“Section 143(1)(a)”

Section References (mined)Section 143Section 143(1)(a)2,323 judgments

The decision most relied on for Section 143(1)(a) is Collector, Land Acquisition v. Mst. Katiji (167 ITR 471), cited in 3,926 judgments on BharatTax.

Leading authorities on Section 143(1)(a)

Collector, Land Acquisition v. Mst. Katiji

167 ITR 471 · 1987 · Supreme Court

3,926

citing judgments

Delay in filing appeals, when supported by sufficient or justifiable cause, should be condoned with a liberal approach to ensure substantial justice. This principle prioritizes the cause of justice over mere technicalities.

CIT v. Kabul Chawla

380 ITR 573 · 2016 · High Court

3,235

citing judgments

In a search assessment under Section 153A, additions can only be made for completed or non-abated assessment years if incriminating material relevant to those years is found during the search, although notice under Section 153A(1) is mandatorily issued for six assessment years preceding the search.

Malabar Industrial Co. Ltd. v. CIT

243 ITR 83 · 2000 · Supreme Court

2,943

citing judgments

For revision under Section 263, the Assessing Officer's order must be both erroneous and prejudicial to the interests of the revenue; if either condition is not met, the revisionary jurisdiction cannot be invoked. An order is not erroneous merely because the Assessing Officer did not record the details of enquiries conducted, provided due enquiries were made.

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.

CIT v. Multiplan India Ltd.

38 ITD 320 · 1991 · ITAT

2,267

citing judgments

An appeal before the Income Tax Appellate Tribunal can be dismissed for non-prosecution or treated as unadmitted when the appellant fails to appear, cooperate, or show diligence, in accordance with Rule 19(2) of the Income-tax (Appellate Tribunal) Rules. The law aids the vigilant, not those who sleep on their rights.

CIT v. Reliance Petroproducts Pvt. Ltd.

322 ITR 158 · 2010 · Supreme Court

2,228

citing judgments

Penalty under Section 271(1)(c) for furnishing inaccurate particulars or concealment of income is not automatically leviable if the assessee has made a full disclosure of all particulars and the addition or disallowance arises from a difference of opinion.

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.

Estate of Late Tukojirao Holkar v. CWT

223 ITR 480 · 1997 · High Court

2,040

citing judgments

A court or tribunal is not bound to answer a reference or adjudicate an appeal on its merits if the party at whose instance the proceeding is made fails to appear at the hearing or take necessary steps for its proper conduct.

Judgments citing Section 143(1)(a)

Shree Saurastra Ka;Akendra Co-Op. Housing Society Ltd., Rajkot vs. The ADIT (CPC), Bangalore

In the result, the appeal of the assessee is allowed

ITA 55/RJT/2023[2019-20]Status: HeardITAT Rajkot31 May 2023AY 2019-20

Bench: Smt. Annapurna Gupta& Shri Siddhartha Nautiyal

For Appellant: Shri D. M. Rindani, A.RFor Respondent: Shri B. D. Gupta, Sr. DR

Section 143(1)Section 143(1)(a)Section 154Section 254Section 254(2)Section 80Section 80PSection 80P(2)Section 80P(2)(d)

deduction under Section 80P(2)(d) amounting to Rs. 10,62,590/-. The assessee’s claim for deduction was disallowed by CPC under Section 143(1) of the Act. In response to the adjustment made by CPC u/s 143(1), the assessee filed three separate rectification applications, which were ... ITAT, Hyderabad Bench 'A', observed asunder: Shri Saurashtra Kalakendra Co-op. Housing Societyvs.ADIT Asst.Year –2019-20 "Further in the case of assessments under section 143(1), it is not permissible for the assesses to plead for rectification under section 154 on grounds of mistake apparent from record. In view

Sun Enterprises, Surat vs. Dy. Commissioner of Income Tax, Cir.2(1)(1)/ Dy.CIT Central Processing Centre (CPC), Surat/Bengaluru

