. Deshmukh Marg, Mumbai-400026. Pan No. Aaacj 4323 N Appellant Respondent Assessment Year: 2007-08 Dc. Cc.46, M/S Jsw Steel Ltd., R.No. 659, 6Th Floor, Aayakar Vs. Jindal Mansion, 5-A, Dr. G Bhavan, M.K. Road, Deshmukh Marg, Mumbai-20. Mumbai-400026. Pan No. Aaacj 4323 N Appellant Respondent Assessment Year: 2007-08 M/S Jsw Steel Ltd., Dcit, Central Circle 46, Jsw Centre, Bandra Kurla Vs. 6Th Flr., Aayakar Bhavan, M.K. Complex, Road, Mumbai-400051. Mumbai-400020. Pan No. Aaacj 4323 N Appellant Respondent

For Appellant: Mr. Danesh Bafna &For Respondent: Mr. Achal Sharma, CIT-DR

Section 14ASection 37(1)

further appeal, the Ld. CIT(A) allowed part relief to the assessee. Aggrieved both the assessee and the Revenue are in appeal before the Tribunal raising the grounds is reproduced above. 39. In ground No. 1 (One), the assessee has challenged confirming of the addition

S N Balasubramaniya, Bangalore vs. Assistant Commissioner of Income Tax, CPC, Bangalore

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

ITA 60/BANG/2022[2019-20]Status: DisposedITAT Bangalore16 Mar 2022AY 2019-20

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

For Appellant: Sri.Sandeep C, CAFor Respondent: Sri.Kannan Narayanan., Addl.CIT-DR

Section 139(1)Section 143(1)Section 143(1)(a)Section 36Section 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

Technocon Builders, Bangalore vs. Deputy Commissioner of Income Tax, Circle-2(2)(1) Represented by Deputy Commissioner of Income Tax, CPC, Bangalore

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

ITA 59/BANG/2022[2018-19]Status: DisposedITAT Bangalore16 Mar 2022AY 2018-19

Bench: Shri. Chandra Poojari & Smt. Beena Pillaiassessment Year : 2019-20 M/S. Technocon Builders, The Deputy # 337, Sf 8, Commissioner Of Karuna Complex, Income Tax, Sampige Road, Circle - 2 (2)(1), Malleshwaram, Vs. Bangalore. Bangalore – 560 003. Pan: Aaift3196L Appellant Respondent Assessee By : Shri Rajagopal, Ca : Shri Priyadarshi Mishra, Addl. Revenue By Cit (Dr) Date Of Hearing : 16-03-2022 Date Of Pronouncement : 16-03-2022 Order Per Beena Pillaipresent Appeal By The Assessee Has Been Filed By Assessee Against The Order Dated 22.11.2021 U/S. 250 Passed By The National Faceless Appeal Centre (Nfac), Delhi Relating To Assessment Year 2019-20 On Following Grounds Of Appeal: “1. The Impugned Order Passed By The Learned Commissioner Of Income Tax (Appeals) Under Section 250 Of The Income Tax Act, 1961 To The Extent Which Is Against The Appellant Is Opposed To Law, Without Jurisdiction, Weight Of Evidence, Probabilities, Facts & Circumstances Of The Case.

For Appellant: Shri Rajagopal, CA

Section 139(1)Section 143(1)Section 250Section 30Section 32Section 36(1)(va)Section 43B

Karle Infrastructure Private Limited, Bengaluru vs. Assistant Director of Income Tax, CPC, Bangalore

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

ITA 40/BANG/2022[2019-20]Status: DisposedITAT Bangalore16 Mar 2022AY 2019-20

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

For Appellant: Smt.Suman Lunkar, CAFor Respondent: Sri.Narayana K.R., Addl.CIT-DR

Section 139(1)Section 143(1)Section 143(1)(a)Section 250Section 36(1)(va)Section 43B

M/S. Skf Technologies (India) Private Limited, Bengaluru vs. The Deputy Commissioner of Income Tax, Circle-6(1)(1), Bengaluru

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

ITA 1773/BANG/2018[2014-15]Status: DisposedITAT Bangalore16 Mar 2022AY 2014-15

Bench: Shri George George K & Ms. Padmavathy Sassessment Year : 2014-15

For Appellant: Shri K.R Vasudevan, AdvocateFor Respondent: Shri Narayana K.R, Addl.CIT(DR)

Section 143(1)Section 143(2)Section 143(3)

rest of the additions made by the AO. 4. Aggrieved by the order of the CIT(A), the assessee has filed an appeal before the Tribunal. Disallowance of product replacement (product development) expenditure (Ground 1) 5. The assessee claimed Rs.85,18,012/- under product replacement expenditure. On verification

