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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)

Shah Construction Company Ltd, Mumbai vs. Dy Commissioner of Income Tax-Cenral Circle-1(3), Mumbai

In the result, all the appeals of the assessee are partly allowed

ITA 864/MUM/2023[2018-19]Status: DisposedITAT Mumbai23 Aug 2023AY 2018-19

Bench: Shri Aby T Varkey & Shri Amarjit Singh

For Appellant: M. SubramanianFor Respondent: Ram Krishna Kedia
Section 143(3)Section 148Section 234B

added the interest on loans borrowed to the existing work-in-progress and disallowed the claim of interest expenditure under section 36(1)(iii) of the Act. 47. The AO has not brought on record any material to establish that the impugned interest expenditure were pertained to the loans borrowed

Shah Construction Company Ltd, Mumbai vs. Dy Commissioner of Income Tax-Cenral Circle-1(3), Mumbai

In the result, all the appeals of the assessee are partly allowed

ITA 863/MUM/2023[2016-17]Status: DisposedITAT Mumbai23 Aug 2023AY 2016-17

Bench: Shri Aby T Varkey & Shri Amarjit Singh

For Appellant: M. SubramanianFor Respondent: Ram Krishna Kedia
Section 143(3)Section 148Section 234B

added the interest on loans borrowed to the existing work-in-progress and disallowed the claim of interest expenditure under section 36(1)(iii) of the Act. 47. The AO has not brought on record any material to establish that the impugned interest expenditure were pertained to the loans borrowed

Shah Construction Company Ltd, Mumbai vs. Dy Commissioner of Income Tax-Cenral Circle-1(3), Mumbai

In the result, all the appeals of the assessee are partly allowed

ITA 862/MUM/2023[2014-15]Status: DisposedITAT Mumbai23 Aug 2023AY 2014-15

Bench: Shri Aby T Varkey & Shri Amarjit Singh

For Appellant: M. SubramanianFor Respondent: Ram Krishna Kedia
Section 143(3)Section 148Section 234B

added the interest on loans borrowed to the existing work-in-progress and disallowed the claim of interest expenditure under section 36(1)(iii) of the Act. 47. The AO has not brought on record any material to establish that the impugned interest expenditure were pertained to the loans borrowed

Shah Construction Company Ltd, Mumbai vs. Dy Commissioner of Income Tax-Cenral Circle-1(3), Mumbai

In the result, all the appeals of the assessee are partly allowed

ITA 861/MUM/2023[2013-14]Status: DisposedITAT Mumbai23 Aug 2023AY 2013-14

Bench: Shri Aby T Varkey & Shri Amarjit Singh

For Appellant: M. SubramanianFor Respondent: Ram Krishna Kedia
Section 143(3)Section 148Section 234B

added the interest on loans borrowed to the existing work-in-progress and disallowed the claim of interest expenditure under section 36(1)(iii) of the Act. 47. The AO has not brought on record any material to establish that the impugned interest expenditure were pertained to the loans borrowed

Shah Construction Company Ltd, Mumbai vs. Dy Commissioner of Income Tax-Cenral Circle-1(3), Mumbai

In the result, all the appeals of the assessee are partly allowed

ITA 860/MUM/2023[2011-12]Status: DisposedITAT Mumbai23 Aug 2023AY 2011-12

Bench: Shri Aby T Varkey & Shri Amarjit Singh

For Appellant: M. SubramanianFor Respondent: Ram Krishna Kedia
Section 143(3)Section 148Section 234B

added the interest on loans borrowed to the existing work-in-progress and disallowed the claim of interest expenditure under section 36(1)(iii) of the Act. 47. The AO has not brought on record any material to establish that the impugned interest expenditure were pertained to the loans borrowed

Assistant Commissioner of Income Tax Circle- 3, Srinagar vs. Measage Saifco Ceements Private Limited, Srinagar

In the result, the appeal of the Department and CO of the Assesse is 23

ITA 451/ASR/2019[2013-14]Status: DisposedITAT Amritsar23 Aug 2023AY 2013-14

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

For Appellant: NoneFor Respondent: Sh. Rajiv Wadhera, Sr. DR
Section 143(3)Section 36Section 36(1)(iii)

will not help the cause of the assessee company as it is important to emphasize here that the object of the provisions under section 36(1)(iii) of the Income-tax Act, 1961 is not to enable an assessee to make a large borrowing and create a liability for payment ... used in the business, interest paid on such borrowing is a proper charge on the business and is allowable as expenditure. Under section 36(1)(iii) of the Income-tax Act, 1961, the amounts diverted not being used for the purposes of the business, interest relating to the amount diverting

