“Section 143(1)”

Section References (mined)Section 143Section 143(1)13,466 judgments

The decision most relied on for Section 143(1) is Collector, Land Acquisition v. Mst. Katiji (167 ITR 471), cited in 3,926 judgments on BharatTax.

Leading authorities on Section 143(1)

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. 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.

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.

CIT v. Reliance Petroproducts Pvt. Ltd.

322 ITR 158 · 2010 · Supreme Court

2,228

citing judgments

Penalty under Section 271(1)(c) for furnishing inaccurate particulars or concealment of income is not automatically leviable if the assessee has made a full disclosure of all particulars and the addition or disallowance arises from a difference of opinion.

CIT v. Reliance Utilities & Power Ltd.

313 ITR 340 · 2009 · High Court

2,118

citing judgments

Where an assessee claims that investments were made out of own funds, interest disallowance under Section 14A read with Rule 8D may not apply if the assessee demonstrates the availability of sufficient interest-free funds to cover such investments.

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.

Judgments citing Section 143(1)

Assistant Commissioner of Income Tax, Central Circle2, 4 Mumbai, Mumbai vs. Jyothy Labs Limited, Mumbai

In the result, the captioned appeals by the revenue are partly allowed and cross-objections are allowed in part for statistical purposes

ITA 3884/MUM/2025[2017-18]Status: DisposedITAT Mumbai06 Aug 2025AY 2017-18

Bench: Shri Saktijit Dey, Hon’Ble & Shri Narendra Kumar Billaiya, Hon’Ble

For Appellant: Shri J D Mistri, A/RFor Respondent: Shri Vivek Perampurna, CIT D/R

Section 131Section 133ASection 143(2)Section 80I

claim for deduction has been withdrawn in the initial year when deduction was claimed and allowed unlike an assessment which iscompleted under Section 143(1) of the Act. We have perused the decision of this Court in Dinshaw Frozen Food Ltd. Nagpur (supra) which in turn has followed the decision

Assistant Commissioner of Income Tax, Central Circle2, 4 Mumbai, Mumbai vs. Jyothy Labs Limited, Mumbai

In the result, the captioned appeals by the revenue are partly allowed and cross-objections are allowed in part for statistical purposes

ITA 3883/MUM/2025[2021-22]Status: DisposedITAT Mumbai06 Aug 2025AY 2021-22

Bench: Shri Saktijit Dey, Hon’Ble & Shri Narendra Kumar Billaiya, Hon’Ble

For Appellant: Shri J D Mistri, A/RFor Respondent: Shri Vivek Perampurna, CIT D/R

Section 131Section 133ASection 143(2)Section 80I

Assistant Commissioner of Income Tax, Central Circle2, 4 Mumbai, Mumbai vs. Jyothy Labs Limited, Mumbai

In the result, the captioned appeals by the revenue are partly allowed and cross-objections are allowed in part for statistical purposes

ITA 3882/MUM/2025[2023-24]Status: DisposedITAT Mumbai06 Aug 2025AY 2023-24

Bench: Shri Saktijit Dey, Hon’Ble & Shri Narendra Kumar Billaiya, Hon’Ble

For Appellant: Shri J D Mistri, A/RFor Respondent: Shri Vivek Perampurna, CIT D/R

Section 131Section 133ASection 143(2)Section 80I

Assistant Commissioner of Income Tax, Central Circle2, 4 Mumbai, Mumbai vs. Jyothy Labs Limited, Mumbai

In the result, the captioned appeals by the revenue are partly allowed and cross-objections are allowed in part for statistical purposes

ITA 3881/MUM/2025[2022-23]Status: DisposedITAT Mumbai06 Aug 2025AY 2022-23

Bench: Shri Saktijit Dey, Hon’Ble & Shri Narendra Kumar Billaiya, Hon’Ble

For Appellant: Shri J D Mistri, A/RFor Respondent: Shri Vivek Perampurna, CIT D/R

Section 131Section 133ASection 143(2)Section 80I

Assistant Commissioner of Income Tax, Central Circle2, 4 Mumbai, Mumbai vs. Jyothy Labs Limited, Mumbai

In the result, the captioned appeals by the revenue are partly allowed and cross-objections are allowed in part for statistical purposes

ITA 3880/MUM/2025[2020-21]Status: DisposedITAT Mumbai06 Aug 2025AY 2020-21

Bench: Shri Saktijit Dey, Hon’Ble & Shri Narendra Kumar Billaiya, Hon’Ble

For Appellant: Shri J D Mistri, A/RFor Respondent: Shri Vivek Perampurna, CIT D/R

