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“Section 36(1)(iii)”

Section References (mined)Section 36Section 36(1)(iii)1,547 judgments

The decision most relied on for Section 36(1)(iii) is CIT v. Reliance Utilities & Power Ltd. (313 ITR 340), cited in 2,118 judgments on BharatTax.

Leading authorities on Section 36(1)(iii)

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.

S.A. Builders Ltd. v. CIT
288 ITR 1 · 2007 · Supreme Court
1,484
citing judgments

Interest paid on borrowed funds cannot be disallowed merely because the assessee made interest-free advances, provided those advances were made for business purposes and commercial expediency. The Revenue cannot dictate a businessman's commercial decisions, but the assessee bears the onus to prove the business expediency.

CIT v. HDFC Bank Ltd.
366 ITR 505 · 2014 · High Court
1,261
citing judgments

When an assessee possesses interest-free funds sufficient to cover investments yielding tax-free income, it is presumed that such investments were made from these interest-free funds, precluding disallowance of interest expenditure under Section 14A.

Maxopp Investment Ltd. v. CIT
347 ITR 272 · 2012 · High Court
516
citing judgments

Disallowance under Section 14A cannot exceed the exempt income earned. The Assessing Officer must record satisfaction regarding the assessee's accounts before making any disallowance.

South Indian Bank Ltd. v. CIT
438 ITR 1 · 2021 · Supreme Court
508
citing judgments

The mixed fund theory is affirmed, holding that no disallowance of interest expenditure under Section 14A can be made if the assessee possesses sufficient non-interest bearing funds, such as capital and reserves, to cover investments made in tax-free securities.

CIT v. Reliance Industries Ltd.
410 ITR 466 · 2019 · Supreme Court
501
citing judgments

When mixed funds are available, interest-free advances are presumed to be made from the assessee's own interest-free funds, preventing disallowance of interest expenditure under section 36(1)(iii). This principle also applies to section 14A disallowance, where interest expenditure is not disallowed if surplus funds are available and no direct nexus is established with borrowed funds for investments earning exempt income.

CIT v. Dalmia Cement (Bharat) Ltd.
254 ITR 377 · 2002 · High Court
417
citing judgments

When there is a nexus between an expenditure and the purpose of business, incurred on grounds of commercial expediency, the Revenue cannot question its reasonableness or assume the role of the businessman to compel profit maximization. This principle applies even if the business is not that of the assessee itself.

HDFC Bank Ltd. v. DCIT
383 ITR 529 · 2016 · High Court
408
citing judgments

Where an assessee has sufficient interest-free funds, investments yielding exempt income are presumed to be made out of such funds, precluding disallowance of related interest expenditure under section 14A.

Judgments citing Section 36(1)(iii)

M/S.Apollo Tyres Ltd, Cochin vs. The Principal Commissioner of Incometax, Cochin

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

ITA 609/COCH/2017[2013-14]Status: DisposedITAT Cochin01 Sept 2025AY 2013-14

Bench: Shri Inturi Rama Rao, Am & Shri Rahul Chaudhary, Jm Assessment Year: 2013-14 Apollo Tyres Ltd. .......... Appellant 3Rd Floor, Areekal Mansion, Panampilly Nagar, Kochi 682036 [Pan: Aaaca6990Q] Vs. Dcit, Corporate Circle-1(1), Kochi ......... Respondent Assessee By: Shri Abraham Joseph Markos, Adv. Revenue By: Shri Sanjit Kumar Das, Cit-Dr Date Of Hearing: 20.08.2025 Date Of Pronouncement: 01.09.2025

For Appellant: Shri Abraham Joseph Markos, AdvFor Respondent: Shri Sanjit Kumar Das, CIT-DR
Section 115JSection 143(3)Section 32Section 32(1)(iia)Section 35Section 43(1)Section 92C

narrative on how this aspect of the matter is examined by the Courts, we refer to the following decisions: Core Health Care Ltd: Section 36(1)(iii) of the Income-tax Act, 1961, has to be read on its own terms: it is a code by itself. It makes ... carried on by the assessee in the year of account. Unlike Section 37 which expressly excludes an expense of a capital nature, section 36(1)(iii) emphasises the user of the capital and not the user of the asset which comes into existence as a result of the borrowed capital

