“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)

Abci Infrastructures Pvt. Ltd., Kolkata, West Bengal vs. ACIT/DCIT, Central Circle 1, Guwahati, Assam

In the result, both the appeals of the assessee are allowed

ITA 418/GTY/2025[2015-16]Status: DisposedITAT Guwahati13 Mar 2026AY 2015-16

Bench: Shri Duvvuru Rl Reddy & Shri Rajesh Kumar

Section 132(1)Section 139(1)Section 153ASection 250Section 271(1)(c)Section 274

ABCI Infrastructure P Ltd. Vs ACIT/DCIT 3. The facts of the case, in brief, are that the assessee filed return of income under Section 139(1) of the Act on 17/10/2016 declaring income of ₹ 22,78,53,330/-. A search action under Section 132(1) of the Act was conducted ... income as declared under Section 153A of the Act is higher than the income as disclosed in the return of income filed under Section 139(1) of the Act. 6. Now the issue before us is whether the income disclosed by the assessee in the return filed under Section 153A

Mr. Shridhar Gangaram Anumandala, Mumbai vs. ITO Ward 22(3)(6), Mumbai

In the result, the appeal of the assessee bearing ITA No

ITA 8391/MUM/2025[2020-21]Status: DisposedITAT Mumbai13 Mar 2026AY 2020-21

Bench: SHRI ANIKESH BANERJEE (Judicial Member), SHRI JAGADISH (Accountant Member)

For Appellant: NoneFor Respondent: Shri S. Anbuselvan (Sr. DR)

Section 139(1)Section 143Section 143(3)Section 234ASection 234BSection 250Section 50Section 55ASection 56(2)(x)Section 69

ground/s before or during the course of appeal that may be necessary and/or advised.” 4. The assessee filed the return of income under section 139(1) of the Act, declaring income under the head “Profits and Gains of Business or Profession.” The assessment was completed by the Ld. AO under

Bishnupriya Bijaychandra Mahanty, Navi Mumbai vs. Income Tax Officer, Mumbai

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

ITA 4477/MUM/2025[2018-2019]Status: DisposedITAT Mumbai13 Mar 2026AY 2018-2019

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2018-19 Bishnupriya Bijaychandra Mahanty Ito, Ward 28(1)(1), Mumbai 204 Plot 13/A Wing Siddhivinayak It-Office, Vashi Railway Vs. Chs, Sector 6, Ghansoli, Navi Station Building, Mumbai 400701, Navi Mumbai- 400703 Authroised Person Add: 218, Ratna High Street, Naranpura, Ahmedabad- 380013 Pan No. Btdpm 7308 A Appellant Respondent

For Respondent: Mr. Pritesh L. Shah (Virtually

Section 1Section 148Section 148ASection 149Section 69

Assessing Officer from the due date of filing return computed by the Assessing Officer from the due date of filing return under section 139(1) till the date of passing the assessment order. under section 139(1) till the date of passing the assessment under section 139(1) till ... date of issue of notice under section 148 and not from the due Bishnupriya Bijaychandra Mahanty Bishnupriya Bijaychandra Mahanty 3 date under section 139(1). Accordingly, the interest levied is date under section 139(1). Accordingly, the interest levied is date under section 139(1). Accordingly, the interest levied

DCIT Central Circle-5(4), Mumbai vs. Satyam Realtors Private Limited, Mumbai

In the result, the appeal of the revenue bearing ITA No

ITA 6283/MUM/2024[2017-18]Status: DisposedITAT Mumbai13 Mar 2026AY 2017-18

Bench: Shri Anikesh Banerjee & Shri Jagadishdcit Cc-5(4), Mumbai Vs Satyam Realtors Private Ltd. Room No.436, 4Th Floor, Room No.4, 3Rd Floor Capri, Anant Kautilya Bhawan, Bandrakurla Kanekar Marg Bandra (East) Complex, Mumbai-400051 Mumbai-400051 Pan:Aaccs7290P Appellant Respondent Assessee By : None, Respondent By : Shri Arun Kanti Datta (Cit Dr) Date Of Hearing : 09/03/2026 Date Of Pronouncement : 13/03/2026 O R D E R Per: Anikesh Banerjee (Jm): The Instant Appeal Of The Revenue Was Preferred Against The Order Of The Ld. Commissioner Of Income Tax (Appeal)-53, Mumbai [For Brevity The “Ld. Cit(A)”], Order Passed Under Section 250 Of The Income Tax Act 1961 (For Brevity ‘The Act’) For Assessment Year 2017-18, Date Of Order 24.09.2024. The Impugned Order Emanated From The Order Of The Ld. Assistant Commissioner Of Income Tax

For Appellant: NoneFor Respondent: Shri Arun Kanti Datta (CIT DR)

