“Section 2(23)(1)(i)”

AMCELL E SERVICES,PATIALA vs. ITO, W-2, PATIALA

The appeal of the assessee is allowed for statistical purposes

Bench: The Tribunal Under Section 253 Of The Income Tax Act, 1961. The Assessee Is Aggrieved By The Order Under Section 250 Of The Income Tax Act, Bearing No. Itba/Nfac/S/250/2023- 24/1057250796(1) Dt. 20/10/2023 Which Is Hereinafter Referred To As The “Impugned Order”. The Assessee Pan Is Aaxfa0904A. The A.Y. Is 2017-18 Corresponding To The F.Y. From 01/04/2016 To 31/03/2017. Factual Matrix 2. The Assessee Has Raised Following Grounds Of Appeal In Form No. 36 Before Us. 1. That The Cit(A) Appeal Decided The Appeal Ex-Party Without Providing Proper Opportunity Of Being Heard As Such The Order Is Liable To Deleted. 2. That The Addition Confirmed By Cit(A) Of Rs. 90,88,250/- Is Illegal & Against The Fact Of The Case. 3. That The Cit(A) Failed To Appreciate That The Ao Has Accepted The Fact That The Bank Account In Question Is Already Incorporate In Personal Returns Of The Partner Shri Mukesh Kumar As Such The Same Has Resulted In Double Taxation.

required to be enquired into first and then only assessment should be made in accordance with law. “Firm” has been defined under section 2(23)(1)(i)(iii) of Income Tax At and so also partner alongwith partnership. Under Section 2(31) person is too defined, which all the stakeholders