Mr. Ashish Arora, Ludhiana vs. DCIT, Ludhiana

In the result, appeal of the Assessee is dismissed

ITA 1152/CHANDI/2014[2010-11]Status: DisposedITAT Chandigarh01 Sept 2025AY 2010-11

Bench: Shri Laliet Kumar & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 1152/Chd/2014 "नधा"रण वष" / Assessment Year : 2010-11 Mr. Ashish Arora, The Dcit B-2, Kitchlu Nagar, बनाम Circle Iii, Ludhiana Rishi Nagar, Vs. Ludhiana "थायी लेखा सं./ Pan No: Adkpa1111B अपीलाथ"/Appellant ""यथ"/Respondent ( Physical Hearing ) "नधा"रती क" ओर से/Assessee By : Sh. Sudhir Sehgal, Advocate राज"व क" ओर से/ Revenue By : Sh. Manav Bansal, Cit Dr सुनवाई क" तार"ख/Date Of Hearing : 07.07.2025 उदघोषणा क" तार"ख/Date Of Pronouncement : 01.09.2025 आदेश/Order Per Krinwant Sahay, Am : Appeal In This Case Has Been Filed By The Assessee Against The Order Dated 19.02.2014 Passed By The Ld. Commissioner Of Income Tax (Appeals)-1. Ludhiana [Herein Referred To As Cit(A)]. The Captioned Appeal Was Dismissed For Non-Prosecution Vide Order Dated 26.7.2016 But Later On The Assessee Filed A Misc. Application Which 1152-Chd-2014 Ashish Arora, Ludhiana 2

For Appellant: Sh. Sudhir Sehgal, AdvocateFor Respondent: Sh. Manav Bansal, CIT DR
Section 133(6)Section 143(3)Section 36(1)(iii)Section 68

Income tax (Appeal-1) Ludhiana has erred in confirming the addition of Rs. 23,16,479/- on account of disallowance of interests under section 36(1)(iii) of the Income tax Act 1961 on the basis of observation made by the Assessing Officer while completing the assessment under section

Assistant Commissioner of Income Tax, Circle-2, Kota vs. Chambal Fertilizers and Chemicals Ltd., Kota

56. As a result, as regards the issue of allowance/disallowance of

ITA 1099/JPR/2024[2016-17]Status: DisposedITAT Jaipur27 Aug 2025AY 2016-17
For Appellant: Shri P.J. Pardiwala, AdvFor Respondent: Shri Rajesh Ojha, CIT &
Section 14ASection 36(1)Section 36(1)(iii)

time, Appellate Tribunal had issued following directions to Learned CIT (A):- “The AO has made the disallowance of interest invoking the provisions of section 36(1) (iii) holding that the assessee had utilised the borrowed funds lying in its cash credit account for making the investment in subsidiary companies ... totally ignored the whole discussions and findings of the AO which have been rendered in the context of section 36(1)(iii) of the Act and has not given any findings as to why the provisions of section 36(1)(iii) are not attracted in the instant case. The ground

Assistant Commissioner of Income Tax, Circle-2, Kota vs. Chambal Fertilizers and Chemicals Ltd, Kota

56. As a result, as regards the issue of allowance/disallowance of

ITA 1098/JPR/2024[2015-16]Status: DisposedITAT Jaipur27 Aug 2025AY 2015-16
Section 14ASection 36(1)Section 36(1)(iii)

time, Appellate Tribunal had issued following directions to Learned CIT (A):- “The AO has made the disallowance of interest invoking the provisions of section 36(1) (iii) holding that the assessee had utilised the borrowed funds lying in its cash credit account for making the investment in subsidiary companies ... totally ignored the whole discussions and findings of the AO which have been rendered in the context of section 36(1)(iii) of the Act and has not given any findings as to why the provisions of section 36(1)(iii) are not attracted in the instant case. The ground

Assistant Commissioner of Income Tax, Circle-2, Kota vs. Chambal Fertilizers and Chemicals Ltd., Kota

