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“Section 37(1)”

Section References (mined)Section 37Section 37(1)4,308 judgments

The decision most relied on for Section 37(1) is CIT v. Reliance Utilities & Power Ltd. (313 ITR 340), cited in 2,118 judgments on BharatTax.

Leading authorities on Section 37(1)

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.

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.

Maxopp Investment Ltd. v. CIT
402 ITR 640 · 2018 · Supreme Court
1,596
citing judgments

Disallowance under Section 14A is not automatic and requires the Assessing Officer to record satisfaction before applying Rule 8D. Only investments yielding exempt income are considered for disallowance, irrespective of their strategic nature.

Cheminvest Ltd. v. CIT
378 ITR 33 · 2015 · High Court
1,569
citing judgments

A disallowance under Section 14A of the Income-tax Act, 1961, for expenditure incurred in relation to exempt income cannot be made if the assessee has not earned any exempt income during the relevant previous year.

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. 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.

Godrej & Boyce Mfg. Co. Ltd. v. DCIT
328 ITR 81 · 2010 · High Court
1,183
citing judgments

Rule 8D, for computing disallowance under Section 14A for expenses related to exempt income, applies from Assessment Year 2008-09 onwards; for prior years, a reasonable disallowance must be made. The disallowance under Section 14A cannot exceed the actual exempt income earned.

CIT v. Woodward Governor India Pvt. Ltd.
312 ITR 254 · 2009 · Supreme Court
968
citing judgments

Foreign exchange fluctuations, whether gains or losses, are inextricably linked to the underlying business transaction and must be accounted for under the mercantile system. The Supreme Court also affirmed the standard accounting principle of valuing stock at cost or net realisable value, whichever is lower.

Judgments citing Section 37(1)

Trig Detectives Pvt Ltd, Mumbai vs. DCIT-Central Circle 1(2), Mumbai

In the result, the appeals filed by the assessee bearing ITA Nos

ITA 1903/MUM/2025[2017-18]Status: DisposedITAT Mumbai02 Dec 2025AY 2017-18

Bench: Shri Anikesh Banerjee & Shri Prabhash Shankar

For Appellant: Shri Rakesh JoshiFor Respondent: Shri Ritesh Misra, CIT DR
Section 139(1)Section 153ASection 250Section 270ASection 271(1)(c)Section 271ASection 274Section 37(1)Section 40

IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “E”, MUMBAI BEFORE SHRI ANIKESH BANERJEE, JUDICIAL MEMBER AND SHRI PRABHASH SHANKAR

Trig Detectives Pvt Ltd, Mumbai vs. DCIT-Central Circle 1(2), Mumbai

In the result, the appeals filed by the assessee bearing ITA Nos

ITA 1902/MUM/2025[2016-17]Status: DisposedITAT Mumbai02 Dec 2025AY 2016-17

Bench: Shri Anikesh Banerjee & Shri Prabhash Shankar

For Appellant: Shri Rakesh JoshiFor Respondent: Shri Ritesh Misra, CIT DR
Section 139(1)Section 153ASection 250Section 270ASection 271(1)(c)Section 271ASection 274Section 37(1)Section 40

IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “E”, MUMBAI BEFORE SHRI ANIKESH BANERJEE, JUDICIAL MEMBER AND SHRI PRABHASH SHANKAR

Trig Detectives Pvt Ltd, Mumbai vs. DCIT Central Circle 1(2), Mumbai

In the result, the appeals filed by the assessee bearing ITA Nos

ITA 1901/MUM/2025[2015-16]Status: DisposedITAT Mumbai02 Dec 2025AY 2015-16

Bench: Shri Anikesh Banerjee & Shri Prabhash Shankar

For Appellant: Shri Rakesh JoshiFor Respondent: Shri Ritesh Misra, CIT DR
Section 139(1)Section 153ASection 250Section 270ASection 271(1)(c)Section 271ASection 274Section 37(1)Section 40

IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “E”, MUMBAI BEFORE SHRI ANIKESH BANERJEE, JUDICIAL MEMBER AND SHRI PRABHASH SHANKAR

Trig Detectives Pvt Ltd, Mumbai vs. DCIT Central Circle 1(2), Mumbai

In the result, the appeals filed by the assessee bearing ITA Nos

ITA 1900/MUM/2025[2014-15]Status: DisposedITAT Mumbai02 Dec 2025AY 2014-15

Bench: Shri Anikesh Banerjee & Shri Prabhash Shankar

For Appellant: Shri Rakesh JoshiFor Respondent: Shri Ritesh Misra, CIT DR
Section 139(1)Section 153ASection 250Section 270ASection 271(1)(c)Section 271ASection 274Section 37(1)Section 40

IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “E”, MUMBAI BEFORE SHRI ANIKESH BANERJEE, JUDICIAL MEMBER AND SHRI PRABHASH SHANKAR

T R Chemicals Limited, Odisha vs. PCIT Sambalpur, Odisha

In the result, appeal of the assessee is allowed

ITA 219/CTK/2025[2018-19]Status: DisposedITAT Cuttack01 Dec 2025AY 2018-19

Bench: Shri George Mathan & Shri Rajesh Kumarआयकर अपील सं/Ita No.219/Ctk/2025 (िनधा"रण वष" / Assessment Year : 2018-2019) T R Chemicals Limited, Vs Pr.Cit, Sambalpur Main Road, Subash Chowk, Rajgangpur, Odisha-770017 Pan No. :Aabct 1919 M (अपीलाथ" /Appellant) .. (""थ" / Respondent) िनधा"रती की ओर से /Assessee By : Shri K.K.Bajoria & Shri Yogesh Banka, Ars राज" की ओर से /Revenue By : Shri Vijay Singh, Sr. Dr सुनवाई की तारीख / Date Of Hearing : 01/12/2025 घोषणा की तारीख/Date Of Pronouncement : 01/12/2025 आदेश / O R D E R Per Bench : This Is An Appeal Filed By The Assessee Against The Order Passed By The Ld. Pr.Cit, Sambalpur, Dated 15.01.2025 For The Assessment Year 2018-2019. 2. It Was Submitted By The Ld. Ar That The Return Filed By The Assessee Came To Be Processed & The Assessment Came To Be Completed U/S.147 Of The Act Wherein The Purchases From M/S Mideast Integrated Steel Ltd. Were Disallowed By Invoking The Provisions Of Section 37(1) Of The Act. It Was The Submission That The Ld. Pr.Cit Invoked His Power U/S.263 Of The Act On The Ground That The Disallowances Made By The Ao U/S.37(1) Of The Act Instead Of Section 69C Of The Act, Is Erroneous & Prejudicial To The Interest Of Revenue. It Was Submitted That The Issue Is Now Squarely Covered By The Decision Of The Coordinate Bench Of The Tribunal In The Case Of Bajrang Steel & Alloys (P) Ltd., Passed In Ita No.553/Ctk/2024, Order Dated

For Appellant: Shri K.K.Bajoria & Shri Yogesh Banka, ARsFor Respondent: Shri Vijay Singh, Sr. DR
Section 147Section 263Section 37(1)Section 69C

completed u/s.147 of the Act wherein the purchases from M/s Mideast Integrated Steel Ltd. were disallowed by invoking the provisions of Section 37(1) of the Act. It was the submission that the ld. Pr.CIT invoked his power u/s.263 of the Act on the ground that the disallowances made ... clearly shows that the expenses in respect of purchases of raw materials have been disallowed by the AO by invoking the provisions of Section 37(1) of the Act. This is because the assessee was not able to 3 prove the transactions with M/s Mideast Integrated Steel Ltd. A perusal

