← All Phrases

“Section 139(1)”

Section References (mined)Section 139Section 139(1)7,818 judgments

The decision most relied on for Section 139(1) is CIT v. Manjunatha Cotton & Ginning Factory (359 ITR 565), cited in 2,590 judgments on BharatTax.

Leading authorities on Section 139(1)

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.

Goetze (India) Ltd. v. CIT
284 ITR 323 · 2006 · Supreme Court
1,842
citing judgments

An assessee cannot raise a new claim or a claim not made in the original or revised return of income for the first time directly before the Assessing Officer during assessment proceedings.

CIT v. Kelvinator of India Ltd.
320 ITR 561 · 2010 · Supreme Court
1,673
citing judgments

An Assessing Officer cannot initiate reassessment proceedings under Section 147 of the Income Tax Act based on a mere change of opinion. Reassessment is permissible only when there is fresh tangible material leading to the belief of income escapement, not merely a review of existing facts.

CIT v. AIMIL Ltd.
321 ITR 508 · 2010 · High Court
1,629
citing judgments

Employee contributions to PF and ESIC, deposited beyond the due date under the respective Acts but within the due date for filing the income tax return under Section 139(1), are allowable deductions under Section 36(1)(va). Such disallowance cannot be made during processing under Section 143(1).

Checkmate Services Pvt. Ltd. v. CIT
143 Taxmann.com 178 · 2022 · Supreme Court
1,392
citing judgments

Employee contributions to provident fund and ESI deposited by an employer beyond the due dates prescribed under the respective special Acts are not allowable as a deduction under section 36(1)(va) of the Income-tax Act, 1961. Such disallowance can be made during processing under section 143(1).

CIT v. Gujarat State Road Transport Corporation
366 ITR 170 · 2014 · High Court
1,158
citing judgments

Employees' contributions to welfare funds, such as provident fund, are not allowable as a deduction under section 36(1)(va) if deposited beyond the due date prescribed under the respective welfare statutes, even by a single day. Such delayed deposits are not cured even if made before the income-tax return filing due date.

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.

CIT v. SSA’s Emerald Meadows
73 Taxmann.com 241 · 2016 · High Court
791
citing judgments

A penalty notice under section 271(1)(c) read with section 274 of the Income Tax Act is invalid if it fails to specify whether the penalty is for concealment of income or for furnishing incorrect particulars of income.

Judgments citing Section 139(1)

Income Tax Officer, Ward-1, Ahmednagar vs. Atul Ashok Parakh, Ahmednagar

In the result, the appeal of the Revenue and Cross Objection of the assessee both are dismissed

ITA 2/PUN/2024[2013-14]Status: DisposedITAT Pune21 Jun 2024AY 2013-14

Bench: Shri R.K. Panda & Ms. Astha Chandra

For Appellant: Shri Prasad S. BhandariFor Respondent: Shri Ramnath P. Murkunde
Section 132Section 147Section 148Section 69

operative Credit Society Ltd. are recorded in the books of accounts and income thereon was declared in the returns filed in compliance to Sections 139(1) and 148 of the Act. 1'0 substantiate this claim, the appellant has submitted copies of the bank statements maintained with M/s Shri Renuka ... against the sales made of Rs.2,05,22,000/- had already been offered for income in the returns filed in compliance to Sections 139(1) and 148 of the Act. 6.5 It is further seen from the submissions made by the appellant that the appellant's case for previous

M/S Empee Distilleries Ltd., Chennai vs. PCIT-1, Chennai

In the result, appeal filed by the assessee is allowed

ITA 716/CHNY/2023[2018-19]Status: DisposedITAT Chennai21 Jun 2024AY 2018-19

Bench: Shri Aby T. Varkey & Shri S.R.Raghunathaआयकर अपील सं./Ita No.716/Chny/2023 िनधा"रण वष"/Assessment Year: 2018-19 V. M/S.Empee Distilleries Ltd., The Pcit, 72, Greams Road, Chennai. Thousand Lights, Chennai-600 006. [Pan: Aaace 1687 N] (अपीलाथ"/Appellant) (""यथ"/Respondent) : अपीलाथ" क" ओर से/ Appellant By Shri M.Karunakaran, Adv. : ""यथ" क" ओर से /Respondent By Shri V. Nandakumar, Cit : सुनवाईक"तारीख/Date Of Hearing 06.06.2024 : घोषणाक"तारीख /Date Of Pronouncement 21.06.2024