M/S Mafatlal Industries Limited, Mumbai vs. Dy Commissioner of Income Tax-Central Circle-8(2), Mumbai

In the result, appeal is partly allowed

ITA 881/MUM/2023[2011-12]Status: DisposedITAT Mumbai22 Aug 2023AY 2011-12

Bench: Shri Amit Shukla () & Ms. Padmavathy S. ()

Section 143(1)Section 14ASection 36(1)(iii)Section 40

Assessing Officer completed the assessments by making the following disallowances:- (1) Disallowance under section 14A Rs. 70,89,262/- (2) Disallowance under section 36(1)(iii) Rs. 1,32,49,990/- 3 ITA 881/Mum/2023 Mafatlal Industries Limited (3) Pooja expenses Rs. 1,43,254/- (4) Expenses paid to relatives ... assessee by restricting the disallowance to the extent of the exempt income of Rs.24,89,968/-. On the disallowance of interest under section 36(1)(iii) of Rs.1,32,49,990/-, the CIT(A) deleted the substantial amount of disallowance and upheld the disallowance pertaining only to Silvia Apparels Limited

DCIT, Circle-27(1), New Delhi vs. Uk India Business Council India P.Ltd, Gurgaon

In the result, the appeal of the Revenue is partly allowed for statistical purpose

ITA 3249/DEL/2019[2015-16]Status: DisposedITAT Delhi18 Aug 2023AY 2015-16

Bench: filing of return replying on the judgment of jurisdiction High Court given in the case of CIT vs. AIMIL. Ltd. without appreciating the judgment given by the Hon'ble High Court in the case of M/s. Unifac Management Services India Pvt. Ltd. vs. The Deputy Commissioner of Income Tax, Cooperation Circle- 3(2), WP No. 5264 of 2018 (Madras), CIT-2, vs. Gujrat State Road Transport Cooperation (2014) 366 ITR 170 (Guj) and CTT vs. Merchem Ltd. (2015) 280 CTR 381 (Kerala) and CBDT's Circular No. 22/2

Section 143(3)Section 36(1)(vii)

despite continuous follow up and reminders and the said debt has been written off in its account which meets requirement of provision of Section 36(1)(iii) of the Act. In view of the factual matrix of this grounds and with the support of judicial precedents in the case

Opg Securities Pvt. Ltd., New Delhi vs. Addl. CIT, Special Range- 7, New Delhi

In the result, the appeal of the assessee is allowed

ITA 1885/DEL/2018[2014-15]Status: DisposedITAT Delhi18 Aug 2023AY 2014-15

Bench: Shri C.M. Garg & Shri M. Balaganeshassessment Year: 2014-15 Opg Securities Pvt. Ltd. Vs Addl. Cit, Opg House, 4/10, Asaf Ali Road, Spl. Range-7, New Delhi – 110 002. New Delhi. Pan: Aaaco1081C

For Appellant: Ms Somya Jain, CAFor Respondent: Ms Raja Rajeswari R, Sr. DR
Section 143(3)Section 14ASection 153(1)Section 36(1)(iii)

income and therefore, there was no warrant to make any further disallowance under section 14A of the Act. Re: Disallowance of interest under section 36(1)(iii) 3. That the CIT(A) erred on facts and in law in upholding disallowance of interest expenditure to the extent of Rs.1 ... under section 36(1)(iii) of the Act. 2 3.1 That the CIT(A) erred in holding that interest bearing funds were utilized for making interest free loans/ advances, without any commercial expediency or business purpose, without appreciating that: (a) borrowed funds were utilized for business purposes

