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“Section 143(3)”

Section References (mined)Section 143Section 143(3)45,044 judgments

The decision most relied on for Section 143(3) is National Thermal Power Co. Ltd. v. CIT (229 ITR 383), cited in 5,834 judgments on BharatTax.

Leading authorities on Section 143(3)

National Thermal Power Co. Ltd. v. CIT
229 ITR 383 · 1998 · Supreme Court
5,834
citing judgments

Appellate authorities can consider new claims and additional grounds if the relevant facts are already on record. The purpose of assessment is to correctly determine tax liability, allowing both parties to raise issues.

Collector, Land Acquisition v. Mst. Katiji
167 ITR 471 · 1987 · Supreme Court
3,926
citing judgments

Delay in filing appeals, when supported by sufficient or justifiable cause, should be condoned with a liberal approach to ensure substantial justice. This principle prioritizes the cause of justice over mere technicalities.

CIT v. Kabul Chawla
380 ITR 573 · 2016 · High Court
3,235
citing judgments

In a search assessment under Section 153A, additions can only be made for completed or non-abated assessment years if incriminating material relevant to those years is found during the search, although notice under Section 153A(1) is mandatorily issued for six assessment years preceding the search.

Malabar Industrial Co. Ltd. v. CIT
243 ITR 83 · 2000 · Supreme Court
2,943
citing judgments

For revision under Section 263, the Assessing Officer's order must be both erroneous and prejudicial to the interests of the revenue; if either condition is not met, the revisionary jurisdiction cannot be invoked. An order is not erroneous merely because the Assessing Officer did not record the details of enquiries conducted, provided due enquiries were made.

CIT v. Vegetable Products Ltd.
88 ITR 192 · 1973 · Supreme Court
2,664
citing judgments

When two equally plausible interpretations of a taxing provision are possible, or when conflicting views exist from non-jurisdictional High Courts, the interpretation that favors the assessee must be adopted.

CIT v. Manjunatha Cotton & Ginning Factory
359 ITR 565 · 2013 · High Court
2,590
citing judgments

A penalty notice issued under section 274 read with section 271(1)(c) is invalid if it fails to specify whether the penalty proceedings are initiated for concealment of income or for furnishing inaccurate particulars of income. This non-specification vitiates the penalty proceedings.

Pr. CIT v. Abhisar Buildwell (P.) Ltd.
149 Taxmann.com 399 · 2023 · Supreme Court
2,379
citing judgments

An assessment under section 153A is without jurisdiction if there is an absence of incriminating material for an unabated assessment year.

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.

Judgments citing Section 143(3)

DCIT, Central Circle, Ghaziabad vs. Amrit Banaspati Company Ltd., Noida

Appeals are partly allowed in the foregoing terms

ITA 4923/DEL/2018[2010-11]Status: DisposedITAT Delhi13 Mar 2026AY 2010-11

Bench: Shri Satbeer Singh Godara & Shri M. Balaganesh

Section 143(3)Section 43(1)

Appeals) [in short, the “CIT(A)”], Meerut’s orders, all dated 06.04.2018 passed in case nos. 106/2014-15, 107/2014-15 and 108/2014-15, involving proceedings under section 143(3)/153A of the Income- tax Act, 1961 (hereinafter referred to as ‘the Act’), respectively. Heard both the parties at length. Case files perused ... Income Tax (Appeals) ['CIT(A)'] erred on facts and in law in upholding the validity of the assessment order dated 30.03.2014 passed under section 143(3)/153A of the Income Tax Act, 1961 ('the Act'). 1.1 That the CIT(A) erred on facts and in law in not appreciating that

Amrit Banaspati Company Ltd., Noida vs. DCIT, Central Circle, Ghaziabad

Appeals are partly allowed in the foregoing terms

ITA 3434/DEL/2018[2012-13]Status: DisposedITAT Delhi13 Mar 2026AY 2012-13

Bench: Shri Satbeer Singh Godara & Shri M. Balaganesh

Section 143(3)Section 43(1)