Section 139(1)Section 143(3)Section 263

section 438 which was not Paid on or before the due date for furnishing the return of income of the previous year under section 139(1) as per Col. 26(i)(B)(b) of Form 3CD have been added back in total income of the year and offered ... deduction if the said employee contribution has been remitted on or before filling the return or before the due date specified in Section 139(1), Hence, no disallowances has been considered for on filing the ITR with respect to delay in remittance of Employee Contributions. 8. Thus, we note that

Madhusudhan Pillai, Vikhroli vs. DCIT Circle-42(1)(1), Mumbai

ITA 804/MUM/2024[2018-19]Status: DisposedITAT Mumbai21 Jun 2024AY 2018-19

Bench: Shri Amarjit Singh & Shri Rahul Chaudhary

For Appellant: Ravindra PoojaryFor Respondent: H.M. Bhatt
Section 139(1)Section 143(1)Section 6Section 90

ITA No.804/Mum/2024 Mr. Madhusudhan Pillai Vs. CPC, Bengalure, DCIT, Circle 41(1)(1) IN THE INCOME TAX APPELLATE TRIBUNAL “C

Irla Co-Op Hsg Soceity Ltd, Mumbai vs. Ward 25(2)(5), Mumbai

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

ITA 4269/MUM/2023[2016-17]Status: DisposedITAT Mumbai21 Jun 2024AY 2016-17

Bench: Shri Amarjit Singh & Shri Rahul Chaudhary, Irla Co-Op Hsg Society Vs. Ito, Ward 25(2)(5) Limited, 191/A, Prime Maharashtra – 400054 Mall Irla, Vile Parle (West) Mumbai – 400056 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aaaai4878F Appellant .. Respondent Appellant By : Pramod Parida Respondent By : H.M. Bhatt Date Of Hearing 13.05.2024 Date Of Pronouncement 21.06.2024 आदेश / O R D E R Per Amarjit Singh (Am): The Present Appeal Filed By The Assessee Is Directed Against The Assessment Order Dated 23.11.2018 Passed U/S 143(3) Of The Income Tax Act, 1961 For The Assessment Year 2016-17. The Assessee Has Raised The Following Grounds Before Us: “1. Disallowance U/S 43B- 61,01,040/- I) The Id. Cit(A) Erred In Confirming The Disallowance Of Statutory Liabilities Without Appreciating That The Same Had Been Paid Before The Due Date Of Filing Of Return U/S 139(1) & Further Erred In Holding That The Appellant, A Co-Op Housing Society (Chs), Is Doing Business Activity, Therefore, As Sec 438 Is Not Applicable On The Face It Being Eligible For The Benefit U/S 80P, The Disallowance Of Rs.61.01.040/- Is Uncalled For & The Same May Be Deleted Ii) Without Prejudice To Above, The Id Cit(A) Erred In Holding That The Concept Of Mutuality Does Not Apply To The Appellant Where There Is Close Nexus Of All Its Funds Flow Are Utilized Exclusively For The Benefit Of Its Members, Hence The Disallowance Made May Be Deleted As Consistency Needs To Be Respected. 2. Taxability U/S. 22 Or U/S. 56- Rental Or Hire Charges Rs.8,73,634/-

For Appellant: Pramod ParidaFor Respondent: H.M. Bhatt
Section 139(1)Section 143(2)Section 143(3)Section 22Section 24Section 43BSection 56Section 80P