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

ITA 162/SRT/2023[2017-18]Status: DisposedITAT Surat31 May 2023AY 2017-18

Bench: Shri Pawan Singh, Jm &Dr. A.L.Saini, Am आयकर अपील सं./Ita No.162/Srt/2023 (िनधा"रण वष" / Assessment Year: (2017-18) (Virtual Court Hearing) Sun Enterprises Deputy Commissioner Of Income Shed No.C1B/156, Ichhapore- Tax Central Processing Centre Vs. Bhatpore Industrial Estate, Hajira, (Cpc),Bengaluru-560100 Surat-394207 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aayfs 4971J (अपीलाथ" /Appellant ) (""थ" /Respondent)

For Appellant: Shri Mehul Shah, C.AFor Respondent: Shri Vinod Kumar, Sr-DR

Section 139(1)Section 143(1)Section 143(1)(a)Section 36(1)(va)Section 43B

Assessing Officer (Central Processing Centre, Bengaluru) in making adjustment u/s 143(1) although the same adjustment does not fall within the ambit of section 143(1)(a)(i) to 143(1)(a)(vi). 2. On the facts and circumstances of the case as well as law on the subject

Akar Auto Industries Ltd, Mumbai vs. DCIT-6(1)(1), Mumbai

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

ITA 502/MUM/2023[2018-2019]Status: DisposedITAT Mumbai30 May 2023AY 2018-2019

Bench: Shri B. R. Baskaran, Am & Shri N. K. Choudhry, Jm

For Appellant: Shri P. C. Parwal, Ld. ARFor Respondent: Shri Manoj Kumar Sinha

Section 143(1)Section 143(1)(a)Section 250Section 36(1)(va)

Income Tax Officer & Ors (ITA No. 693/Pun/2022 decided on 23.11.2022). 4.1 The assessee further claimed that adjustment as per sub clause (iv) of section 143(1)(a) of the Act can be made in respect of disallowance of expenditure indicated in the audit report, but not taken into account ... assessee is untenable. 6.2 Next issue raised by the assessee pertains to the non- applicability of the provisions of clause (ii) of section 143(1) of the Act. We observe that that the Hon’ble Apex Court in the Case of Checkmate Services Pvt. Ltd. vs. CIT (supra) clearly held

The Nakodar Primary Cooperative Agriculture Development Bank Limited, Jalandhar vs. Income Tax Officer Ward, Nakodar

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

ITA 63/ASR/2023[2019-20]Status: DisposedITAT Amritsar30 May 2023AY 2019-20

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

Section 143Section 143(1)Section 154Section 250oSection 40A(7)Section 80P

opportunity as provided in section 154 was provided to the assesse which had the impact of enhancing the assessment made under section 143(1). 3. That in the facts and circumstances of the case and in law, the order passed by NFAC deserves to be set-aside on the footing ... which are extracted as below: “8. In the Memorandum to the Finance Bill 2016, while inserting sub clause (iv) to section 143(1 )(a), it was explained as under: Clause (a) of sub-section (1) of section 143 provides that, a return filed is to be processed and total income

DCIT, Circle-7(1), New Delhi vs. Dec Property Management (India) Pvt. Ltd., New Delhi

In the result, the appeals in ITA No

ITA 2667/DEL/2022[2019-20]Status: DisposedITAT Delhi30 May 2023AY 2019-20

Bench: Sh. Anil Chaturvedi & Sh. Anubhav Sharmaita Nos. 2666 & 2667/Del/2022 (Assessment Years : 2018-19 & 2019-20) Dcit Vs. Dec Property Management Circle – 7(1) (India) Pvt. Ltd. New Delhi 1101, Plot No.D-9, Gopal Heights, Netaji Subhash Place, New Delhi - 110034 Pan No. Aabcd 7231 Q (Appellant) (Respondent) Assessee By Shri Jaspal Sathi, Adv. Revenue By Shri Javed Akhtar, Cit-D.R. Date Of Hearing: 25.05.2023 Date Of Pronouncement: 30.05.2023 Order Per Anil Chaturvedi, Am: These Two Appeals Filed By The Revenue Are Directed Against The Order Dated 08.09.2022 Passed By The Commissioner Of Income Tax (Appeals)- Nfac, Delhi Relating To Assessment Years 2018-19 & 2019-20. 2. Before Us, At The Outset, Both The Parties Submitted That Though The Appeals Filed By The Assessee Are For Two Different Assessment Years But The Facts & Issues Involved In Both The