Patel & Associates, Mumbai vs. Dy CIT -CC-7(3), Mumbai

In the result, the appeal of the assessee is partly allowed

ITA 832/MUM/2021[2017-18]Status: DisposedITAT Mumbai15 Mar 2022AY 2017-18

Bench: Shri Om Prakash Kant () & Shri Pavan Kumar Gadale () Assessment Year: 2017-18 Patel & Associates, Dcit Cc-7(3), Office No. 1, 2Nd Floor, Patel Vs. Aayakarbhavan, Bhuvan, 29 Vijay Wad, Dr Mumbai-400020. Nagindas N Shah Lane Chirasazar, Mumbai-400 002. Pan No. Aanfm 8145 P Appellant Respondent

For Appellant: Ms. AparnaSivakumar, AR

Section 139(9)Section 143(3)

ratio of loan advanced to total unsecured loan received. Aggrieved with the finding of the Ld. CIT(A), the assessee is in appeal before the Tribunal, raising the grounds as reproduced above. 3. The ground No. 1 (One)of the assessee is related to grievance that method of computation

M/S. Canadian International School Private Limited, Bengaluru vs. Assistant Commissioner of Income Tax, Circle-2(1)(1), Bangalore

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

ITA 55/BANG/2022[2019-20]Status: DisposedITAT Bangalore15 Mar 2022AY 2019-20

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year: 2019-20

For Appellant: Ms. Sunaina Bhatia, A.RFor Respondent: Smt. Priyadarshini Mishra, D.R

Section 139(1)Section 143(1)Section 36Section 36(1)(va)

sections 43B and 36(1)(va) of the Act and also following certain decisions rendered by Tribunals. Aggrieved, the assessee has filed this appeal before the tribunal. 4. The contention of the assessee was that it has remitted the employees contribution of PF & ESI before the due date prescribed

M/S. Corporation Bank, Mangaluru vs. Deputy Commissioner of Income Tax, Circle- 2(1), Mangaluru

ITA 1109/BANG/2019[2015-16]Status: DisposedITAT Bangalore15 Mar 2022AY 2015-16

Bench: Shri George George K & Ms. Padmavathy S & Ita No.1680/Bang/2018 Assessment Year : 2015-16 & 2014-15

For Appellant: Shri Ananthan, C.A &For Respondent: Shri Pradeep Kumar, CIT(DR)

Section 115JSection 143(3)Section 36(1)(vii)Section 36(1)(viia)

debited by the assessee to the P&L account. 15.3. Aggrieved by the order of the CIT(A) the assessee has filed the appeal before the Tribunal for the addition to Rs.1,28,10753/- debited by the assessee to the P&L account. 15.4. The ld.AR made the following submissions ... No.1109/Bang/2019, 1680/Bang/2018, 164/Pnj/2019 & 235/Pan/2018 Page 24 of 44 17.1. Aggrieved by the order of the CIT (A) the assessee is not in appeal before the Tribunal. 17.2. The ld.AR reiterated the submissions made before the CIT(A) whereas the ld.DR supported the claim of the lower authorities. 17.3. We have

Transact Bpo Services India Private Limited, Bengaluru vs. Deputy Commissioner of Income Tax, CPC, Bangalore

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

ITA 51/BANG/2022[2019-20]Status: DisposedITAT Bangalore14 Mar 2022AY 2019-20

Bench: Shri N.V. Vasudevan & Shri B.R. Baskaranassessment Year : 2019-20

For Appellant: Shri Mahesh, A.RFor Respondent: Shri Sankar Ganesh K., D.R

Section 139(1)Section 143(1)Section 36Section 36(1)(va)

Indauto Filters, Bengaluru vs. Deputy Commissioner of Income Tax, CPC, Bangalore

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

ITA 48/BANG/2022[2018-19]Status: DisposedITAT Bangalore14 Mar 2022AY 2018-19

Bench: Shri N.V. Vasudevan & Shri B.R. Baskaranassessment Year : 2018-19

For Appellant: Shri K. Gururaj Acharya, A.RFor Respondent: Shri Sankar Ganesh K., D.R

Section 139(1)Section 143(1)Section 36Section 36(1)(va)

Rashmi Subhash Jha, Mumbai vs. ITO-29(3)(1), Mumbai

In the result, appeal filed by the assessee is allowed

ITA 782/MUM/2021[2017-18]Status: DisposedITAT Mumbai11 Mar 2022AY 2017-18

Bench: Shri Sandeep Singh Karhail () & Shri Gagan Goyal ()

Section 139Section 142Section 143(1)Section 44ASection 80Section 90Section 90ASection 91

first appellate authority. The first appellate authority, however, upheld the order of the assessing officer. 4. Further aggrieved, the assessee is in appeal before the Tribunal. 5. The Ld.AR of the assessee before us disputed that the assessee was not a professional. The Ld.AR of the assessee pleaded that