P a g e | 1 IRLA Co-op HSG Society Ltd. VS. ITO, Ward 25(2)(5) IN THE INCOME

Meghna Das, New Delhi vs. ITO, Ward-49(1), Delhi

In the result, the appeal of the assessee is allowed

ITA 415/DEL/2024[2020-21]Status: HeardITAT Delhi20 Jun 2024AY 2020-21

Bench: Shri Pradip Kumar Kediaassessment Year 2020-21

For Respondent: Shri Om Prakash, Sr.DR
Section 139(1)Section 143(1)Section 90

credit of Rs.8,96,355/- for the solitary reason that prescribed Form No.67 has not been filed within the due date prescribed under Section 139(1) of the Act as warranted by Rule 128(9) of the Income Tax Rules, 1962. The prescribed form was filed on 22.01.2021 in tandem ... ground that the requisite Form no.67 was filed on 22nd January, 2021, i.e., beyond the due date prescribed under Section 139(1) of the Act, the extended due date under Section 139(1) being 10th January, 2021. It is the case of the assessee that the foreign tax credit cannot

Doctor Punjabrao Deshmukh Krushi Vidyapeeth Karamchari Pat Sanstha Mryat, Akola vs. Income Tax Officer, Ward-1, Akola

ITA 331/NAG/2022[2018-2019]Status: DisposedITAT Nagpur19 Jun 2024AY 2018-2019

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri K.P. DewaniFor Respondent: Shri Abhay Y. Marathe
Section 139(1)Section 234ASection 250Section 80ASection 80P

being declined on the ground that the appellant did not file its return for the relevant assessment year within the period prescribed under Section 139 (1) of the Act. 3. The facts are not much in dispute. Section 80-IB of the Act allows certain deductions if an industry ... obtaining the benefit of such deductions is that the return for the relevant year should be filed within the time prescribed under Section 139(1) of the Act. Such condition is imposed by Section 80AC of the Act and the wording of the material part is couched in a negative

Ku Sodalamuthu and Co Private Limited, Coimbatore vs. DCIT, Coimbatore

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

ITA 774/CHNY/2024[2018-19]Status: DisposedITAT Chennai19 Jun 2024AY 2018-19

Bench: Shri Aby T Varkey, Hon’Ble & Shri S. R. Raghunatha, Hon’Bleआयकर अपील सं./Ita No.: 774/Chny/2024 िनधा"रण वष" / Assessment Year: 2018-19 Deputy Commissioner Of Income K U Sodalamuthu & Co V. Tax, Private Limited, Corporate Circle-1, 428, Mettupalayam Road, 63, Race Course Road, Coimbatore – 641 043 Coimbatore – 641 025. [Pan: Aaack-7236-M] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri. N.V. Lakshmi, Advocate ""यथ" क" ओर से/Respondent By : Shri. D. Hema Bhupal, Jcit सुनवाई क" तारीख/Date Of Hearing : 29.04.2024 घोषणा क" तारीख/Date Of Pronouncement : 19.06.2024 आदेश /O R D E R

For Appellant: Shri. N.V. Lakshmi, AdvocateFor Respondent: Shri. D. Hema Bhupal, JCIT
Section 139(1)Section 142(1)Section 143(2)Section 143(3)Section 80I

आयकर अपीलीय अिधकरण, ‘बी’ "यायपीठ, चे"ई IN THE INCOME TAX APPELLATE TRIBUNAL ‘B’ BENCH, CHENNAI "ी एबी टी वक", "याियक

Muniyallappa Bharathi, Bangalore vs. Income Tax Officer, Ward 4(3)(3), Bangalore

In the result, all the appeals filed by the assessees stands dismissed

ITA 841/BANG/2024[2019-20]Status: DisposedITAT Bangalore19 Jun 2024AY 2019-20

Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahuassessment Year : 2019-20

For Appellant: Shri Subramanya Bhat, CAFor Respondent: Shri Ganesh R. Ghale, Standing Counsel
Section 139(1)Section 143(1)Section 143(1)(a)Section 25oSection 36(1)(va)Section 43

failed to appreciate that the PF and ESI contributions were remitted before the due date of filing return of income stipulated under section 139(1) of the Act and accordingly, no addition was warranted on the facts and circumstances of the case. 7) The appellant craves leave to add, alter ... appreciating that the employee contribution to provident fund amounting to Rs. 77,17,455 was paid within the due date as per section 139(1) of the Act. 2.3. The learned CIT(A), NFAC, Delhi erred in not appreciating that employee contribution to provident fund cannot be disallowed