Section 139(1)Section 143(1)Section 36(1)(iv)Section 36(1)(va)Section 43B

return of income u/s 139(1) of the Act. He further submitted that the aforesaid addition does not fall within the purview of Section 143(1) as it is a debatable issue and in support of his contention he relied on the decision of Bombay Tribunal in the case ... stressed that the action of the AO in making the extant disallowance does not fall in any of the clauses of section 143(1). 7. We fully agree with the proposition bolstered by the ld. AR that adjustment to the total income or loss can be made only

DCIT, Circle-7(1), New Delhi vs. Dec Property Management (India) Pvt. Ltd., New Delhi

In the result, the appeals in ITA No

ITA 2666/DEL/2022[2018-19]Status: DisposedITAT Delhi30 May 2023AY 2018-19

Section 139(1)Section 143(1)Section 36(1)(iv)Section 36(1)(va)Section 43B

Vinod Kumar Sharma, Delhi vs. AO Ward 71(1), Delhi

In the result, the appeal of the assessee is dismissed

ITA 233/DEL/2022[2018-19]Status: DisposedITAT Delhi30 May 2023AY 2018-19

Bench: Shri Kul Bharat & Shri Pradip Kumar Kedia

Section 115BSection 139Section 143(1)Section 143(1)(a)Section 154Section 234ASection 234BSection 234CSection 36(1)(va)

holding that there was no mistake apparent from record by the AO Centralized Processing Centre (CPC) while processing the income tax return under Section 143(1) of the Income-Tax Act, 1961 overlooking the judgments raised upon by the assessee. However, alternative plea was made vide letter dated 27th October ... Rs.36,24,460. The 4 same was processed and the assessee received a communication dated 10.05.2019 for adjustment to its income under Section 143(1)(a) of the Income-Tax Act, 1961 (the “Act”), thereby proposing the disallowance of Rs.24,27,426 on the ground that the said amount paid

C & C Constructions Limited, New Delhi vs. DCIT, Central Circle-19, New Delhi

In the result, the appeals in ITA No

ITA 1544/DEL/2022[2014-15]Status: DisposedITAT Delhi30 May 2023AY 2014-15

Bench: Sh. Anil Chaturvedi & Sh. Anubhav Sharmaita Nos. 1543 & 1544/Del/2022 (Assessment Years : 2013-14 & 2014-15) C & C Constructions Ltd. Vs. Dcit 74, Hemkunt Colony, Central Circle – 19 New Delhi – 110 048 New Delhi Pan No. Aaacc 4543 R (Appellant) (Respondent) Assessee By Shri Sibtain Raza, A.R. Revenue By Shri Javed Akhtar, Cit-D.R. Date Of Hearing: 25.05.2023 Date Of Pronouncement: 30.05.2023 Order Per Anil Chaturvedi, Am: These Two Appeals Filed By The Assessee Are Directed Against The Order Dated 28.04.2022 Passed By The Commissioner Of Income Tax (Appeals)-27, New Delhi Relating To Assessment Years 2013-14 & 2014-15. 2. Before Us, At The Outset, Both The Parties Submitted That Though The Appeals Filed By The Assessee Are For Two Different Assessment Years But The Facts & Issues Involved In Both The Appeals Are Identical Except For The Assessment Year & The

Section 139(1)Section 143(1)Section 143(2)Section 143(3)Section 2(24)(x)Section 36(1)(va)

further submitted that CIT(A) was not justified in making the addition as the aforesaid addition does not fall within the purview of Section 143(1) as it is a debatable issue. He further submitted that there is no application of mind by CIT(A) in disposing of the ground ... stressed that the action of the AO in making the extant disallowance does not fall in any of the clauses of section 143(1). 7. We fully agree with the proposition bolstered by the ld. AR that adjustment to the total income or loss can be made only