Shri Mahendra Kumar Goyal, HUF, Pali vs. ITO, Ward-2, Pali

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

ITA 213/JODH/2018[2012-13]Status: DisposedITAT Jodhpur17 Aug 2023AY 2012-13

Bench: Shri Pavan Kumar Gadale & Shri Dr. Dipak P. Ripoteshri Mahendra Kumar Vs. Ito – Ward-2 Goyal Huf, Pali, Marwar, M/S Merita &Co,Ca Pali-306401, 244,Kamalanehru Rajasthan Nagar,Opp;Prakartic Chikitsa Kendra, Chopasni Road, Jodhpur-348008, Rajasthan Pan/Gir No. : Aaehm7139L Appellant .. Respondent Assessee By : Shri N. R Mertia, Ca Revenue By : Ms. Nidhi Nair, Jcit -Dr Date Of Hearing 14.08.2023 Date Of Pronouncement 17.08.2023 आदेश / O R D E R Per Pavan Kumar Gadale Jm: The Assessee Has Filed The Appeal Against The Order Of The Commissioner Of Income Tax (Appeals)(Cit(A)-I, Jodhpur Passed U/S 143(3) & 250 Of The Income Tax Act, 1961. The Assessee Has Raised The Fallowing Grounds Of Appeal As Under: Sh. Mahendra Kumar Goyal Huf, Pali. 1. In The Facts & Circumstances Of The Case The Ld. Commissioner Of Income Tax (Appeals-1), Jodhpur Has Erred In Law & Facts In Maintaining The Disallowance Of Interest Made By Ld. A.O Of Rs. 4,61,473/- (3,11,690/- + 1,49,783/-) By Invoking Sec. 36(1)(Iii) Of The Act Which The Ld. Cit(A) Erroneously & Unjustifiedly Held As Right Actions On The Part Of The Id. A.O. The Actions Being Erroneous & Unjustified May Kindly Be Cancelled. The Hon'Ble Itat May Kindly Allow The Appeal By Allowing The Claimed Interest As Revenue Expenditure.

For Appellant: Shri N. R Mertia, CAFor Respondent: Ms. Nidhi Nair, JCIT -DR
Section 143(1)Section 143(2)Section 143(3)Section 36(1)(iii)

IN THE INCOME TAX APPELLATE TRIBUNAL “DB” BENCH, JODHPUR BEFORE SHRI PAVAN KUMAR GADALE, JUDICIAL MEMBER & SHRI DR. DIPAK P

Mitra Trading & Exports Pvt. Ltd., Mumbai vs. ACIT 7(2)(1), Mumbai

In the result, appeal of the assessee is dismissed

ITA 6389/MUM/2019[2014-15]Status: DisposedITAT Mumbai14 Aug 2023AY 2014-15

Bench: Shri Amit Shukla & Shri Gagan Goyalm/S Mitra Trading & Exports Pvt. Ltd, Unit No. 355, 3Rd Floor, Kalyandas Udyog Bhavan, S.H. Tandel Marg, Near- Century Bhavan, Prabhadevi Mumbai-400 025 Pan: Aafcm6767N ...... Appellant Vs. Acit 7(2) (1) Mumbai, Maharashtra Mumbai. ..... Respondent

For Appellant: Shri Rajeev Khandelwal, Ld. ARFor Respondent: Smt. Mahita Nair, CIT-DR
Section 143(2)Section 250Section 36(1)

transaction along with the condition wholly and exclusively for the purposes of the Act. 7. In this connection we may refer to section 36(1) (iii) of the Income-tax Act, 1961 (hereinafter referred to as the 'Act') which states that "the amount of the interest paid in respect ... commercial expediency in giving interest-free loan to the allied concern and the interest attributable to interest-free advances was not allowable under section 36(1)(iii). The High Court confirmed the order of the tribunal. The facts of the matter under consideration are almost similar to the case cited

ACIT Circle-54(1), New Delhi vs. National Agricultural Cooperative Marketing Federation of India, New Delhi

ITA 3555/DEL/2019[2014-15]Status: DisposedITAT Delhi09 Aug 2023AY 2014-15

Bench: Dr. B. R. R. Kumar & Shri Yogesh Kumar U.S.

For Appellant: Sh. Herin Mehta, CA, ShFor Respondent: Ms. Sarita Kumari, CIT DR
Section 10Section 14ASection 2Section 37(1)Section 40Section 43(5)(d)Section 72Section 80

interest expenditure to the extent attributable to the tie-up advances is held by the A.O. as not allowable under the provisions of Section 36(1)(iii) of the Income Tax Act as the amount was not used for the purpose of business. The claim of interest National Agricultural Cooperative ... interest expenditure to the extent attributable to the tie-up advances is held by the A.O . not allowable under the provisions of section 36(1)(iii) of the Income Tax Act as the amount is not used for the purpose of business. The claim of interest National Agricultural Cooperative Marketing

ACIT Circle-54(1), New Delhi vs. National Agricultural Cooperative Marketing Federation of India, New Delhi

ITA 3554/DEL/2019[2012-13]Status: DisposedITAT Delhi09 Aug 2023AY 2012-13

Bench: Dr. B. R. R. Kumar & Shri Yogesh Kumar U.S.