Appeals) [in short, the “CIT(A)”], Meerut’s orders, all dated 06.04.2018 passed in case nos. 106/2014-15, 107/2014-15 and 108/2014-15, involving proceedings under section 143(3)/153A of the Income- tax Act, 1961 (hereinafter referred to as ‘the Act’), respectively. Heard both the parties at length. Case files perused ... Income Tax (Appeals) ['CIT(A)'] erred on facts and in law in upholding the validity of the assessment order dated 30.03.2014 passed under section 143(3)/153A of the Income Tax Act, 1961 ('the Act'). 1.1 That the CIT(A) erred on facts and in law in not appreciating that

Amrit Banaspati Company Ltd., Noida vs. DCIT, Central Circle, Ghaziabad

Appeals are partly allowed in the foregoing terms

ITA 3433/DEL/2018[2011-12]Status: DisposedITAT Delhi13 Mar 2026AY 2011-12

Bench: Shri Satbeer Singh Godara & Shri M. Balaganesh

Section 143(3)Section 43(1)

Appeals) [in short, the “CIT(A)”], Meerut’s orders, all dated 06.04.2018 passed in case nos. 106/2014-15, 107/2014-15 and 108/2014-15, involving proceedings under section 143(3)/153A of the Income- tax Act, 1961 (hereinafter referred to as ‘the Act’), respectively. Heard both the parties at length. Case files perused ... Income Tax (Appeals) ['CIT(A)'] erred on facts and in law in upholding the validity of the assessment order dated 30.03.2014 passed under section 143(3)/153A of the Income Tax Act, 1961 ('the Act'). 1.1 That the CIT(A) erred on facts and in law in not appreciating that

Amrit Banaspati Company Ltd., Noida vs. DCIT, Central Circle, Ghaziabad

Appeals are partly allowed in the foregoing terms

ITA 3432/DEL/2018[2010-11]Status: DisposedITAT Delhi13 Mar 2026AY 2010-11

Bench: Shri Satbeer Singh Godara & Shri M. Balaganesh

Section 143(3)Section 43(1)

Appeals) [in short, the “CIT(A)”], Meerut’s orders, all dated 06.04.2018 passed in case nos. 106/2014-15, 107/2014-15 and 108/2014-15, involving proceedings under section 143(3)/153A of the Income- tax Act, 1961 (hereinafter referred to as ‘the Act’), respectively. Heard both the parties at length. Case files perused ... Income Tax (Appeals) ['CIT(A)'] erred on facts and in law in upholding the validity of the assessment order dated 30.03.2014 passed under section 143(3)/153A of the Income Tax Act, 1961 ('the Act'). 1.1 That the CIT(A) erred on facts and in law in not appreciating that

Shanti Devi Jain Memorial Trust, Muzaffarnagar vs. ITO, Ward Exemption, Ghaziabad

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

ITA 1293/DEL/2018[2013-14]Status: DisposedITAT Delhi13 Mar 2026AY 2013-14

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandraassessment Years: 2013-14

Section 11(5)Section 12ASection 143(3)Section 234ASection 250(6)Section 80G

Assessment Year 2013-14. The assessment order in this appeal is passed by the Assessing Officer [for short, AO] under section 143(3) of the Act. 2. The assessee has raised following grounds of appeal:- M/s Shanti Devi Jain Memorial Trust 1. That the assessment order passed U/s 143(3

The Bank of Tokyo Mitsubishi Ufj, New Delhi vs. DCIT, Circle- 3(1)(1), International Taxation, New Delhi

ITA 7212/DEL/2017[2013-14]Status: DisposedITAT Delhi13 Mar 2026AY 2013-14

Bench: Vikas Awasthy & Shri Brajesh Kumar Singh

Section 143(2)Section 143(3)Section 144Section 144C(5)Section 44C

ITA No.- 7212/Del/2017 The Bank of Tokyo Mitsubishi UFJ Ltd. IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH, D: NEW