Sandeep Kumar, New Delhi vs. ITO - Ward 1, Panipat

In the result, appeal of the assessee is allowed

ITA 4348/DEL/2025[2018-19]Status: DisposedITAT Delhi28 Nov 2025AY 2018-19

Bench: Shri Mahavir Singh & Shri Manish Agarwal[Assessment Year : 2018-19] Sandeep Kumar, Vs Ito C/O-B-50, Lgf, South Ward-1 Extension Part-Ii, Panipat New Delhi -110049 Pan-Aueps5626A Appellant Respondent Appellant By Shri Shantanu Jain, Adv. Ms. Jahnavi Khanna, Adv. Shri Gurjeet Singh, Ca Respondent By Shri Khitesh Gupta, Sr.Dr Date Of Hearing 26.11.2025 Date Of Pronouncement 28.11.2025 Order

Section 147Section 148Section 250Section 263Section 69C

nowhere in the assessment order, the AO raised any doubts about the source of such purchases. Therefore, he invoked the provisions of section 37(1) of the Act and disallowed the purchases made by the assessee. This being so, the provisions of section 69C of the Act are not applicable

Dy. Commissioner of Income Tax, Noida vs. M/S. Ace Infracity Developers Pvrivate Ltd, Noida

In the result, appeal of the Revenue is dismissed

ITA 4104/DEL/2025[2022-23]Status: DisposedITAT Delhi28 Nov 2025AY 2022-23

Bench: Shri Anubhav Sharma & Shri Manish Agarwal[Assessment Year 2022-23] Dcit Vs M/S. Ace Infracity Developers Pvt. Central Circle-1, Ltd., Plot No. Ib, Gautam Budh A.R.T.O Complex, Nagar-201301 Sector-33, Noida-201301. Pan-Aakca8693E Appellant Respondent

Section 132Section 139(1)Section 143(2)Section 143(3)Section 37Section 37(1)Section 68Section 69A

case and in law, the Ld. CIT(A)-3, Noida has erred in deleting the disallowance of Rs.41,72,005/- made under section 37(1) of the Act, without appreciating that the assessee had failed to reconcile and correctly classify the nature of disallowable expenses including interest on delayed

Sai Corp Creations Private Limited, New Delhi vs. DCIT, C R Building

In the result, the Appeal of the Assessee is partly allowed for

ITA 3451/DEL/2025[2022-23]Status: DisposedITAT Delhi28 Nov 2025AY 2022-23

Bench: Yogesh Kumar U.S. & Shri Manish Agarwalsai Corp Creations Pvt. Ltd. Vs Dcit D-8/2, Vasantvihar, Circe-22(2), C. R. Building, New Delhi New Delhi Pan: Aatcs7145L Appellant Respondent Assessee By Ms. Tanvi Khurana, Ca Revenue By Sh. Piyush Tripathi, Sr. Dr Date Of Hearing 27/11/2025 Date Of Pronouncement 28/11/2025

Section 36(1)(va)Section 37(1)

plea that the belated deposit of employees contributions to PF/ESIC governed under Section 36(1)(va) is also simultaneously amenable to deduction under Section 37(1) of the Act. In terms of the provision, Section 37(1) permits deduction of expenditure which is not in the nature of expenditure prescribed ... personal expenses of the assessee. Thus, in view of such mandate of law, the deduction of expenditure under the general clause of Section 37(1) would not extend to 4 Sai Corp Creations Pvt. Ltd. Vs. DCIT expenditure specially covered within the ambit of Section 36(1

Poonam Sabharwal, Delhi vs. ITO Ward-28(5), Delhi

In the result, the appeal of the assessee for A

ITA 1183/DEL/2025[2017-18]Status: DisposedITAT Delhi28 Nov 2025AY 2017-18

Bench: Shri C.N. Prasad & Shri Naveen Chandra

Section 143Section 143(1)Section 143(1)(a)Section 36(1)Section 36(1)(va)Section 43B

plea that the belated deposit of employees contributions to PF/ESIC governed under Section 36(1) (va) is also simultaneously amenable to deduction under Section 37(1) of the Act. In terms of the provision, Section 37(1) permits deduction of expenditure which is not in the nature of expenditure prescribed ... personal expenses of the assessee. Thus, in view of such mandate of law, the deduction of expenditure under the general clause of Section 37(1) would not extend to expenditure specially covered within the ambit of Section 36(1)(va) of the Act. The Hon'ble Supreme Court