ITA 1097/JPR/2024[2011-12]Status: DisposedITAT Jaipur27 Aug 2025AY 2011-12

Bench: SHRI GAGAN GOYAL (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: Shri P.J. Pardiwala, AdvFor Respondent: Shri Rajesh Ojha, CIT &
Section 14ASection 36(1)Section 36(1)(iii)

time, Appellate Tribunal had issued following directions to Learned CIT (A):- “The AO has made the disallowance of interest invoking the provisions of section 36(1) (iii) holding that the assessee had utilised the borrowed funds lying in its cash credit account for making the investment in subsidiary companies ... totally ignored the whole discussions and findings of the AO which have been rendered in the context of section 36(1)(iii) of the Act and has not given any findings as to why the provisions of section 36(1)(iii) are not attracted in the instant case. The ground

Assistant Commissioner of Income Tax, Circle-2, Kota vs. Chambal Fertilizers and Chemicals Ltd, Kota

ITA 1091/JPR/2024[2017-18]Status: DisposedITAT Jaipur27 Aug 2025AY 2017-18

Bench: SHRI GAGAN GOYAL (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: Shri P.J. Pardiwala, AdvFor Respondent: Shri Rajesh Ojha, CIT &
Section 14ASection 36(1)Section 36(1)(iii)

time, Appellate Tribunal had issued following directions to Learned CIT (A):- “The AO has made the disallowance of interest invoking the provisions of section 36(1) (iii) holding that the assessee had utilised the borrowed funds lying in its cash credit account for making the investment in subsidiary companies ... totally ignored the whole discussions and findings of the AO which have been rendered in the context of section 36(1)(iii) of the Act and has not given any findings as to why the provisions of section 36(1)(iii) are not attracted in the instant case. The ground

Assistant Commissioner of Income Tax, Circle-2, Kota vs. Chambal Fertilizers and Chemicals Ltd, Kota

ITA 1090/JPR/2024[2010-11]Status: DisposedITAT Jaipur27 Aug 2025AY 2010-11

Bench: SHRI GAGAN GOYAL (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: Shri P.J. Pardiwala, AdvFor Respondent: Shri Rajesh Ojha, CIT &
Section 14ASection 36(1)Section 36(1)(iii)

time, Appellate Tribunal had issued following directions to Learned CIT (A):- “The AO has made the disallowance of interest invoking the provisions of section 36(1) (iii) holding that the assessee had utilised the borrowed funds lying in its cash credit account for making the investment in subsidiary companies ... totally ignored the whole discussions and findings of the AO which have been rendered in the context of section 36(1)(iii) of the Act and has not given any findings as to why the provisions of section 36(1)(iii) are not attracted in the instant case. The ground

Manglayatan Projects P.Ltd, New Delhi vs. Addl.CIT, Special Range-4, New Delhi

In the result, the appeal filed by the assessee stands Partly

ITA 5527/DEL/2018[2014-15]Status: DisposedITAT Delhi27 Aug 2025AY 2014-15

Bench: Shri Anubhav Sharma & Shri Krinwant Sahay, Accoutant Member Asstt. Year : 2014-15 Manglayatan Projects Pvt. Ltd., Vs. Addl. Cit, Special Range-04, A-86, Gali No. 9, New Delhi Chander Vihar, Mandawali, New Delhi (Pan: Aaicm3804H) (Appellant) (Respondent) Appellant By : Sh. Prateek Mittal, Ca Respondent By : Ms. Harpreet Kaur Hansra, Sr. Dr. Date Of Hearing 20.08.2025 Date Of Pronouncement 27.08.2025 Order

For Appellant: Sh. Prateek Mittal, CAFor Respondent: Ms. Harpreet Kaur Hansra, SR. DR
Section 131Section 143(3)Section 14ASection 36(1)(iii)Section 68

erred on facts and in law in upholding the action of AO in incorrectly invoking the provisions of Section 36(1)(iii) of the Income tax Act, 1961 and making the addition of Rs. 2,20,500/- although the appellant had sufficient capital and other non-interest bearing funds ... given to the group concerns out of commercial expediency, hence the interest paid is required to be allowed in view of provisions of section 36(1)(iii) of the I.T. Act. The Ld. AR has submitted that that the overall loan given out to M/s Parayas Infosolutions

G R N Finsec Private Limited, Mumbai vs. Assistant Commissioner of Income Tax, Mumbai