For Appellant: Sh. Herin Mehta, CA, ShFor Respondent: Ms. Sarita Kumari, CIT DR
Section 10Section 14ASection 2Section 37(1)Section 40Section 43(5)(d)Section 72Section 80

interest expenditure to the extent attributable to the tie-up advances is held by the A.O. as not allowable under the provisions of Section 36(1)(iii) of the Income Tax Act as the amount was not used for the purpose of business. The claim of interest National Agricultural Cooperative ... interest expenditure to the extent attributable to the tie-up advances is held by the A.O . not allowable under the provisions of section 36(1)(iii) of the Income Tax Act as the amount is not used for the purpose of business. The claim of interest National Agricultural Cooperative Marketing

ACIT Circle-54(1), New Delhi vs. National Agricultural Cooperative Marketing Federation of India, New Delhi

ITA 3553/DEL/2019[2011-12]Status: DisposedITAT Delhi09 Aug 2023AY 2011-12

Bench: Dr. B. R. R. Kumar & Shri Yogesh Kumar U.S.

For Appellant: Sh. Herin Mehta, CA, ShFor Respondent: Ms. Sarita Kumari, CIT DR
Section 10Section 14ASection 2Section 37(1)Section 40Section 43(5)(d)Section 72Section 80

interest expenditure to the extent attributable to the tie-up advances is held by the A.O. as not allowable under the provisions of Section 36(1)(iii) of the Income Tax Act as the amount was not used for the purpose of business. The claim of interest National Agricultural Cooperative ... interest expenditure to the extent attributable to the tie-up advances is held by the A.O . not allowable under the provisions of section 36(1)(iii) of the Income Tax Act as the amount is not used for the purpose of business. The claim of interest National Agricultural Cooperative Marketing

National Agricultural Cooperative Marketing Federation of India, New Delhi vs. ACIT Circle-32(1), New Delhi

ITA 3000/DEL/2019[2011-12]Status: DisposedITAT Delhi09 Aug 2023AY 2011-12

Bench: Dr. B. R. R. Kumar & Shri Yogesh Kumar U.S.

For Appellant: Sh. Herin Mehta, CA, ShFor Respondent: Ms. Sarita Kumari, CIT DR
Section 10Section 14ASection 2Section 37(1)Section 40Section 43(5)(d)Section 72Section 80

interest expenditure to the extent attributable to the tie-up advances is held by the A.O. as not allowable under the provisions of Section 36(1)(iii) of the Income Tax Act as the amount was not used for the purpose of business. The claim of interest National Agricultural Cooperative ... interest expenditure to the extent attributable to the tie-up advances is held by the A.O . not allowable under the provisions of section 36(1)(iii) of the Income Tax Act as the amount is not used for the purpose of business. The claim of interest National Agricultural Cooperative Marketing

Regal Industries, Mumbai vs. DCIT 19(3), Mumbai

In the result, the appeal by the assessee is allowed

ITA 1737/MUM/2023[2010-2011]Status: DisposedITAT Mumbai08 Aug 2023AY 2010-2011

Bench: Shri B.R. Baskaran & Shri Sandeep Singh Karhail

For Appellant: Shri V.H. JariwalaFor Respondent: Smt. Mahita Nair
Section 142(1)Section 143Section 143(2)Section 143(3)Section 154Section 250Section 36(1)(iii)

under section 143(3) of the Act the only addition made by the AO was in respect of disallowance of interest expenditure under section 36(1)(iii) of the Act. Subsequently, the AO initiated the rectification proceedings on the basis of incorrectly carrying forward and setting off of losses

M/S. Lila Trading Company, Sri Ganganagar vs. ITO, Ward-1, Sriganganagar

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

ITA 71/JODH/2020[2015-16]Status: DisposedITAT Jodhpur08 Aug 2023AY 2015-16

Bench: Shri Pavan Kumar Gadale & Dr. Dipak P. Ripoteassessment Year : 2015-16 M/S Lila Trading Company, Income Tax Officer, Shop No. 97, New Dhan Mandi Vs Ward-1, Sri Ganganagar Sri Ganganagar Pan: Aaafl5911B Appellant / Assessee Respondent / Revenue Assessee By None Revenue By Ms. Nidhi Nair, Jcit-Dr Date Of Hearing 07.08.2023 Date Of Pronouncement 08.08.2023 Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Order Of Ld. Commissioner Of Income Tax (Appeals), Bikaner Dated 31.12.2019 Emanating From The Order Of Income Tax Officer, Ward-1, Sri Ganganagar Under Section 143(3) Of The Act For A.Y. 2015-16. The Grounds Of Appeal Raised By Assessee Are As Under:- “1. In Facts & Circumstances, Ld. Cit (A) Was Not Justified In Sustaining 10% Disallowance Of Rs.53,220 Made Out Of Aggregate Claim Of Rs.5,32,209 Under Five Heads Of Expenses On The Grounds That Some Of Vouchers Were Produced & Most Of The Vouchers Being Self- Made Verification Of Possibilities Of Personal Use Or Their Correctness Could Not Be Ascertained But M/S Lila Trading Company