Poonam Sabharwal, Delhi vs. ITO Ward-28(5), Delhi

In the result, the appeal of the assessee for A

ITA 1182/DEL/2025[2021-22]Status: DisposedITAT Delhi28 Nov 2025AY 2021-22

Bench: Shri C.N. Prasad & Shri Naveen Chandra

Section 143Section 143(1)Section 143(1)(a)Section 36(1)Section 36(1)(va)Section 43B

plea that the belated deposit of employees contributions to PF/ESIC governed under Section 36(1) (va) is also simultaneously amenable to deduction under Section 37(1) of the Act. In terms of the provision, Section 37(1) permits deduction of expenditure which is not in the nature of expenditure prescribed ... personal expenses of the assessee. Thus, in view of such mandate of law, the deduction of expenditure under the general clause of Section 37(1) would not extend to expenditure specially covered within the ambit of Section 36(1)(va) of the Act. The Hon'ble Supreme Court

Income Tax Officer, New Libra Kothi, Railway Road, Sirhind vs. Bhagwan Dass, Amloh Road, Mandi Gobindgarh

In the result, appeal of the Revenue is dismissed

ITA 1025/CHANDI/2024[2021-22]Status: DisposedITAT Chandigarh27 Nov 2025AY 2021-22
For Respondent: Shri Tej Mohan Singh, Advocate
Section 115BSection 133(6)Section 143(1)Section 36(1)Section 36(1)(vii)Section 68

आयकर अपीलीय अधिकरण, चण्डीगढ़ न्यायपीठ “ए”, चण्डीगढ़ IN THE INCOME TAX APPELLATE TRIBUNAL, CHANDIGARH BENCH “A”, CHANDIGARH HEARING THROUGH: PHYSICAL

Urlife Lifestyle Wellness Limited, Hyderabad vs. Assistant Commissioner of Income-Tax, Corporate Circle 4(1), Chennai

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

ITA 2160/CHNY/2025[AY 2021-22]Status: DisposedITAT Chennai27 Nov 2025

Bench: Shri George George K & Shri Jagadishआयकर अपील सं./Ita No.: 2160/Chny/2025 िनधा"रण वष"/Assessment Year: 2021-22 Urlife Lifestyle Wellness The Assistant Commissioner Ltd., Vs. Of Income Tax, 2Nd Floor, Corporate Circle – 4(1), Apollo Health City, Chennai. Apollo Hospitals Complex, Jubilee Hills, Film Nagar, Hyderabad – 500 096. Pan: Aadca 8021H (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri K. Abhiroop Bhargav, Ca ""यथ" क" ओर से/Respondent By : Ms. T. Mythili, Jcit सुनवाई क" तारीख/Date Of Hearing : 26.11.2025 घोषणा क" तारीख/Date Of Pronouncement : 27.11.2025

For Appellant: Shri K. Abhiroop Bhargav, CAFor Respondent: Ms. T. Mythili, JCIT
Section 11Section 143(3)Section 250Section 37(1)

especially when the ITO doubts the genuineness thereof. It cannot be disputed that before an assessee can become entitled to an allowance under section 37(1), he must satisfy the department of the purpose for which the amount is spent. In order to claim that an expenditure falls under section ... payment through banking channels and deduction of TDS does not give eligibility to the appellant for claiming deduction as business expenses. Provisions of section 37(1) are as under: “Any expenditure (not being expenditure of the nature described in sections 30 to 36 [***][Certain words omitted