Section 131Section 133ASection 143(2)Section 80I

Asst.Commissioner of Income Taxcentral Circle-2(4), Mumbai vs. Jyothy Labs Limited, Mumbai

In the result, the captioned appeals by the revenue are partly allowed and cross-objections are allowed in part for statistical purposes

ITA 3879/MUM/2025[2019-20]Status: DisposedITAT Mumbai06 Aug 2025AY 2019-20

Bench: Shri Saktijit Dey, Hon’Ble & Shri Narendra Kumar Billaiya, Hon’Ble

For Appellant: Shri J D Mistri, A/RFor Respondent: Shri Vivek Perampurna, CIT D/R

Section 131Section 133ASection 143(2)Section 80I

Asst. Commissioner of Income Tax, Central Circle-2(4), Mumbai vs. Jyothy Labs Limited, Mumbai

In the result, the captioned appeals by the revenue are partly allowed and cross-objections are allowed in part for statistical purposes

ITA 3863/MUM/2025[2016-17]Status: DisposedITAT Mumbai06 Aug 2025AY 2016-17

Bench: Shri Saktijit Dey, Hon’Ble & Shri Narendra Kumar Billaiya, Hon’Ble

For Appellant: Shri J D Mistri, A/RFor Respondent: Shri Vivek Perampurna, CIT D/R

Section 131Section 133ASection 143(2)Section 80I

Tmt Employees Co Operative Credit Society Limited, Mumbai vs. Principal Commissioner of Income Tax -1, Thane

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

ITA 3591/MUM/2025[2020-21]Status: DisposedITAT Mumbai06 Aug 2025AY 2020-21

Bench: Shri Anikesh Banerjee & Shri Prabhash Shankartmt Employees Co-Operative Vs Pcit, Thane-1 B Wing, Ashar It Park, 6Th Floor, Credit Society Ltd, Shop No.10, Prashaskiya Road No.16Z, Wagle Industrial Bhavan, Then M P (Tmt) Estate, Thane (West)-400 604 Employees Ccs, Wagle Estate, Wagle Aagar, Mumbai-400 604 Pan: Aaeat4545J Applicant Respondent

For Appellant: Shri Venugopal Nair, CAFor Respondent: Shri Ritesh Mishra, CIT DR

Section 143(1)Section 143(3)Section 144BSection 263Section 80PSection 80P(2)(d)

society and has filed the return of income for impugned assessment year admitting taxable income at Nil. The return was processed under section 143(1) of the Act. Subsequently, the case was selected for complete scrutiny under CASS to verify – (i) High creditors / liabilities; and (ii) deduction from Total Income

Jubilant Foodworks Limited, Noida vs. Assistant Commissioner of Income Tax, Noida

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

ITA 184/DEL/2025[2022-23]Status: DisposedITAT Delhi06 Aug 2025AY 2022-23

Bench: Sh. M. Balaganesh & Sh. Sudhir Kumarassessment Year: 2022-23 Jubilant Food Works Vs. Assistant Commissioner Of Limited Plot No. 1A Sector Income Tax, Circle – 5 (1) 16 A Gautam Buddha Nagar (1), Noida Uttar Pradesh 201301 Pan No. Aabcd 1821 C (Appellant) (Respondent) Appellant By Sh. K M Gupta, Advocate Ms. Shruti Khimata, Ca Respondent By Sh. Jitender Singh, Cit Dr

Section 139(1)Section 139(5)Section 143(1)Section 80Section 80ASection 80J

vide order dated 18.11.2024 pertaining to A.Y. 2022-23 arising out the assessment order dated 24-08-2023 under section 143(1) of the Income Tax Act, 1961, (in short ‘the Act’). 2. The assessee has raised the following grounds in appeal: 1. On the facts and circumstances ... belated one. This is mechanical exercise and one that can be carried out by the CPC, very much within the scope of section 143(1)(a)(ii) of the Act." 10. We have heard the parties and gone through the material available on record. In the instant case the report

Sara International Private Limited, New Delhi vs. ACIT Circle 22(1), New Delhi

ITA 533/DEL/2024[2016-17]Status: DisposedITAT Delhi06 Aug 2025AY 2016-17

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahman

For Appellant: Shri Salil Kapoor, AdvocateFor Respondent: Shri Manish Gupta, Sr. DR

Section 115JSection 143(1)Section 143(2)

short 'the Act') on the income of Rs.2,37,67,603/-. The case of the assessee was processed under section 143(1) on 08.12.2016 accepting the returned income. The case of the assessee was selected for scrutiny under CASS and accordingly notices u/s 143(2) and 142(1) were issued

Bharat Jain, Sarita Vihar, New Delhi vs. AO/ADIT-CPC Bengaluru, Civic Centre, New Delhi