Kunwar Pranav Singh Champion, Roorkee vs. Income Tax Officer, Roorkee

In the result, the captioned appeals of the assessee in ITA No

ITA 41/DDN/2026[2020-21]Status: DisposedITAT Dehradun12 Mar 2026AY 2020-21

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal

Section 143(3)Section 250Section 271ASection 68

IN THE INCOME TAX APPELLATE TRIBUNAL DEHRADUN “DB” BENCH: DEHRADUN BEFORE SHRI YOGESH KUMAR U.S., JUDICIAL MEMBER & SHRI MANISH AGARWAL

Kunwar Pranav Singh Champion, Roorkee vs. Income Tax Officer, Roorkee

In the result, the captioned appeals of the assessee in ITA No

ITA 40/DDN/2026[2020-21]Status: DisposedITAT Dehradun12 Mar 2026AY 2020-21

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal

Section 143(3)Section 250Section 271ASection 68

IN THE INCOME TAX APPELLATE TRIBUNAL DEHRADUN “DB” BENCH: DEHRADUN BEFORE SHRI YOGESH KUMAR U.S., JUDICIAL MEMBER & SHRI MANISH AGARWAL

Soban Singh, Dehradun, Uttrakhand vs. DCIT Circle 1(1)(1), Dehradun, Uttrakhand

In the result, the appeal of the assessee is allowed

ITA 26/DDN/2026[2022-23]Status: DisposedITAT Dehradun12 Mar 2026AY 2022-23

Bench: Shri Mahavir Singh & Shri Manish Agarwal[Assessment Year : 2022-23] Soban Singh, Vs Dcit Anand Nagar, Balawala Circle-1(1)(1) Dehradun, Uttarakhand Dehradun Pan-Djfps8212B Uttarakhand Appellant Respondent Appellant By Shri Abhinav Vijh, Ca Respondent By Ms. Poonam Sharma, Cit Dr Date Of Hearing 10.03.2026 Date Of Pronouncement 12.03.2026 Order Per Manish Agarwal, Am : The Present Appeal Is Filed By Assessee Against The Order Dated 03.12.2025 By Ld. Commissioner Of Income Tax (A), Nfac, Delhi [“Ld.Cit(A)”] In Appeal No.Nfac/2021-22/10363960 Passed U/S 250 Of The Income Tax Act, 1961 [“The Act”] Arising Out Of Assessment Order Dated 25.03.2024 Passed U/S 143(3) R.W.S. 144B Of The Act Pertaining To Assessment Year 2022-23. 2. Heard The Contentions Of Both The Parties At Length & Perused The Material Available On Record. From The Perusal Of The Table Reproduced At Page 12 Of Ld. Cit(A)’S Order Containing The Party-Wise Details Of Rent Paid During The Previous Year, It Is Observed That Assessee Had Paid Rent To Total Six Parties In Cash Every Month & The Payment Made To Each Individual Owner Was Below The Maximum Limit Prescribed U/S 40A(3) Of The Act Of Inr 10,000/-. The Ao Has Wrongly Considered The Gross Amount Of Rent Paid To All The Landlords As In Violation Of Provision Of Section 40A(3) Of The Act. Since The Rent Paid To Each Individual Land Owner Was Below Inr 10,000/- On Each Occasion, Therefore, Provision Of Section 40A(3) Are Not Applicable. Accordingly, No Disallowance Is Required To Be Made U/S 40A(3) Of The Act. In The Light Of Above Facts, We Delete The Disallowance Made By The Ao. All The Grounds Of Appeal Taken By The Assessee Are Allowed.

Section 143(3)Section 250Section 40A(3)

IN THE INCOME TAX APPELLATE TRIBUNAL DEHRADUN “SMC” BENCH: DEHRADUN BEFORE SHRI MAHAVIR SINGH, VICE PRESIDENT & SHRI MANISH AGARWAL, ACCOUNTANT