Section 143(3)Section 234DSection 36(1)(iii)Section 37

IN THE INCOME TAX APPELLATE TRIBUNAL JODHPUR BENCH, JODHPUR BEFORE SHRI PAVAN KUMAR GADALE, JUDICIAL MEMBER AND DR. DIPAK P

Jagson International Ltd., Delhi vs. DCIT Circle-13(1), Delhi

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

ITA 902/DEL/2022[2017-18]Status: DisposedITAT Delhi04 Aug 2023AY 2017-18

Bench: Shri Saktijit Dey & Shri M. Balaganeshassessment Year: 2017-18 Jagson International Ltd., Vs Dcit, H-35, 1St Floor, Circle-13(1), Jangpura Extension, Delhi. New Delhi – 110 014. Pan: Aaacj2147A Assessment Year: 2017-18 Dcit, Vs. Jagson International Ltd., H-35, 1St Floor, Circle-13(1), Delhi Jangpura Extension, New Delhi – 110 014. Pan: Aaacj2147A (Appellant) (Respondent) Assessee By : Shri Rajiv Saxena, Ms Sumangla Saxena & Shri Shyam Sunder, Advocates Revenue By : Mohd. Gayasuddin Ansari, Cit, Dr Date Of Hearing : 08.05.2023 Date Of Pronouncement : 04.08.2023

For Appellant: Shri Rajiv SaxenaFor Respondent: Mohd. Gayasuddin Ansari, CIT, DR
Section 115JSection 115VSection 143(3)Section 407

Madhav Prasad Jatia V. CIT, (SC) 118 ITR 200 has established that the expression "for the purposes of Business & Profession" occurring in Section 36(1)(iii) is wider in scope than the expression occurring in Section 57(iii), meaning thereby that the scope for allowing a deduction under Section 36 ... under Section 57(iii). This phrase, as held in many legal pronouncements, is the most important yardstick for the allowability of deduction under Section 36(1)(iii) of Income Tax Act, 1961. While explaining the meaning of this phrase, the Hon'ble Supreme Court in the case

JCIT Circle-13(1), New Delhi vs. Jagson International Ltd., New Delhi

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

ITA 1303/DEL/2022[2017-18]Status: DisposedITAT Delhi04 Aug 2023AY 2017-18

Bench: Shri Saktijit Dey & Shri M. Balaganeshassessment Year: 2017-18 Jagson International Ltd., Vs Dcit, H-35, 1St Floor, Circle-13(1), Jangpura Extension, Delhi. New Delhi – 110 014. Pan: Aaacj2147A Assessment Year: 2017-18 Dcit, Vs. Jagson International Ltd., H-35, 1St Floor, Circle-13(1), Delhi Jangpura Extension, New Delhi – 110 014. Pan: Aaacj2147A (Appellant) (Respondent) Assessee By : Shri Rajiv Saxena, Ms Sumangla Saxena & Shri Shyam Sunder, Advocates Revenue By : Mohd. Gayasuddin Ansari, Cit, Dr Date Of Hearing : 08.05.2023 Date Of Pronouncement : 04.08.2023

For Appellant: Shri Rajiv SaxenaFor Respondent: Mohd. Gayasuddin Ansari, CIT, DR
Section 115JSection 115VSection 143(3)Section 407

Madhav Prasad Jatia V. CIT, (SC) 118 ITR 200 has established that the expression "for the purposes of Business & Profession" occurring in Section 36(1)(iii) is wider in scope than the expression occurring in Section 57(iii), meaning thereby that the scope for allowing a deduction under Section 36 ... under Section 57(iii). This phrase, as held in many legal pronouncements, is the most important yardstick for the allowability of deduction under Section 36(1)(iii) of Income Tax Act, 1961. While explaining the meaning of this phrase, the Hon'ble Supreme Court in the case

M/S. Sunil & Company, Jodhpur vs. ACIT, Circle-1, Jodhpur

In the result, appeal of the assessee is allowed

ITA 502/JODH/2018[2004-05]Status: DisposedITAT Jodhpur03 Aug 2023AY 2004-05

Bench: Its Hearing Before Your Honour.”

Section 143(2)Section 143(3)Section 36(1)(iii)

IN THE INCOME TAX APPELLATE TRIBUNAL JODHPUR BENCH, JODHPUR VIRTUAL HEARING BEFORE: DR. S. SEETHALAKSHMI, JM & SHRI RATHOD KAMLESH JAYANTBHAI