C & C Constructions Limited, New Delhi vs. DCIT, Central Circle-19, New Delhi

In the result, the appeals in ITA No

ITA 1543/DEL/2022[2013-14]Status: DisposedITAT Delhi30 May 2023AY 2013-14

Section 139(1)Section 143(1)Section 143(2)Section 143(3)Section 2(24)(x)Section 36(1)(va)

Manju Singh, Kota vs. ACIT, Circle-1, Kota

In the result, all the three appeals of the assessee in ITA No

ITA 56/JPR/2023[2018-19]Status: DisposedITAT Jaipur30 May 2023AY 2018-19

Bench: The Date Of Hearing.

For Appellant: Shri Nikhlesh Kataria, CAFor Respondent: Smt. Manisha Choudhary, Addl.CIT

Section 139(1)Section 143(1)

record in making addition of PF/ESI while processing of return u/s 143(1) of the Act though such adjustment is beyond purview of Section 143(1) being a debatable and controvertial issue and hence the AO may be directed to rectify the addition so made.’’ 2.1 Apropos Ground Nos. 1 ... stated that the impugned adjustment u/s 143(1) of the Act is beyond the powers of the CPC, Bengaluru. 13. The provisions of section 143(1)(a) read as under:- “143(1) Where a return has been made under section 139, or in response to a notice under sub-section

Integrity Verification Services Private Limited, Mumbai vs. Income Tax Officer, Ward 3(2)(1), Mumbai

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

ITA 1843/MUM/2021[2018-19]Status: DisposedITAT Mumbai29 May 2023AY 2018-19

Bench: Shri Om Prakash Kant & Shri Narender Kumar Choudhryintegrity Verification Ito, Services Pvt.Ltd., 11, Ward-3(2)(1), बनाम/ Tulsani Chambers, Mumbai. Vs. Nariman Point, Mumbai- 400021. "थायीलेखासं./जीआइआरसं./Pan/Gir No. : Aaccg1281A (अपीलाथ"/Appellant) (""थ" / Respondent) अपीलाथ" ओर से/ Appellant By : Shri Gyaneshwar Kataram ""थ" की ओर से/Respondentby: Shri M.P.Ahuja, Sr.Ar सुनवाई की तारीख/ Date Of Hearing 11/05/2023 घोषणा की तारीख /Date Of Pronouncement 29/05/2023 आदेश / Order Per Om Prakash Kant - Am: This Appeal Filed By The Assessee Is Directed Against The Order Dated 22.09.2021 Passed By Ld. Commissioner Of Income-Tax (Appeals)-National Faceless Appeal Centre (“Nfac”), Delhi [ In Short, The “Ld.Cit(A)”] For Assessment Year (“Ay”) 2018-19. The Appeal Was Originally Heard & Pronounced On 28.04.2022, However, Later On In View Of The Decision Of The Hon’Ble Supreme Court In The Case Checkmate Services Pvt.Ltd. Vs Cit In Ita Of No.2833/2016 Dated 12.10.2022 Has Been Recalled For Deciding The Issue Of Deduction U/S 36(1)(Va) Of The Act. Accordingly, This Appeal Came Before Us For Hearing.

For Appellant: Shri Gyaneshwar KataramFor Respondent: Shri M.P.Ahuja, Sr.AR

Section 10Section 139Section 142Section 143Section 143(1)Section 143(1)(a)Section 36(1)(va)

1)(va) of the Act and therefore, this falls in the nature of incorrect claim of the assessee. In terms of provision of section 143(1)(a)(ii) of the Act, the AO can make adjustment for any incorrect claim while processing the return of income under theprovision of section