Davinder Kumar Mago, Punjabi Bagh vs. DCIT/ACIT Central Circle, Ddn, Dehradun

In the result appeal of the assessee is allowed

ITA 17/DDN/2026[2019-20]Status: DisposedITAT Dehradun12 Mar 2026AY 2019-20

Bench: Shri Mahavir Singh & Shri Manish Agarwal[Assessment Year : 2019-20] Davinder Kumar Mago Vs Dcit/Acit 12/1, Punjabi Bagh, Central Circle, External Punjabi Bagh, Dehradun New Delhi-110026 Uttarakhand Pan-Ajhpm9802A Appellant Respondent Appellant By Shri Ajay Wadhwa, Adv. (Vc) Respondent By Ms. Poonam Sharma, Cit Dr Date Of Hearing 10.03.2026 Date Of Pronouncement 12.03.2026 Order Per Manish Agarwal, Am : This Appeal Filed By The Assessee Against The Order By Pr.Cit (Central), Kanpur At Meerut Passed U/S 263 Of The Income Tax Act, 1861 (“The Act”) Dated 08.01.2026 Arising Out Of The Order Passed U/S 143(3) R.W.S. 147 Of The Act.

Section 142(1)Section 143(3)Section 147Section 263

IN THE INCOME TAX APPELLATE TRIBUNAL DEHRADUN “DB” BENCH: DEHRADUN BEFORE SHRI MAHAVIR SINGH, VICE PRESIDENT & SHRI MANISH AGARWAL, ACCOUNTANT

Sanjay Naithani, Kotdwar vs. Income Tax Officer, Assessment Unit

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

ITA 260/DDN/2025[2023-2024]Status: DisposedITAT Dehradun12 Mar 2026AY 2023-2024

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal[Assessment Year : 2023-24] Sanjay Naithani Vs Ito Kalalghati, Uday Rampur, Kotdwar, Pauri Pauri, Uttarakhand Uttarakhand Pan-Anwpn8086E Appellant Respondent Appellant By None Respondent By Ms. Poonam Sharma, Cit Dr Date Of Hearing 11.03.2026 Date Of Pronouncement 12.03.2026 Order Per Bench: The Present Appeal Is Filed By Assessee Against The Order Dated 13.10.2025 Passed By Ld. Commissioner Of Income Tax (A), Nfac, Delhi [“Ld. Cit(A)”] Passed U/S 250 Of The Income Tax Act, 1961 [“The Act”] Arising Out Of Assessment Order Dated 03.03.2025 Passed U/S 143(3) R.W.S. 144B Of The Act Pertaining To Assessment Year 2023- 24. 2. At The Time Of Hearing, No One Appeared On Behalf Of The Assessee. Therefore, The Appeal Of The Assessee Is Taken For Hearing In The Absence Of The Ld.Ar & On The Basis Of Material Available On Record. 3. On The Other Hand, Ld. Cit Dr Vehemently Supported The Orders Of The Lower Authorities.

Section 143(3)Section 250

IN THE INCOME TAX APPELLATE TRIBUNAL DEHRADUN CIRCUIT BENCH: DEHRADUN BEFORE SHRI YOGESH KUMAR U.S., JUDICIAL MEMBER & SHRI MANISH AGARWAL