Sh. Onkar Syal, Bharatpur vs. ITO, Ward-2, Bharatpur

In the result, both the appeal of the assessee are allowed for

ITA 347/JPR/2024[2018-19]Status: DisposedITAT Jaipur18 Jun 2024AY 2018-19

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Sh. P. C. Parwal (CA)For Respondent: Sh. Anup Singh (Addl. CIT)
Section 139(1)Section 142(1)Section 144Section 69A

period (09.11.2016 to 30.12.2016) in his bank account maintained with Baroda Rajasthan Kshetriya Gramin Bank, Rajendra Nagar, Bharatpur. As per the provisions of section 139(1) of the Income Tax Act, 1961, the assessee was required to file the income tax return for the assessment year

Sh. Onkar Syal, Bharatpur vs. ITO, Ward-2, Bharatpur

In the result, both the appeal of the assessee are allowed for

ITA 346/JPR/2024[2017-18]Status: DisposedITAT Jaipur18 Jun 2024AY 2017-18

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Sh. P. C. Parwal (CA)For Respondent: Sh. Anup Singh (Addl. CIT)
Section 139(1)Section 142(1)Section 144Section 69A

period (09.11.2016 to 30.12.2016) in his bank account maintained with Baroda Rajasthan Kshetriya Gramin Bank, Rajendra Nagar, Bharatpur. As per the provisions of section 139(1) of the Income Tax Act, 1961, the assessee was required to file the income tax return for the assessment year

Valaram Suresh Kumar, Bangalore vs. Income Tax Officer, Ward-6(2)(1), Bangalore

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

ITA 729/BANG/2024[2017-18]Status: DisposedITAT Bangalore18 Jun 2024AY 2017-18

Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahuassessment Year : 2017-18

For Appellant: Shri Shreehari Kutsa, Advocate
Section 133(6)Section 139(1)Section 142(1)Section 250Section 69A

IN THE INCOME TAX APPELLATE TRIBUNAL SMC-‘A’ BENCH : BANGALORE BEFORE SMT. BEENA PILLAI, JUDICIAL MEMBER AND SHRI LAXMI PRASAD

Sonal Sunil Thakrar, Mumbai vs. NFAC, Delhi

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

ITA 744/MUM/2024[2012-13]Status: DisposedITAT Mumbai18 Jun 2024AY 2012-13

Bench: Shri B.R. Baskaran & Shri Sandeep Singh Karhailassessment Year :2012-13 Mrs. Sonal Sunil Thakkar, B-104, Mrud Kishore Bldg., Behind Gokul Shopping Center, Datta Pada Road, Borivali West, Mumbai – 400 092 Pan: Ahhpt-4628-D ---- Appellant Vs. National Faceless Assessment Centre, Ito 42(1)(5), Kautilya Bhavan, Bandra East, Mumbai – 400 051 --- Respondent Assessee By : Shri Tejas Shah Revenue By : Shri Surendra Meena Date Of Hearing : 13/06/2024 Date Of Pronouncement : 18/06/2024

For Appellant: Shri Tejas ShahFor Respondent: Shri Surendra Meena
Section 139(1)Section 143(1)Section 148Section 271(1)(c)Section 271F

IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “F”, MUMBAI BEFORE SHRI B.R. BASKARAN, ACCOUNTANT MEMBER AND SHRI SANDEEP SINGH

M/S Dhanlaxmi Builders & Developers, Mumbai vs. ACIT-25(2), Mumbai

In the result, the appeal is allowed in above terms

ITA 207/MUM/2024[2014-15]Status: DisposedITAT Mumbai18 Jun 2024AY 2014-15

Bench: SHRI PRASHANT MAHARISHI (Accountant Member), SHRI SUNIL KUMAR SINGH (Judicial Member)

Section 133ASection 139(1)Section 143(2)Section 2Section 68

IN THE INCOME TAX APPELLATE TRIBUNAL, ‘D’ BENCH MUMBAI BEFORE: SHRI PRASHANT MAHARISHI, ACCOUNTANT MEMBER & SHRI SUNIL KUMAR SINGH, JUDICIAL