ACIT, Mumbai vs. Avendus Capital Private Limited, Mumbai

In the result, appeal of the revenue is dismissed

ITA 6128/MUM/2025[2021-22]Status: DisposedITAT Mumbai27 Nov 2025AY 2021-22

Bench: Shri Anikesh Banerjee & Shri Girish Agrawalassessment Year: 2021-22 Dcit-14(1)(1), Mumbai Vs Avendus Capital Private Limited Room No. 432, 4Th Floor, 901, 9Th Floor Platina, Plot No. Aayakar Bhavan, M.L. Road, C-59, Bandra Kurla Complex, Mumbai 400020 Bandra East, Mumbai 400051 Pan: (Aabcc2404Q) Appellant Respondent Present For: Appellant By : Shri Ashish Mehta & Shri Pulkit Pandey, Advocates Respondent By : Shri Surendra Mohan, Sr. Dr Date Of Hearing : 26.11.2025 Date Of Pronouncement : 27.11.2025 O R D E R Per Girish Agrawal: This Appeal Filed By The Revenue Is Against The Order Of Cit(A) 48, Mumbai Vide Order No. Itba/Apl/S/250/2025-26/1078825129(1) Dated 23.07.2025 Passed Against Assessment Order U/S. 143(3) Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”), Dated 28.12.2023 For Ay 2021-22. 2. Grounds Taken By The Revenue Are Reproduced As Under: “1. Whether, On The Facts & In The Circumstances Of The Case & In Law, The Citia) Failed To Appreciate That The Expenditure Incurred On The Esop Scheme Is A Capital Expenditure & Not A Revenue Expenditure

For Appellant: Shri Ashish Mehta and Shri Pulkit Pandey, AdvocatesFor Respondent: Shri Surendra Mohan, Sr. DR
Section 143(3)Section 37(1)Section 371

IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH, MUMBAI BEFORE SHRI ANIKESH BANERJEE, JUDICIAL MEMBER AND SHRI GIRISH AGRAWAL, ACCOUNTANT

Asia Investments Pvt.. Ltd., Mumbai vs. DCIT, Circle 2 (1)(1), Mumbai

In the result, all the three appeal

ITA 6209/MUM/2019[2014-15]Status: DisposedITAT Mumbai27 Nov 2025AY 2014-15

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan ()

For Respondent: Mr. Kalpesh Unadkat &
Section 14A

IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “A” MUMBAI BEFORE SHRI OM PRAKASH KANT (ACCOUNTANT MEMBER) AND SHRI RAJ

Asia Investments Private Limited, Mumbai vs. Assistant Commissioner of Income Tax Circle 2(1)(1), Mumbai

In the result, all the three appeals are allowed partly

ITA 6353/MUM/2017[2013-14]Status: DisposedITAT Mumbai27 Nov 2025AY 2013-14

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan ()

For Appellant: Mr. Kalpesh Unadkat &For Respondent: Mr. Rajesh Kumar Yadav, CIT-DR
Section 143(3)Section 14A

expenditure as bears a clear and proximate connection with earning exempt income may be disallowed. Expenditure not so connected must be examined under section 37(1) to determine whether it is incurred wholly and exclusively for business purposes; but such expenditure cannot be denied deduction under section 14A merely because ... next issue in this appeal of assessee is against the order of CIT(A) confirming the disallowance of interest on expenditure under section 37(1) of the Act made by the AO to the tune of ₹ 4,36,649/-. For this assessee has raised the following ground

Asia Investments Private Limited, Mumbai vs. Assistant Commissioner of Income Tax Circle 2(1)(1), Mumbai

In the result, all the three appeals are allowed partly

ITA 4529/MUM/2017[2012-13]Status: DisposedITAT Mumbai27 Nov 2025AY 2012-13

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan ()

For Appellant: Mr. Kalpesh Unadkat &For Respondent: Mr. Rajesh Kumar Yadav, CIT-DR
Section 143(3)Section 14A

next issue in this appeal of assessee is against the order of CIT(A) confirming the disallowance of interest on expenditure under section 37(1) of the Act made by the AO to the tune of ₹ 4,36,649/-. For this assessee has raised the following ground ... addressed the matter in the context of Rule 8D(2)(i), it had not adjudicated upon the allowability of such expenditure under Section 37(1). 11.3 We have given thoughtful consideration to the rival submissions and examined the material placed on record. The short question for adjudication is whether