Rajkamal Agnihotri, Dehradun vs. Income Tax Officer, Dehradun

In the result, the appeal of the assessee is allowed

ITA 240/DDN/2025[2022-23]Status: DisposedITAT Dehradun12 Mar 2026AY 2022-23

Bench: Shri Mahavir Singh & Shri Manish Agarwal[Assessment Year : 2022-23] Rajkamal Agnihotri Vs Ito Shivalik View, Lane No.3, Ward-1(1)(3) Jogiala, Ring Road, Dehradun Nathanpur, Dehradun Uttarakhand Uttarakhand -248005 Pan-Amqpa2608G Appellant Respondent Appellant By Shri K. K. Juneja, Adv. Respondent By Ms. Poonam Sharma, Cit Dr Date Of Hearing 10.03.2026 Date Of Pronouncement 12.03.2026 Order Per Manish Agarwal, Am : The Present Appeal Is Filed By Assessee Against The Order Dated 06.11.2025 By Ld. Commissioner Of Income Tax (A), Nfac, Delhi [“Ld. Cit(A)”] In Appeal No. Nfac/2021-22/10408670 Passed U/S 250 Of The Income Tax Act, 1961 [“The Act”] Arising Out Of Assessment Order Dated 14.03.2024 Passed U/S 143(3) R.W.S. 144B Of The Act Pertaining To Assessment Year 2022-23. 2. Brief Facts Of The Case Are That Assessee Is An Individual & Filed His Return Of Income On 28.07.2022, Declaring Total Income Of Inr 4,89,260/-. The Return Was Updated On 11.09.2023 U/S 139(8A) Of The Act, Declaring Total Income Of Inr 73,92,200/- & Paid The Taxes Alongwith The Interest Thereon. The Case Of The Assessee Was Selected For Scrutiny On The Ground That No Capital Gain Was Reported In Itr Though The Assessee Has Sold The Property Thereafter, The Assessment Was Completed U/S 143(3)/144B Of The Act Dated 14.03.2024 Wherein Income Declared In The Updated Return Filed U/S 139(8A) Of The Act Was Accepted However, Penalty Proceedings U/S 270A(1) R.W.S. 270A(8) & 270A(9)(A) Of The Act Were Initiated. The Ao Thereafter, Proceeded With Pending Penalty Proceedings & Imposed The Penalty In Terms Of The Order Dated 14.03.2024 Imposing The Penalty Of Inr 31,58,542/- U/S 270A Of The Act.

Section 139Section 143(2)Section 143(3)Section 19Section 250Section 270Section 270ASection 270A(1)Section 9

IN THE INCOME TAX APPELLATE TRIBUNAL DEHRADUN “DB” BENCH: DEHRADUN BEFORE SHRI MAHAVIR SINGH, VICE PRESIDENT & SHRI MANISH AGARWAL, ACCOUNTANT

Grand Legacy, Dehradun vs. DCIT Circle 1, Dehradun

In the result, the appeal of the assessee is allowed

ITA 229/DDN/2025[2018-19]Status: DisposedITAT Dehradun12 Mar 2026AY 2018-19

Bench: Shri Mahavir Singh & Shri Manish Agarwal[Assessment Year : 2018-19] Grand Legacy Vs Dcit Khasra No.384 Min/New Circle-1, No.642K, Dehra Khas Dehradun Adjoining Lal Pul Patel Uttarakhand Nagar, Dehradun Uttarakhand -248001 Pan-Aaifg4885D Appellant Respondent Appellant By Shri Rajan Malik & Shri A.K. Kashyap Respondent By Ms. Poonam Sharma, Cit Dr Date Of Hearing 10.03.2026 Date Of Pronouncement 12.03.2026 Order Per Manish Agarwal, Am : The Present Appeal Is Filed By Assessee Against The Order Dated 19.09.2025 By Ld. Commissioner Of Income Tax (A), Nfac, Delhi [“Ld. Cit(A)”] In Appeal No. Nfac/2017-18/10101141 Passed U/S 250 Of The Income Tax Act, 1961 [“The Act”] Arising Out Of Assessment Order Dated 26.03.2021 Passed U/S 143(3) R.W.S. 143(3A) & 143(3B) Of The Act Pertaining To Assessment Year 2018-19. 2. Brief Facts Of The Case Are That Assessee Had Claimed Deduction U/S 80-Ic Of The Act Which Was Disallowed By The Ao For The Reason That The Assessee Has Not Fulfilled The Conditions Prescribed For Claiming Said Deduction & Initiated The Penalty Proceedings U/S 271A For Under Reporting As A Consequence Of Mis-Reporting Of Income. Thereafter, Ao Levied Penalty U/S 271A Of The Act Of Inr 67,820/- For Under Reporting By Invoking Clause (E) Of Sub-Section (9) Of Section 270A Of The Act.