Mahindra Accelo Limited, Mumbai vs. Addl/JCIT (A)-1, Mumbai

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

ITA 1315/MUM/2024[2020-21]Status: DisposedITAT Mumbai18 Jun 2024AY 2020-21

Bench: Shri B.R. Baskaran & Shri Sandeep Singh Karhailassessment Year :2020-21 Mahindra Accelo Limited, 6Th Floor, Mahindra Towers, P.K.Kurne Chowk, Worli, Mumbai -400 018 Pan: Aaacm-4745-P ---- Appellant Vs. Addl/Jcit(A)-1, Visakhapatnam, 1St Floor, Prestige Alpha No.48/1 48/2, Beratenngrahara Begur, Hosur Road, Uttarahalli Hobli, Bengaluru – 560 100 --- Respondent Assessee By : Ms.Sneha Goyal Revenue By : Shri Surendra Meena Date Of Hearing : 12/06/2024 Date Of Pronouncement : 18/06/2024

For Appellant: Ms.Sneha GoyalFor Respondent: Shri Surendra Meena
Section 139(1)Section 143(1)Section 154Section 43B

Paid on or before the due date for furnishing the return of income of the previous year under section 139(1) - xxxxx 26(i)(B)(b) - not paid on or before the aforesaid date xxxxx 4. Since the leave encashment amount of Rs.3,85,96,890/- outstanding on 31.3.2019 continued

Usha Subhash Diwan, Mumbai vs. Income Tax Office 25(1)(5), Mumbai

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

ITA 3630/MUM/2023[2011-12]Status: DisposedITAT Mumbai18 Jun 2024AY 2011-12

Bench: Shri B.R. Baskaran & Shri Sandeep Singh Karhailassessment Year :2011-12 Usha Subhash Diwan, D-303, Nirman Park, Pump House, R.J.Road, Mumbai – 400 093 Pan: Afupd-8410-N ---- Appellant Vs. I.T.O -25(1)(5),Mumbai C-10/406, G Block, Bkc, Bandra(E) Mumbai – 400 051 --- Respondent Assessee By : Shri Sanjay Parikh Revenue By : Shri Surendra Meena Date Of Hearing : 12/06/2024 Date Of Pronouncement : 18/06/2024

For Appellant: Shri Sanjay ParikhFor Respondent: Shri Surendra Meena
Section 139(1)Section 144Section 148

IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “F”, MUMBAI BEFORE SHRI B.R. BASKARAN, ACCOUNTANT MEMBER AND SHRI SANDEEP SINGH

Shiksha Foundation, Ahmedabad vs. The ITO, Ward-2 (Exemp), Ahmedabad

In the result, the appeal of the assessee is allowed

ITA 441/AHD/2024[2018-19]Status: DisposedITAT Ahmedabad14 Jun 2024AY 2018-19

Bench: Ms. Annapurna Gupta (Accountant Member), Shri Siddhartha Nautiyal (Judicial Member)

For Appellant: Shri Divyang Shah, A.RFor Respondent: Shri Santosh Kumar, Sr. D.R
Section 11Section 119Section 12ASection 143(1)Section 143(1)(a)Section 250

234F of the Act. 10. On going through the facts of the case, we observe that as per Explanation 2(a)(ii) of section 139(1) of the act, the due date for filing the Income-tax return in case of a person (other than a company) whose accounts ... assessment year. Accordingly, due date for filing the Income-tax return in the case of appellant-trust, for AY 2018-19, as per section 139(1) of the act, is 30th September, 2018. Further, from the facts of the case, we observe that appellant trust had filed its return

DCIT, CC-3(3), Kolkata vs. Amicus Real Estate Pvt. Ltd., Kolkata

In the result, appeal of the revenue is dismissed

ITA 803/KOL/2023[2010-11]Status: DisposedITAT Kolkata14 Jun 2024AY 2010-11

Bench: SHRI SANJAY GARG, HON’BLE (Judicial Member), DR. MANISH BORAD, HON’BLE (Accountant Member)

For Appellant: Shri Sunil Surana, A/RFor Respondent: Shri Abhijit Kundu, CIT, D/R
Section 132Section 139(1)Section 143(1)Section 143(2)Section 250

| आयकर अपीलीय अिधकरण "यायपीठ, कोलकाता | IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH, KOLKATA BEFORE SHRI SANJAY GARG, HON’BLE