Arun Kumar Verma, Bhilai, Durg vs. Income Tax Officer 1(2), Bhilai, Durg

The appeals of the assessee are dismissed in terms of my aforesaid observations

ITA 80/RPR/2023[2019-20]Status: DisposedITAT Raipur29 May 2023AY 2019-20

Bench: Shri Ravish Soodआयकर अपील सं./ Ita Nos.79 & 80/Rpr/2023 "नधा"रण वष" / Assessment Years : 2018-19 & 2019-2020 Arun Kumar Verma Plot No.152, Telgu Para, Maroda Tank, Maroda, Bhilai (C.G.) Pan : Abkpv0530H .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer-1(2), Raipur (C.G.). ……""यथ" / Respondent

For Appellant: Ms. Puja Bajaj, CAFor Respondent: Shri Piyush Tripathi, Sr. DR

Section 139Section 142Section 143(1)Section 154Section 36(1)(va)

contested this action of the CPC by contending that such an adjustment made by the CPC is not permissible under the Act as section 143(1) permits adjustment only when there is arithmetical error or incorrect claim is apparent from any information in the return whereas in the instant case ... processing return of income without any human intervention, it was found that the assessee's case is covered by sub clause (iv) to section 143(1)(a) of the Act. Thus, the CPC made adjustment on account of disallowance of expenditure indicated in the audit report but not taken into

Arun Kumar Verma, Bhilai, Durg vs. Income Tax Officer 1(2), Bhilai, Durg

The appeals of the assessee are dismissed in terms of my aforesaid observations

ITA 79/RPR/2023[2018-19]Status: DisposedITAT Raipur29 May 2023AY 2018-19

For Appellant: Ms. Puja Bajaj, CAFor Respondent: Shri Piyush Tripathi, Sr. DR

Section 139Section 142Section 143(1)Section 154Section 36(1)(va)

Santosh Kumar Nishad, Raipur vs. Income Tax Officer, Ward-1(1), Raipur

The appeals of the assessee are dismissed in terms of my aforesaid observations

ITA 108/RPR/2023[2019-20]Status: DisposedITAT Raipur29 May 2023AY 2019-20

Bench: Shri Ravish Soodआयकर अपील सं./ Ita Nos. 107 & 108/Rpr/2023 "नधा"रण वष" / Assessment Years : 2018-19 & 2019-2020 Santosh Kumar Nishad Mandhar, Mohadi, Tehsil : Dharsiwa, Raipur-493 111 (C.G.) Pan : Agfpn5475R .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer-1(1), Raipur (C.G.). ……""यथ" / Respondent

For Appellant: Shri Ravi Agrawal, CAFor Respondent: Shri Piyush Tripathi, Sr. DR

Section 139(1)Section 143(1)Section 143(1)(a)Section 154Section 36(1)(va)

automatically attracted. The AO CPC has, in my humble view, acted in accordance with provisions of section 143(1)(a)(iv) of the Act and the adjustment made by the AO CPC in the order u/s 143(1)(a) of the Act and the subsequent retaining the same

Santosh Kumar Nishad, Raipur vs. Income Tax Officer, Ward-1(1), Raipur

The appeals of the assessee are dismissed in terms of my aforesaid observations

ITA 107/RPR/2023[2018-19]Status: DisposedITAT Raipur29 May 2023AY 2018-19

For Appellant: Shri Ravi Agrawal, CAFor Respondent: Shri Piyush Tripathi, Sr. DR

Section 139(1)Section 143(1)Section 143(1)(a)Section 154Section 36(1)(va)

Harshdeep Singh Juneja, Raipur vs. Dy. Commissioner of Income Tax, CPC, Bangalore

In the result, appeal of the assessee is allowed for statistical purposes in terms of our aforesaid observations

ITA 106/RPR/2021[2018-19]Status: DisposedITAT Raipur29 May 2023AY 2018-19

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita No. 106/Rpr/2021 "नधा"रण वष" / Assessment Year : 2018-19 Harshdeep Singh Juneja 21/537, Katora Talab Road, Raipur (C.G.)-492 001 Pan : Acupj6153B .......अपीलाथ" / Appellant बनाम / V/S. The Deputy Commissioner Of Income Tax, Circle-1(1), Raipur (C.G.) ……""यथ" / Respondent