Section 143(3)Section 250Section 270ASection 271ASection 274Section 80Section 80I

IN THE INCOME TAX APPELLATE TRIBUNAL DEHRADUN “DB” BENCH: DEHRADUN BEFORE SHRI MAHAVIR SINGH, VICE PRESIDENT & SHRI MANISH AGARWAL, ACCOUNTANT

Pal Mineral Industries (P) Limited, Haldwani vs. Dc/ACIT, Central Circle, Haldwani

ITA 106/DDN/2025[2013-2014]Status: DisposedITAT Dehradun12 Mar 2026AY 2013-2014

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal

Section 143(3)Section 153ASection 153CSection 250

IN THE INCOME TAX APPELLATE TRIBUNAL DEHRADUN “DB” BENCH: DEHRADUN BEFORE SHRI YOGESH KUMAR U.S., JUDICIAL MEMBER & SHRI MANISH AGARWAL

Pal Mineral Industries (P) Limited, Haldwani vs. Dc/ACIT, Central Circle, Haldwani

ITA 105/DDN/2025[2014-2015]Status: DisposedITAT Dehradun12 Mar 2026AY 2014-2015

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal

Section 143(3)Section 153ASection 153CSection 250

IN THE INCOME TAX APPELLATE TRIBUNAL DEHRADUN “DB” BENCH: DEHRADUN BEFORE SHRI YOGESH KUMAR U.S., JUDICIAL MEMBER & SHRI MANISH AGARWAL

Mohan Pal, Haldwani, Nainital vs. Assistant Commissioner of Income Tax, Central Circle, Haldwani, ACIT - DCIT

ITA 85/DDN/2024[2015-16]Status: DisposedITAT Dehradun12 Mar 2026AY 2015-16

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal

Section 132Section 143(3)Section 153ASection 153A(1)Section 153CSection 250

IN THE INCOME TAX APPELLATE TRIBUNAL DEHRADUN “DB” BENCH: DEHRADUN BEFORE SHRI YOGESH KUMAR U.S., JUDICIAL MEMBER & SHRI MANISH AGARWAL

Mohan Pal, Haldwani, Nainital vs. Assistant Commissioner of Income Tax, Central Circle, Haldwani, ACIT - DCIT

ITA 84/DDN/2024[2014-15]Status: DisposedITAT Dehradun12 Mar 2026AY 2014-15

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal

Section 132Section 143(3)Section 153ASection 153A(1)Section 153CSection 250

IN THE INCOME TAX APPELLATE TRIBUNAL DEHRADUN “DB” BENCH: DEHRADUN BEFORE SHRI YOGESH KUMAR U.S., JUDICIAL MEMBER & SHRI MANISH AGARWAL

Mohan Pal, Haldwani, Nainital vs. Assistant Commissioner of Income Tax, Central Circle, Haldwani, ACIT-DCIT

ITA 83/DDN/2024[2013-14]Status: DisposedITAT Dehradun12 Mar 2026AY 2013-14

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal

Section 132Section 143(3)Section 153ASection 153A(1)Section 153CSection 250

IN THE INCOME TAX APPELLATE TRIBUNAL DEHRADUN “DB” BENCH: DEHRADUN BEFORE SHRI YOGESH KUMAR U.S., JUDICIAL MEMBER & SHRI MANISH AGARWAL

ITO, Ward- 2(5), Dehradun vs. Uttrakhand Poorv Sainik Kalyan Nigam Ltd., Dehradun

In the result, the appeal of the Revenue is dismissed

ITA 3023/DEL/2018[2013-14]Status: DisposedITAT Dehradun12 Mar 2026AY 2013-14

Bench: SHRI MAHAVIR SINGH (Vice President), SHRI MANISH AGARWAL (Accountant Member)

Section 10Section 143(3)Section 158ASection 250Section 271(1)(c)

IN THE INCOME TAX APPELLATE TRIBUNAL DEHRADUN “DB” BENCH: DEHRADUN BEFORE SHRI MAHAVIR SINGH, VICE PRESIDENT & SHRI MANISH AGARWAL, ACCOUNTANT

Awla Infra, Ferozepur vs. Assitant Commissioner of Income Tax Circle, Ferozepur

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

ITA 53/ASR/2025[2014-15]Status: DisposedITAT Amritsar12 Mar 2026AY 2014-15

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta

For Appellant: Sh. Ashray Sarna, C. A
Section 143(3)Section 250Section 271(1)(b)

IN THE INCOME TAX APPELLATE TRIBUNAL AMRITSAR BENCH, AMRITSAR (PHYSICAL HEARING) BEFORE SH. MANOJ KUMAR AGGARWAL, ACCOUNTANT MEMBER AND SH