Suneel Kumar Agrawal, Lakhimpur Kheri vs. Income Tax Officer 3(5), Lakhimpur

In the result, the appeal of the assessee stands allowed

ITA 112/LKW/2023[2017-18]Status: DisposedITAT Lucknow13 Jun 2024AY 2017-18

Bench: Shri Sudhanshu Srivastavaa.Ys. 2017-18 Suneel Kumar Agarwal, Vs. Income Tax Officer-3(5), Old Galla Mandi, Lakhimpur - Kheri Lakhimpur Kheri-262701 Pan Agfpa 3061J (Appellant) (Respondent) Appellant By Shri P.K. Kapoor, Ca Respondent By Shri Sanjeev Krishna Sharma, Addl. Cit( Dr) Date Of Hearing 20/03/2024 Date Of Pronouncement 13/06/2024 O R D E R This Appeal Has Been Preferred By The Assessee Against Order Dated 10.02.2023 Passed By The Ld. Commissioner Of The Income Tax (Appeal) [Hereinafter Called The ‘Cit(A)’], Lucknow-3 For Assessment Year (Ay) 2017-18. 2.0 The Brief Facts Of The Case, As Appearing From The Assessment Order, Are That The Assessee Is Engaged In Trading Of Edible Oil, Food Grains, Khandsari, Sugar, Atta, Maida & Suji Etc. A Warrant U/S. 132A Of The Income Tax Act, 1961 (Hereinafter Called The ‘Act’) Was Served On The Assessee On 02.02.2017 & A Sum Of Rs.14,64,000/- Was Seized From The Possession Of The Assessee.

Section 132ASection 139(1)Section 153ASection 69A

year. In response thereto, the assessee submitted a copy of e-filed Income Tax Return which had already been filed in terms of Section 139(1) of the Act, wherein the assessee had shown an income of Rs.3,03,297/-. The turnover had been shown at Rs.3

Moonak Welfare Society, Sangrur vs. ITO, Ward, Sunam

In the result, we direct the AO to allow the exemption u/s 11 to the assessee society

ITA 465/CHANDI/2023[2022-23]Status: DisposedITAT Chandigarh13 Jun 2024AY 2022-23

Bench: The Ld. Cit(A). 3.1 It Was Submitted During The Appellate Proceedings That The Cpc, Bangalore While Processing The Return Of Income Has Disallowed The Exemption On The Ground That Tax Audit Report In Form 10B Should Have Been Filed One Month Prior To The Filing

For Appellant: Shri Jaspal Sharma, AdvocateFor Respondent: Shri Ved Parkash Kalia, JCIT, Sr. DR
Section 11Section 12ASection 12A(1)(b)Section 139Section 139(1)Section 143(1)

that the assessee has filed its return of income and Form 10B after the due date for filing the return of income under section 139(1) ie, on 31/12/2022 and accordingly it is not entitled to claim benefit of exemption under section 11 of the Act. It was further held ... under section 11, even where the return of income has been filed after due date of filing of the return of income under section 139(1) of the Act. 3.6 Finally, the Ld. CIT(A) referred to the provisions of Sub Section (b) & (ba) of Section 12A as well

Jhaveri Trading and Investment Pvt.Ltd., Ahmedabad vs. The DCIT, Cent. Cir. 1(1), Ahmedabad

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

ITA 403/AHD/2023[2014-15]Status: DisposedITAT Ahmedabad13 Jun 2024AY 2014-15

Bench: Shri Waseem Ahmed & Shri Tr Senthil Kumarआयकर अपील सं./Ita Nos. 401 To 403/Ahd/2023 "नधा"रण वष"/Asstt. Years: (2012-2013 To 2014-2015) & आयकर अपील सं./Ita Nos. 399 & 400/Ahd/2023 "नधा"रण वष"/Asstt. Years: (2010-2011 & 2011-12)

For Appellant: Shri Deepak Shah, ARFor Respondent: Shri Sudhendu Das, CIT.DR
Section 132(4)Section 68

assessee has also shown the closing inventory at ₹ 5,67,62,457.00. Likewise, the assessee has filed the return of income under section 139(1) of the Act declaring an income of Rs. 8,33,83,875.00 before adjusting the set of the brought forward losses. Even assuming but without