In the result, the appeal filed by the assessee in ITA No

ITA 5341/MUM/2024[2016-17]Status: DisposedITAT Mumbai26 Aug 2025AY 2016-17

Bench: Shri Vikram Singh Yadav & Shri Sandeep Gosain

For Appellant: Shri Madhur Agrawal &For Respondent: Shri Swapnil Choudhary
Section 143(3)Section 14ASection 36(1)Section 36(1)(iii)

funds to make such investments during the year to the tune of Rs 39,62,500/- and no disallowance is called for under section 36(1)(iii) of the Act. In the result, ground of appeal is allowed. 10. Regarding Grounds No. 2 to 6, it was submitted that

G R N Finsec Private Limited, Mumbai vs. Deputy Commissioner of Income Tax - Circle 1(1)(2), Mumbai

In the result, the appeal filed by the assessee in ITA No

ITA 5329/MUM/2024[2015-16]Status: DisposedITAT Mumbai26 Aug 2025AY 2015-16

Bench: Shri Vikram Singh Yadav & Shri Sandeep Gosain

For Appellant: Shri Madhur Agrawal &For Respondent: Shri Swapnil Choudhary
Section 143(3)Section 14ASection 36(1)Section 36(1)(iii)

funds to make such investments during the year to the tune of Rs 39,62,500/- and no disallowance is called for under section 36(1)(iii) of the Act. In the result, ground of appeal is allowed. 10. Regarding Grounds No. 2 to 6, it was submitted that

Goldman Sachs (India) Finance Private Limited, Mumbai vs. Assessment Unit, Income-Tax Department, New Delhi

In the result, the appeal by the assessee is partly allowed for statistical

ITA 6766/MUM/2024[AY 2021-22]Status: DisposedITAT Mumbai22 Aug 2025

Bench: Shri Narendra Kumar Billaiyashri Sandeep Singh Karhail

For Appellant: Shri Madhur AgrawalFor Respondent: Ms. Neena Jeph, CIT-DR
Section 142(1)Section 143(1)Section 143(1)(a)Section 143(2)Section 143(3)Section 144C(1)Section 144C(5)Section 253Section 32Section 37(1)

also liable to undertake the alternate disallowance of the payment as the same fails to fulfils the provisions of section 36(1)(iii) and section 37 of the Act. Accordingly, the learned DRP held that even if the transfer pricing adjustment are not upheld, the entire interest payment of Rs.133 ... disallowable under the provisions of section 36(1)(iii) / section 37 of the Act. In conformity with the direction issued by the learned DRP, the AO, vide final assessment order made a disallowance of the entire interest payment of Rs.133,71,83,173/- under section 36/37 of the Act. Being

Abhishek Mehta, Chennai vs. ITO, Corporate Circle-3(1), Chennai

In the result, both the appeals filed by the assessee are allowed

ITA 898/CHNY/2025[2020-21]Status: DisposedITAT Chennai21 Aug 2025AY 2020-21

Bench: Shri Manu Kumar Giri & Shri Jagadishआयकर अपील सं./Ita Nos.897 & 898/Chny/2025 िनधा<रण वष< /Assessment Years: 2018-19 & 2020-21

For Appellant: Shri D.Anand, AdvocateFor Respondent: Ms. Gouthami Manivasagam, JCIT
Section 36(1)Section 36(1)(iii)

facts of the case. 2. The National Faceless Appeal Centre erred in upholding the interest disallowance made by the AO under section 36(1) (iii) of the Income Tax Act, 1961, on the ground that the rate of interest paid on unsecured loans was higher than the interest received ... expenditure must be determined from the viewpoint of the assessee, not the Revenue. 4. The National Faceless Appeal Centre ought to have seen Section 36(1) (iii) allows a deduction for interest on borrowed capital used for business purposes without specifying any benchmark for the interest rate. The tax authorities