Section 143(3)Section 14ASection 14A(1)Section 250Section 43B

payable to a cooperative bank which is not paid on or before the due date prescribed for filing of return of income under section 139(1) of the Act shall be 5 Satyam Relations Pvt. Ltd. liable to be disallowed under section 438 of the Act only we.f ... payable to a cooperative bank which is not paid on or before the due date prescribed for filing of return of income under section 139(1) of the Act shall be liable to be disallowed under section 438 of the Act only w.e.f. A.Y 2018-19.1 notice that the year

Getinge Medical India Private Limited, Mumbai vs. DCIT 2(2)(1), Mumbai Maharashtra

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

ITA 4872/MUM/2024[2020-21]Status: DisposedITAT Mumbai13 Mar 2026AY 2020-21

Bench: Smt. Beena Pillai () & Shri Girish Agrawal ()

Section 115Section 115BSection 142(1)Section 143(2)Section 156Section 234ASection 270ASection 37Section 41Section 41(1)(a)

income. The Ld.AR submitted that the Notification dated 31.12.2020 issued by the CBDT extended the time to file return of income under section 139(1) of the Act and the due date to file the return of income till 15/02/2021. The Ld.AR submitted that during the relevant period when ... option to be taxed at the concessional rate. It requires that the option be exercised on or before the due date under section 139(1) and in the prescribed form, namely Form 10 IC. The provision thus contains two components — the substantive act of opting for the new regime

DCIT, Delhi vs. Noida Toll Bridge Company Limited, Delhi

In the result, all the 03 appeals filed by the Revenue stand dismissed

ITA 6177/DEL/2025[2018-19]Status: DisposedITAT Delhi13 Mar 2026AY 2018-19

Bench: Shri Mahavir Singh & Shri S. Rifaur Rahman

For Appellant: Sh. Mahesh Kumar, CIT(DR)For Respondent: None

Section 115JSection 139(1)

Flyway which is situated across river Yamuna and connects Delhi and Noida. The assessee filed its return of income under section 139(1) of the Act for the relevant assessment year on 15.10.2016, declaring total income of Rs. 3,69,27,430/- under the normal provisions of the Act. However

DCIT, Delhi vs. Noida Toll Bridge Company Limited, Delhi

In the result, all the 03 appeals filed by the Revenue stand dismissed

ITA 6176/DEL/2025[2017-18]Status: DisposedITAT Delhi13 Mar 2026AY 2017-18

Bench: Shri Mahavir Singh & Shri S. Rifaur Rahman

For Appellant: Sh. Mahesh Kumar, CIT(DR)For Respondent: None

Section 115JSection 139(1)

DCIT, Delhi vs. Noida Toll Bridge Company Limited, Delhi

In the result, all the 03 appeals filed by the Revenue stand dismissed

ITA 6175/DEL/2025[2016]Status: DisposedITAT Delhi13 Mar 2026

Bench: Shri Mahavir Singh & Shri S. Rifaur Rahman

For Appellant: Sh. Mahesh Kumar, CIT(DR)For Respondent: None

Section 115JSection 139(1)

DCIT, Central Circle-32, Delhi vs. Bses Yamuna Power Limited, New Delhi

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

ITA 5474/DEL/2025[2009-10]Status: DisposedITAT Delhi13 Mar 2026AY 2009-10

Bench: Shri S. Rifaur Rahman & Shri Vimal Kumardcit, Bses Yamuna Power Limited, Central Circle-32, Room No.359, E2, Ara Centre, Delhi. Vs. Jhandewalan Extension, New Delhi-110055. [ Pan-Aabcc8569N (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv., Ms. Deepashree Rao, Adv. & Shri Shivam Gupta, Ca Department By Ms. Monika Singh, Cit-Dr Date Of Hearing 21.01.2026 Date Of Pronouncement 13.03.2026 O R D E R Per Vimal Kumar, Jm: The Appeal Filed By The Revenue Is Against Order Dated 23.05.2025 Of The Learned Commissioner Of Income Tax (Appeals)-30, New Delhi [Hereinafter Referred To As ‘The Ld. Cit(A)’] Passed U/S 250 Of The Income Tax Act, 1961, [Hereinafter Referred To As ‘The Act’] Arising Out Of Assessment Order Dated 20.12.2016 Of Ld. Assessing Officer/Dcit, Circle-5(1), New Delhi (Hereinafter Referred To As ‘The Ld. Ao’ ) U/S 147/143(3) Of The Act For Assessment Year 2009-10. 2. Brief Facts Of The Case Are That Original Return Of Income Was Filed By Assessee On 29.09.2009 U/S 139(1) Of The Act After Adjusting Brought Forward Losses Of Dcit Vs. Bses Yamuna Power Ltd.