Joginder Kumar & Sons HUF, Panipat vs. PCIT Rotak, Rotak

In the result, the appeal of the assessee is allowed

ITA 1975/DEL/2025[2018-19]Status: DisposedITAT Delhi27 Nov 2025AY 2018-19

Bench: Shri Anubhav Sharma & Shri Manish Agarwaljoginder Kumar & Sons Huf Pcit, 352/6, Near S D Modern School, Rohtak. Panipat-132103. Vs. Pan- Aachj6257L (Appellant) (Respondent) Assessee By Shri Dhurv Goel, Ca Department By Shri Pradumna Kumar Singh, Sr. Dr Date Of Hearing 04.09.2025 Date Of Pronouncement 27.11.2025 O R D E R Per Manish Agarwal, Am: This Appeal Is Filed By The Assessee Against The Order Of The Ld. Principal Commissioner Of Income Tax, Rohtak (‘The Pcit’ In Short) Passed U/S 263 Of The Income Tax Act, 1961 Dated 21.03.2025 Wherein The Ld. Pcit Held The Assessment Order As Erroneous & Prejudicial To The Interest Of The Revenue In Terms Of Explanation 2 Of Section 263 & Direct The Ao To Conduct Fresh Enquiries & Passed The Speaking Order.

Section 115BSection 147Section 148Section 263Section 37(1)Section 69C

genuine and nowhere in the assessment order, AO raised any doubts about the source of such purchases. Therefore, he invoked the provisions of section 37(1) of the Act and disallowed the purchases made by the assessee. This being so, the provisions of section

DCIT, Circle -3(1), Visakhapatnam vs. Nord Anglia Education Infrastructure Private Limited, Visakhapatnam

In the result, all the appeals filed by the revenue, viz

ITA 314/VIZ/2025[2014-15]Status: DisposedITAT Visakhapatnam26 Nov 2025AY 2014-15

Bench: Shri Ravish Sood & Shri Balakrishnan S.

For Appellant: 1.Shri Karnjot Singh KhuranaFor Respondent: Shri Badicala Yadagiri, CIT-DR
Section 143(3)

आयकर अपीलीय अिधकरण, िवशाखापटणम पीठ IN THE INCOME TAX APPELLATE TRIBUNAL Visakhapatnam Bench, Visakhapatnam Before Shri Ravish Sood, Judicial Member

DCIT, Circle - 3(1), Visakhapatnam vs. Nord Anglia Education Infrastructure Private Limited, Visakhapatnam

In the result, all the appeals filed by the revenue, viz

ITA 206/VIZ/2025[2018-19]Status: DisposedITAT Visakhapatnam26 Nov 2025AY 2018-19

Bench: Shri Ravish Sood & Shri Balakrishnan S.

For Appellant: 1.Shri Karnjot Singh KhuranaFor Respondent: Shri Badicala Yadagiri, CIT-DR
Section 143(3)

आयकर अपीलीय अिधकरण, िवशाखापटणम पीठ IN THE INCOME TAX APPELLATE TRIBUNAL Visakhapatnam Bench, Visakhapatnam Before Shri Ravish Sood, Judicial Member

DCIT, Circle - 3(1), Visakhapatnam vs. Nord Anglia Education Infrastructure Private Limited, Visakhapatnam

In the result, all the appeals filed by the revenue, viz

ITA 205/VIZ/2025[2017-18]Status: DisposedITAT Visakhapatnam26 Nov 2025AY 2017-18

Bench: Shri Ravish Soodand

For Appellant: 1.Shri Karnjot Singh KhuranaFor Respondent: Shri Badicala Yadagiri, CIT-DR
Section 143(3)

aTaeny aitehe after, feranceurs tis IN THE INCOME TAX APPELLATE TRIBUNAL Visakhapatnam Bench, Visakhapatnam Before Shri Ravish Sood, Judicial Member