Abhishek Mehta, Chennai vs. ITO, Corporate Circle-3(1), Chennai

In the result, both the appeals filed by the assessee are allowed

ITA 897/CHNY/2025[2018-19]Status: DisposedITAT Chennai21 Aug 2025AY 2018-19

Bench: Shri Manu Kumar Giri & Shri Jagadish

For Appellant: Shri D.Anand, AdvocateFor Respondent: Ms. Gouthami Manivasagam, JCIT
Section 36(1)Section 36(1)(iii)

facts of the case. 2. The National Faceless Appeal Centre erred in upholding the interest disallowance made by the AO under section 36(1) (iii) of the Income Tax Act, 1961, on the ground that the rate of interest paid on unsecured loans was higher than the interest received ... expenditure must be determined from the viewpoint of the assessee, not the Revenue. 4. The National Faceless Appeal Centre ought to have seen Section 36(1) (iii) allows a deduction for interest on borrowed capital used for business purposes without specifying any benchmark for the interest rate. The tax authorities

Ideal Energy Projects Limited, Nagpur vs. Central Circle 5(3), Mumbai

In the result, the appeal by the assessee is allowed

ITA 3343/MUM/2025[2012-2013]Status: DisposedITAT Mumbai21 Aug 2025AY 2012-2013

Bench: Shri Narendra Kumar Billaiyashri Sandeep Singh Karhailideal Energy Projects Limited., Plot No.1601, 5Th Floor, Gupta Tower, Science College Road, Civil Lines, Nagpur, Mumbai - 440001 ............... Appellant Pan : Aabci8643M V/S Deputy Commissioner Of Income Tax, Central Circle – 5(3), ……………… Respondent Room No.426, 4Th Floor, Kautilya Bhavan, C- Block, Bandra Kurla Complex, Bandra East, Mumbai Assessee By : Shri Hitesh P. Shah (Virtually Appear) Revenue By : Mr. Virabhadra S. Mahajan, Cit-Dr

For Appellant: Shri Hitesh P. Shah (Virtually appear)For Respondent: Mr. Virabhadra S. Mahajan, CIT-DR
Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 250Section 271(1)(c)Section 36(1)(iii)Section 57

though upheld the disallowance of interest expenditure made under section 57 of the Act by the AO, however, allowed the interest paid under section 36(1)(iii) of the Act. Further, part of the interest was also added to the cost of the WIP. We find that the findings ... levied was subsequently deleted by the learned CIT(A) as the interest expenditure 5 was partly allowed under section 36(1)(iii) of the Act and party was added to the total cost of WIP. Thus, the only disallowance on the basis of which the impugned penalty was levied

The Dy.CIT, Central Circle-1, Vadodara vs. Pawan Edifice Pvt. Ltd., Vadodara

Appeals are partly allowed for

ITA 529/AHD/2023[2013-14]Status: DisposedITAT Ahmedabad20 Aug 2025AY 2013-14
For Appellant: Ms. Amrin Pathan, ARFor Respondent: Shri Ashok Kumar Suthar, Sr. DR
Section 115JSection 139(1)Section 143(2)Section 143(3)Section 14ASection 36Section 68Section 80G

Revenue's appeal to the extent indicated above. Issue 2 - Charging of Notional interest on advances given to related parties / disallowance under section 36(1)(iii) 30. For A.Y. 2013–14, the Assessing Officer noted from the books of account and details furnished that the assessee had advanced sums without ... assessee submitted that the assessee had sufficient own funds to make the impugned advances and, therefore, no disallowance of interest under section 36(1)(iii) was warranted. In respect of two non-related parties, namely, (i) Godiji Realty Pvt. Ltd. – Rs.2,45,00,000/-, and (ii) Venugopal Infrastructure – Rs.35

Pawan Edifice Pvt. Ltd., Vadodara vs. The Dy.CIT, Circle-2(1)(2), Vadodara

Appeals are partly allowed for

ITA 478/AHD/2023[2014-15]Status: DisposedITAT Ahmedabad20 Aug 2025AY 2014-15

Bench: Ms Suchitra Kamble

For Appellant: Ms. Amrin Pathan, ARFor Respondent: Shri Ashok Kumar Suthar, Sr. DR
Section 115JSection 139(1)Section 143(2)Section 143(3)Section 14ASection 36Section 68Section 80G