Section 139(1)Section 143(3)Section 147Section 148Section 250

necessary corollary thereof. 6. The assessee, on the other hand, inter alia, submits that it had filed its return on 28.09.2009 under section 139(1) of the Act. declaring loss of Rs. 154,39,15,018- which stood assessed in a regular assessment under section

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

Swarnimtouch Solutions Private Limited, Ahmedabad vs. ITO Ward 4(1)(1), Ahmedabad

In the result, the appeal of the assessee is allowed

ITA 2466/AHD/2025[2024-25]Status: DisposedITAT Ahmedabad12 Mar 2026AY 2024-25

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

For Appellant: Shri Hardik Vora, ARFor Respondent: Shri C Dharani Nath, Sr. DR

Section 139(1)Section 143(1)Section 80

time prescribed under the provisions of the Act, namely one month prior to the due date of filing the return of income under section 139(1). Consequently, the total income of the assessee was determined at Swarnimtouch Solutions Pvt. Ltd. vs. ITO Asst. Year

Income Tax Officer, Non Corporate Ward 22(1), Chennai vs. Ezhumalai, Thirukazhukundram

ITA 4108/CHNY/2025[2019-20]Status: DisposedITAT Chennai12 Mar 2026AY 2019-20

Bench: Shri George George K, Vice- & Shri Inturi Rama Raoआयकर अपील सं. / Ita No.4108/Chny/2025 िनधा"रण वष" / Assessment Year: 2019-20 Income Tax Officer, V Ezhumalai, Non Corporate Ward- S 1123, Ponpatharkoodam, 22(1), Tambaram Gangai Amman Koil Street, Thirukazhukundram, Chengalpattu – 603405 Pan: Acipe8113C Appellant/ Revenue Respondent / Assessee Assessee By None Revenue By Ms. V Aswathy – Jcit Date Of Hearing 18/02/2026 Date Of Pronouncement 12/03/2026 आदेश/ Order Per Inturi Rama Rao, Am : This Appeal Filed By The Revenue Directed Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac], Delhi

Section 120Section 143(2)Section 144Section 147Section 148Section 148ASection 250

आयकर अपीलीय अिधकरण ”डी” "ायपीठ चे"ई म"। IN THE INCOME TAX APPELLATE TRIBUNAL CHENNAI BENCHES “D” :: CHENNAI BEFORE SHRI

Lima Loundes Marie, Puducherry vs. ITO, Ward-3, Puducherry

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

ITA 3957/CHNY/2025[2016-17]Status: DisposedITAT Chennai12 Mar 2026AY 2016-17

Bench: Inturi Rama Rao & Shri Manu Kumar Giri

For Appellant: Mr. Girish Kumar,S, AdvocateFor Respondent: Ms. R. Anitha, Addl. CIT

Section 139(1)Section 142(1)Section 144Section 147Section 148Section 148A

case are that the assessee is an individual. The assessee did not file the return of income under the provisions of section 139(1) of the Act for the A.Y. 2016–17. Based on information that the assessee had made an investment of Rs. 98,68,000/- in immovable property

Tehmina K Katrak Charitable Trust, Mumbai vs. ITO Ward 2(4), Mumbai

ITA 549/MUM/2026[2021-22]Status: DisposedITAT Mumbai12 Mar 2026AY 2021-22

Section 11Section 119Section 139Section 154Section 92E

Section 12A/12AA/12AB has not E filed the Audit Report in Form 10B one month prior to the due date for furnishing return under Section 139(1). Hence the exemption amounting to INR.3,29,425/-claimed in Sr.no. 2 exemption claimed u/s 11(1)(d) and Sr.no. 4i to 4viii

DCIT, Circle-3(4), Mumbai vs. Glenmark Pharmaceuticals Limited, Mumbai

In the result, appeal of the Revenue for Assessment Year 2016-17

ITA 3991/MUM/2025[2016-17]Status: DisposedITAT Mumbai12 Mar 2026AY 2016-17

Bench: Shri Pawan Singh & Shri Girish Agrawal

For Appellant: Shri Vijay Mehta, CAFor Respondent: Ms. Neena Jeph, CIT DR

Section 143(3)Section 35Section 41(1)Section 801C

IN THE INCOME TAX APPELLATE TRIBUNAL “K” BENCH MUMBAI BEFORE SHRI PAWAN SINGH, JUDICIAL MEMBER AND SHRI GIRISH AGRAWAL, ACCOUNTANT

DCIT, Circle-3(4), Mumbai vs. Glenmark Pharmaceuticals Limited, Mumbai

In the result, appeal of the Revenue for Assessment Year 2016-17

ITA 3971/MUM/2025[2015-16]Status: DisposedITAT Mumbai12 Mar 2026AY 2015-16

Bench: Shri Pawan Singh & Shri Girish Agrawal

For Appellant: Shri Vijay Mehta, CAFor Respondent: Ms. Neena Jeph, CIT DR

Section 143(3)Section 35Section 41(1)Section 801C

IN THE INCOME TAX APPELLATE TRIBUNAL “K” BENCH MUMBAI BEFORE SHRI PAWAN SINGH, JUDICIAL MEMBER AND SHRI GIRISH AGRAWAL, ACCOUNTANT