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

ITA 4986/DEL/2024[2020-21]Status: DisposedITAT Delhi06 Aug 2025AY 2020-21

Bench: Shri Satbeer Singh Godara & Shri S.Rifaur Rahmanbharat Jain, Vs. Adit – Cpc, Flat No.133, Pocket G, Sfs Flats, Bengaluru. Maharaja Agarsen Marg, Sarita Vihar, New Delhi – 110 076. (Pan : Aaapj4180E) (Appellant) (Respondent) Assessee By : Shri Nitin Kanwar, Advocate Shri Shivam Jain, Advocate Shri Rajiv Kumar, Advocate Revenue By : Shri Ramesh Chand, Sr. Dr Date Of Hearing : 14.05.2024 Date Of Order : 06.08.2024 O R D E R Per S.Rifaur Rahman: 1. This Appeal Has Been Filed By The Assessee Against The Order Of Ld. Commissioner Of Income Tax (Appeals)/National Faceless Appeal Centre (Nfac) [“Ld. Cit(A)”, For Short] Dated 28.08.2024 For The Assessment Year 2020-21. 2. At The Time Of Hearing, Ld. Ar Of The Assessee Brought To Our Notice Return Of Income Filed By The Assessee For The Ay 2020-21 Wherein The Status Of 2 The Assessee Was Clearly Mentioned As Non-Resident As Residential Status Of The Assessee In Itr 3 Filed On 16.12.2020 With The Acknowledgement No.826193800161220. With The Above Facts On Record, He Submitted That The Authorities Below Proceeded To Apply The Provisions Of Section 44Ada Of The Income-Tax Act, 1961 (For Short ‘The Act’) For The Reason That Assessee Has Not Maintained Proper Books Of Account For Carrying On The Professional Activities, Therefore, They Applied The Presumptive Tax @ 50%. He Submitted That Provisions Of Section 44Ada Are Not Applicable To The Non-Resident & It Was Wrongly Applied In Assessee’S Case. He Further Submitted That The Ld. Cit (A) Dismissed The Appeal By Observing As Under:-

For Appellant: Shri Nitin Kanwar, AdvocateFor Respondent: Shri Ramesh Chand, Sr. DR

Section 143(1)Section 154Section 30Section 44A

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘A’: NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER and SHRI

Devinder Singh, Gurugram vs. ITO, Circle 1(1), Gurugram

In the result, appeal of the assessee is allowed

ITA 4782/DEL/2024[2018-19]Status: DisposedITAT Delhi06 Aug 2025AY 2018-19

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

Section 10(37)Section 142(1)Section 143Section 143(1)(a)Section 143(2)Section 143(3)Section 263Section 28Section 56(2)(viti)Section 57

individual. He filed his return for AY 2018-19 on 29.08.2018 declaring income of Rs. 6,35,470/-. His return was processed under section 143(1)(a) on 28.06.2019. His case was selected for complete scrutiny assessment under the e- assessment Scheme, 2019 on two issues, namely refund claim ... income from other sources and claimed deduction for 50% as per section 57(iv) of the 1961 Act. The return was processed under section 143(1) of the Act. An application under section 264 was made claiming that by mistake the assessee treated the interest income as income from other

Deputy Commissioner of Income Tax, New Delhi vs. Adaab Hotels Ltd, Delhi

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

ITA 4677/DEL/2024[2017-18]Status: DisposedITAT Delhi06 Aug 2025AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahmandcit, Vs. Adaab Hotels Limited, New Delhi. 81, Adchini, Sr. Aurobindo Marg, Delhi – 110 016. (Pan : Aabca0850G) (Appellant) (Respondent) Assessee By : Shri Ankit Kumar, Advocate Shri Parth Singhal, Advocate Revenue By : Shri Ramesh Chand, Sr. Dr Date Of Hearing : 13.05.2025 Date Of Order : 06.08.2025 O R D E R Per S.Rifaur Rahman: 1. This Appeal Is Filed By The Assessee Against The Order Of Ld. Commissioner Of Income-Tax (Appeals)/National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As ‘Ld. Cit (A)] Dated 09.08.2024 For Assessment Year 2017-18 Raising Following Grounds Of Appeal :- “1. On The Facts & In The Circumstances Of The Case, The Ld. Cit(A) Has Erred In Deleting The Addition Of Rs 1,70,52,504/- Made U/S 68 Of The Act Without Appreciating The Fact That The Assessee Company Has Failed To Produce The Relevant Document As Required By The Assessing Officer During The Assessment Proceedings. 2. On The Facts & In The Circumstances Of The Case, The Ld. Cit(A) Has Erred In Deleting The Addition Of Rs.1,70,52,504/- Made U/S 68 Of The Act By Ao, On The Basis Of Fresh/New Evidences Produced By The Assessee During The Appellate Proceedings Without Appreciating The Facts That The Assessee Has Failed To Produce