Revenue’s appeal to the extent indicated above. Issue - 2 - Charging of Notional interest on advances given to related parties / disallowance under section 36(1)(iii) 30. For A.Y. 2013-14, the Assessing Officer noted from the books of account and details furnished that the assessee had advanced sums without ... assessee submitted that the assessee had sufficient own funds to make the impugned advances and, therefore, no disallowance of interest under section 36(1)(iii) was warranted. In respect of two non-related parties, namely, (i) Godiji Realty Pvt. Ltd. - Rs. 2,45,00,000/-, and (ii) Venugopal Infrastructure

Pawan Edifice Pvt. Ltd., Vadodara vs. The Dy.CIT, Circle-2(1)(2), Vadodara

ITA 477/AHD/2023[2013-14]Status: DisposedITAT Ahmedabad20 Aug 2025AY 2013-14
For Appellant: Ms. Amrin Pathan, ARFor Respondent: Shri Ashok Kumar Suthar, Sr. DR
Section 115JSection 139(1)Section 143(2)Section 143(3)Section 14ASection 36Section 68Section 80G

Revenue's appeal to the extent indicated above. Issue 2 - Charging of Notional interest on advances given to related parties / disallowance under section 36(1)(iii) 30. For A.Y. 2013–14, the Assessing Officer noted from the books of account and details furnished that the assessee had advanced sums without ... assessee submitted that the assessee had sufficient own funds to make the impugned advances and, therefore, no disallowance of interest under section 36(1)(iii) was warranted. In respect of two non-related parties, namely, (i) Godiji Realty Pvt. Ltd. – Rs.2,45,00,000/-, and (ii) Venugopal Infrastructure – Rs.35

Paltex, Mumbai vs. ITO Ward 24(3)(1) Mumbai, Mumbai

In the result, grounds No

ITA 1301/MUM/2025[2013-14]Status: DisposedITAT Mumbai20 Aug 2025AY 2013-14

Bench: Shri Pawan Singh(Hybrid Hearing) Paltex, Ito, Ward – 24(3)(1), Plot No.41, Pal House, Vs Piramal Chambers, Marol Co-Operative Society, Lalbaug, Lower Parel, Andherei Kural Road, Mumbai-400012 Andheri (East),Mumbai-400059. [Pan No. Aaafp 1973 F] Appellant / Assessee Respondent / Revenue

Section 254(1)Section 28Section 36(1)(iii)Section 40Section 57Section 68Section 71

interest income in their individual income and paid due tax thereon. Therefore, in substance, there is no loss to revenue. The provisions of section 36(1)(iii) are not applicable to the interest on partners capital, rather, such payments are to be governed exclusively by section 40(b). In support

M/S Gvk Jaipur Expressway Private Limited, Telangana vs. PCIT 2, Jaipur

In the result, the appeal of the assessee is allowed

ITA 248/JPR/2023[2018-19]Status: DisposedITAT Jaipur19 Aug 2025AY 2018-19
For Appellant: Shri Tarun Mittal, C.AFor Respondent: Shri Arvind Kumar, CIT-DR
Section 115Section 115JSection 143(3)Section 14ASection 263Section 36(1)(iii)Section 80

earlier orders so passed by his ld. predecessor for A.Y 2012-13 and A.Y 2013-14 in terms of invocation of provisions of section 36(1)(iii) of the Act instead of section 14A of the Act. Given that there are no changes in the facts and circumstances ... Godrej & Boyce Manufacturing Company Ltd (Supra), we reverse the said findings of the ld CIT(A) and uphold the applicability of provisions of section 36(1)(iii) of the Act for the purposes of making the disallowance of interest expenses debited in the profit/loss account for these two assessment years

DCIT, Jaipur vs. Gvk Jaipur Expressway Pvt Ltd, Jaipur

In the result, the appeal of the revenue for the years [A

ITA 307/JPR/2021[2017-18]Status: DisposedITAT Jaipur19 Aug 2025AY 2017-18

Bench: Us. Moreover, The Assessee Has Also Filed Cross Objections In Both The

For Appellant: Shri Tarun Mittal, C.AFor Respondent: Shri Arvind Kumar, CIT-DR
Section 115JSection 14ASection 250Section 36(1)(va)Section 43B

आयकर अपीलीय अधिकरण, जयपुर न्यायपीठ, जयपुर IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES,”A” JAIPUR डा० एस. सीतालक्ष्मी, न्यायिक