ACIT., Central Circle-1(4), Hyderabad vs. Kvr Consultancy Private Limited, Hyderabad

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

ITA 212/HYD/2025[2016-17]Status: DisposedITAT Hyderabad11 Mar 2026AY 2016-17

Section 132Section 142(1)Section 147Section 148Section 251

ground that, the loan transaction between the assessee company and M/s. Opus Holdings Pvt. Ltd. was not reported in the ITR filed under Section 139(1) of the Act on 29.11.2016. But, fact remains that the assessee company has explained the said discrepancy to the A.O. and proved that ... grounds. The first and foremost reason given by the A.O. is discrepancy in the ITR filed by the assessee company under Section 139(1) of the Act on 29.11.2016 and the subsequent return filed in response to notice issued under Section 148 of the Act on 02.11.2021. Admittedly

Ravipati Radha Bai, Hyderabad vs. ITO, Ward 7(1), Hyderabad

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

ITA 2022/HYD/2025[2017-18]Status: DisposedITAT Hyderabad11 Mar 2026AY 2017-18

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita.No.2022/Hyd/2025 Assessment Year 2017-2018 Ravipati Radha Bai [[ The Income Tax Officer, Hyderabad – 500 028. Ward-7(1), Vs. Telangana. Hyderabad – 500 084. Pan Aaihr4276B (Appellant) (Respondent) िनधा"रती "ारा/Assessee By : Sri H Srinivasulu, Advocate राज" व "ारा/Revenue By : Ms Reema Yadav, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 05.03.2026 घोषणा की तारीख/Pronouncement: 11.03.2026 आदेश/Order Per Vijay Pal Rao:

For Appellant: Sri H Srinivasulu, AdvocateFor Respondent: MS Reema Yadav, Sr. AR

Section 144Section 250

आयकर अपील"य अ"धकरण, हैदराबाद पीठ IN THE INCOME TAX APPELLATE TRIBUNAL Hyderabad ‘SMC’ Bench, Hyderabad BEFORE SHRI VIJAY

C-2480 Elayangaram Paccs, Tirupattur vs. ITO, Tirupathur

In the result, appeal of the Assessee stands partly allowed for statistical purpose

ITA 4037/CHNY/2025[2018-19]Status: DisposedITAT Chennai11 Mar 2026AY 2018-19

Bench: Shri George George K, Vice- & Shri Inturi Rama Raoआयकर अपील सं. / Ita No.4037/Chny/2025 "नधा"रण वष" / Assessment Year: 2018-19 C-2480 Elayanagaram Assessment Unit, Primary Agricultural V Nfac, Income Tax Cooperative Credit Society, S. Department, Elayanagaram, Tirupattur. Ito-Che-W- Pan: Aahfc7142G (146)(2), Chennai. Appellant Respondent Assessee By Mr. Shyam Sundar – Ca Revenue By Ms. V Awasthay – Jcit Date Of Hearing 17/02/2026 Date Of Pronouncement 11/03/2026 आदेश / Order Per Inturi Rama Rao, Am: This Is An Appeal Filed By The Assessee Directed Against The Order Of Ld. Commissioner Of Income Tax(Appeals)[Nfac] Delhi [‘The Cit(A)’] Passed Under Section 250 Of The Income Tax Act

Section 115BSection 139(1)Section 142(1)Section 144Section 147Section 148Section 250Section 250(6)Section 69Section 80P(2)(a)

classified as a Primary Agricultural Cooperative Credit Society. The appellant had not filed the Return of Income under the provision of section 139(1) of the Act for the A.Y.2018- 19. Based on the information that the appellant society made cash deposit in the account maintained with Vellore District Central

Naseer Ahmath Riswana Fathima, Coimbatore vs. ITO, Non Corp Ward 1(4), Cheenai, Chennai

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

ITA 3415/CHNY/2025[2017-18]Status: DisposedITAT Chennai11 Mar 2026AY 2017-18

Bench: Ms. Padmavathy.S & Shri Manu Kumar Giriआयकर अपील सं./Ita No.3415/Chny/2025 िनधा#रण वष# /Assessment Year: 2017-18

For Appellant: Mr. K.Vishwa padmanabhan, C.A ()For Respondent: Ms. R. Anitha, Addl. CIT

Section 139(1)Section 143(3)Section 250Section 271BSection 44A

आयकर अपीलीय अिधकरण, ‘सी’ "ायपीठ, चे"ई। IN THE INCOME TAX APPELLATE TRIBUNAL ‘C’ BENCH: CHENNAI सु"ी पदमावती यस, लेखा