For Appellant: Shri Ankit Kumar, AdvocateFor Respondent: Shri Ramesh Chand, Sr. DR

Section 143(1)Section 68

demonetization period, the assessee had deposited cash to the extent of Rs.170,52,504/- in its various bank accounts. Accordingly, notices under section 143(1) and 142(1) of the Income-tax Act, 1961 (for short ‘the Act’) were issued and served on the assessee directing the assessee to submit

Mahesh Kumar, Delhi vs. ITO, Ward-68(6), Delhi

In the result, Ground no. 3 as raised by the assessee deserves to be allowed and the impugned addition cannot be sustained

ITA 2650/DEL/2024[2012-13]Status: DisposedITAT Delhi06 Aug 2025AY 2012-13

Bench: Justice (Retd.) C.V. Bhadang(), Shri Mahavir Singh & Shri Brajesh Kumar Singh[Assessment Year: 2012-13] Mahesh Kumar, Vs Ito, 6/305/1A, Doonger Ward-68(6), Mohalla, Delhi-110032. Delhi. Pan-Aoopk6335A Appellant Respondent Appellant By Shri Neeraj Mangla, Ca Respondent By Shri Krishna K. Ramawat, Sr. Dr Date Of Hearing 06.08.2025 Date Of Pronouncement 06.08.2025

Section 10(38)Section 143(3)Section 147Section 148Section 68

Return of Income (RoI) for assessment year 2012-13 on 18.06.2012 declaring an income of Rs.2,07,380/-, which was processed under Section 143(1) of the Act. There was no regular assessment under Section 143(3) of the Act made in this case. It appears that the assessment

Ultra Modern Exports Pvt. Ltd., New Delhi vs. ITO Ward - 27(1), New Delhi

ITA 527/DEL/2020[2011-12]Status: DisposedITAT Delhi06 Aug 2025AY 2011-12

Bench: Shri Vikas Awasthy & Shri M. Balaganesh

For Appellant: Shri S. K. Tulsiyan, AdvFor Respondent: Shri Om Prakash, Sr. DR

Section 143(1)Section 143(3)Section 147Section 148Section 68

also had shown income from short term capital gains amounting to Rs 1,39,060/-. This return was duly processed under section 143(1) of the Act on 30-1-2012. No regular assessment under section 143(3) of the Act was made on this return. 5. Based

ACIT Central Circle16, New Delhi vs. Krishna Dal Mill Pvt Ltd, New Delhi

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

ITA 1737/DEL/2020[2014-15]Status: DisposedITAT Delhi06 Aug 2025AY 2014-15

Bench: Shri Vikas Awasthy & Shri M. Balaganeshacit, Vs. M/S. Krishna Dal Mill Pvt. Ltd, Central Circle-16, C-19, Lawarance Road, New Delhi Pitampura, North West Delhi, Delhi-110035 (Appellant) (Respondent) Pan: Aaack0099E Assessee By : Shri Satyen Sethi, Adv Shri A. T. Panda, Ms. Gargi Sethi, Adv Shri Nirbhay Mehta, Adv Shri Aswani Gupta, Ca Revenue By: Ms. Namita Khurana, Cit-Dr (On Rotational Duty) Date Of Hearing 02/07/2025 Date Of Pronouncement 06/08/2025

For Appellant: Shri Satyen Sethi, AdvFor Respondent: Ms. Namita Khurana, CIT-Dr (on rotational duty)

Section 132Section 143(1)Section 143(3)Section 153Section 245C(1)Section 245D(1)Section 245D(4)

filed by the assessee company on 30-9-2014 declaring total income of Rs 21,060/-. This was duly processed under section 143(1) of the Act on 7-12-2014. A search and seizure action under section 132 of the Act was conducted on Bansal Diamonds Private Limited (BDPL

Goel Jewellery & Mart P. Ltd., New Delhi vs. ITO, Ward- 10(2), New Delhi

In the result, appeal of the assessee is partly allowed as indicated above

ITA 6686/DEL/2017[2007-08]Status: DisposedITAT Delhi06 Aug 2025AY 2007-08

Bench: Shri Shamim Yahya & Shri Sudhir Pareek

For Appellant: Shri Satyen Sethi, Adv. &For Respondent: Shri Om Parkash, Sr. DR

Section 147Section 68

IN THE INCOME TAX APPELLATE TRIBUNAL (DELHI BENCH: ‘C’: NEW DELHI) BEFORE SHRI SHAMIM YAHYA, ACCOUNTANT MEMBER AND SHRI SUDHIR