For Appellant: S/Shri Praveen Khandelwal &For Respondent: Shri Piyush Tripathi, Sr. DR

Section 143(1)Section 40ASection 40A(3)

that the very purpose of affording an opportunity to the assessee as per the mandate of “2nd proviso” to Section 143(1) (a) of the Act would be rendered as redundant and otiose in case the response filed by an assessee was not to be considered. Our attention was drawn ... proviso” to Section 143(1)(a) of the Act, wherein the same specifically provides that the response received from the assessee to the proposed adjustment to his returned income was mandatorily to be considered before proceeding any further and making any such adjustment. It was, thus, the claim

Alsisar Hotels & Resorts Private Limited, Jaipur vs. Assistant Commisioner of Income Tax, Jaipur

In the result, all the three appeals of the assessee in ITA No

ITA 135/JPR/2023[2017-18]Status: DisposedITAT Jaipur26 May 2023AY 2017-18

Bench: The Due Date Of The Filing Of Return During The Year. 2. That The Petitioner Raves To Add, Alter Or Amend All Or Any Of The Grounds Of Appeal On Or Before The Due Date Of Hearing.”

For Appellant: Shri Neeraj Rathore (C.A.)For Respondent: None a

Section 143(1)Section 143(3)Section 2(24)(x)Section 36(1)(va)Section 37(1)

disallowance made by the CPC Bengaluru while processing the return u/s 143(1) of the Act is beyond the scope of provisions of section 143(1(a) of the Act and,therefore, cannot be sustained. 7. We have carefully perused the decision of the co- ordinate bench in the case ... sucha situation, cannot be reason enough to disregard the binding views of the Hon'ble jurisdictional Court. To that extent, the provisions of section 143(1)(a)(iv) must be read down. What essentially follows is the adjustments under section 143(1)(a) in respect of” disallowance of expenditure indicated

Braham Parkash Yadav, Bhiwadi, Alwar vs. Commissioner of Income-Tax (Appeals), National Faceless Appeal Centre (NFAC)

In the result, all the three appeals of the assessee in ITA No

ITA 439/JPR/2022[2020-21]Status: DisposedITAT Jaipur26 May 2023AY 2020-21

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Praveen Kumar Garg (C.A.)For Respondent: Ms Monisha Choudhary (Addl. CIT) a

Section 143(1)Section 143(1)(a)Section 2(24)(x)Section 36(1)(va)Section 43B

M/S Ready Roti India Pvt. Ltd., F-28, Riico Industrial Area, Sare Khurd, Alwar vs. CPC, Bangalore/ ACIT/DCIT, Circle-6, Jaipur

In the result, appeals of the assessee are dismissed

ITA 437/JPR/2022[2020-21]Status: DisposedITAT Jaipur24 May 2023AY 2020-21

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri P. C. Parwal (C.A.)For Respondent: Smt Runi Pal (Addl. CIT) a

Section 143(1)Section 143(1)(a)Section 2(24)(x)Section 36(1)(va)

आयकर अपीलीय अधिकरण] जयपुर न्यायपीठ] जयपुर IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES,”B” JAIPUR Mk0 ,l- lhrky{eh

M/S Ready Roti India Pvt. Ltd., F-28, Riico Industrial Area, Sare Khurd, Alwar vs. CPC, Bangalore/ ACIT/DCIT, Circle-6, Jaipur

In the result, appeals of the assessee are dismissed

ITA 436/JPR/2022[2019-20]Status: DisposedITAT Jaipur24 May 2023AY 2019-20

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri P. C. Parwal (C.A.)For Respondent: Smt Runi Pal (Addl. CIT) a

Section 143(1)Section 143(1)(a)Section 2(24)(x)Section 36(1)(va)

आयकर अपीलीय अधिकरण] जयपुर न्यायपीठ] जयपुर IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES,”B” JAIPUR Mk0 ,l- lhrky{eh