The Orgaon Urban Co-Operative Credit Society Limited, Marcela vs. Income Tax Officer, Ward - 1(2), Panaji

ITA 74/PAN/2025[2017-18]Status: DisposedITAT Panaji05 Aug 2025AY 2017-18

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshaliita Nos. 074/Pan/2025 Assessment Year : 2017-18 The Orgaon Urban Co-Operative Credit Society Limited. Devulwada, Mercela, Goa-403 107. Pan : Aaaat6227D . . . . . . . Appellant

For Appellant: Ms Eesha Dukle [‘Ld. AR’]For Respondent: Ms Rijjula Uniyal [‘Ld. DR’]

Section 143(1)Section 143(3)Section 2(19)Section 250Section 253(1)Section 80P(2)(a)Section 80P(2)(d)Section 80P(4)

IN THE INCOME TAX APPELLATE TRIBUNAL, PANAJI BENCH, GOA BEFORE HON’BLE SHRI PAVAN KUMAR GADALE, JUDICIAL MEMBER AND SHRI

Jay Prabhudas Vithalani, Jamnagar vs. Principal Commissioner of Income Tax, Jamnagar

In the result, both the appeals of the same assessee (ITA No

ITA 75/RJT/2025[2021-22]Status: DisposedITAT Rajkot05 Aug 2025AY 2021-22

Bench: Dr. Arjunlal Saini & Shri Dinesh Mohan Sinhaआयकर अपीलसं./Ita No. 75/Rjt/2025 (निर्धारणवर्ष / Assessment Year: (2021-22) (Hybrid Hearing) Jay Prabhudas Vithlani 201, Varajresidency, 8 – Patel Colony, Gujarat-361008 Vs. The Principal Commissioner Of Income Tax, Aayakar Bhavan, Nr. Subhash Bridge, Jamnagar Rajkot Highway Gujarat-361001 स्थायीलेखासं./जीआइआरसं./Pan/Gir No.: Abcpv0266A (Appellant) (Respondent) आयकर अपीलसं./Ita No.74/Rjt/2025 (निर्धारणवर्ष / Assessment Year: (2021-22) Khushaboo Jaykumar Vithlani 201, Varajresidency, 8 – Patel Colony, Gujarat-361008 Vs. The Principal Commissioner Of Income Tax, Aayakar Bhavan, Lal Wadi Main Road, Kaushal Nagar, Gujarat - 361110 स्थायी लेखासं . / जी आइआरसं . / Pan/Gir.: Aefpv6723A (Appellant) (Respondent) Appellant By Respondent By Date Of Hearing Date Of Pronouncement : Shri Sagar Shah, Ld. Ar : Shri Sanjay Kumar, Ld. Cit(Dr) : 19/06/2025 : 05/08/2025 आदेश / Order Per Dinesh Mohan Sinha, Jm: Captioned Two Appeals Filed By The Different Assessee, Pertaining To Assessment Year (Ay) – 2021-22, Are Directed Against The Separate Order Passed By The Principal Commissioner Of Income Tax [(In Short "Ld. Pr.Cit”] U/S. 263 Of The Act, Both Orders Dated 24.01.2025. 2. Since, These Two Appeals Filed By The Different Assessee For Same

Section 263

Return of Income for AY 2021-22 declaring total income of Rs.8,51,060/- on 26.02.2022, which was processed on 29.03.2022 under section 143(1) of the Income Tax Act, 1961 at returned income. The case of the assessee was selected for Scrutiny under CASS having reason for selection

Khushboo Jaykumar Vithlani, Jamnagar vs. The Principal Commissioner of Income Tax, Jamnagar

In the result, both the appeals of the same assessee (ITA No

ITA 74/RJT/2025[2021-22]Status: DisposedITAT Rajkot05 Aug 2025AY 2021-22

Bench: Dr. Arjunlal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 75/Rjt/2025 ("नधा"रणवष" / Assessment Year: (2021-22) (Hybrid Hearing) Jay Prabhudasvithlani Vs. The Principal Commissioner Of 201, Varajresidency, 8 – Patel Colony, Income Tax, Gujarat – 361008 Aayakar Bhavan, Nr. Subhash Bridge, Jamnagar Rajkot Highway Gujarat – 361001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Abcpv0266A (Appellant) (Respondent)

For Appellant: Shri Sagar Shah, Ld. ARFor Respondent: Shri Sanjay Kumar, Ld. CIT(DR)

Section 263