“lack of inquiry”

Rectification & RevisionSection 263Section 2631,087 judgments

The decision most relied on for lack of inquiry is CIT v. Gabriel India Ltd. (203 ITR 108), cited in 990 judgments on BharatTax.

Leading authorities on lack of inquiry

CIT v. Gabriel India Ltd.

203 ITR 108 · 1993 · High Court

990

citing judgments

The Commissioner cannot revise an assessment order under Section 263 merely because they hold a different opinion or believe a deeper inquiry was warranted if the Assessing Officer has applied their mind and conducted some inquiry. Revision under Section 263 is permissible only in cases of a complete lack of inquiry or non-application of mind by the Assessing Officer, not for merely inadequate inquiry.

CIT v. Orissa Corporation Pvt. Ltd.

159 ITR 78 · 1986 · Supreme Court

897

citing judgments

When an assessee provides the identity and address of a creditor or investor for a cash credit or share capital under Section 68, the burden shifts to the Department to establish lack of genuineness or creditworthiness, requiring it to conduct further inquiries; mere non-compliance by third parties to summons cannot be the sole basis for an adverse inference against the assessee.

CIT v. Sunbeam Auto Ltd.

332 ITR 167 · 2011 · High Court

897

citing judgments

The Commissioner cannot revise an assessment under Section 263 merely because the assessment order does not explicitly reflect an inquiry, or because the Commissioner holds a different opinion. An inquiry, even if considered inadequate, or an assessment based on a plausible view by the Assessing Officer after due examination, does not automatically make the order erroneous or prejudicial to the interests of the revenue.

Gee Vee Enterprises v. Addl. CIT

99 ITR 375 · 1975 · High Court

543

citing judgments

An assessment order is erroneous and prejudicial to the interest of revenue if the Assessing Officer fails to make proper inquiries before accepting the assessee's statements or claims. The Commissioner can revise such an order under Section 263 without conducting further inquiries himself.

CIT v. Anil Kumar Sharma

335 ITR 83 · 2011 · High Court

264

citing judgments

The Commissioner cannot invoke Section 263 for an assessment merely because of an inadequate inquiry by the Assessing Officer, provided there was some inquiry or the record demonstrates application of mind, as this constitutes a mere difference of opinion.

Narayan Tatu Rane v. ITO

70 Taxmann.com 227 · 2016 · ITAT

220

citing judgments

Before revising an assessment order under Section 263, the CIT/PCIT must conduct their own inquiries or verifications to establish that the Assessing Officer's order is erroneous and unsustainable in law, rather than merely directing further inquiry or pointing out the AO's lack of inquiry.

DIT v. Jyoti Foundation

357 ITR 388 · 2013 · High Court

210

citing judgments

An assessment order cannot be deemed erroneous and prejudicial to the interest of revenue under Section 263 if the Assessing Officer conducted an inquiry and applied their mind during the original assessment, as Explanation 2 to Section 263 does not permit unending inquiries by the revisional authority.

CIT v. Infosys Technologies Ltd.

341 ITR 293 · 2012 · High Court

205

citing judgments

A Commissioner can revise an assessment order under Section 263 if it is erroneous and prejudicial to the interests of the revenue. This includes cases where the Assessing Officer fails to make further inquiries before accepting the assessee's statements in the return.

Judgments citing lack of inquiry

Bhaskar Arvind Kumar Hingad, Mumbai vs. Asstt CIT-24(1), Mumbai

In the result, the appeal of the assessee stands allowed

ITA 692/MUM/2022[2014-15]Status: DisposedITAT Mumbai21 Oct 2022AY 2014-15

Bench: Shri Pramod Kumar, Vp & Shri Aby T. Varkey, Jm आयकर अपील सं/ I.T.A. No.692/Mum/2022 (निर्धारण वर्ा / Assessment Years: 2014-15) Bhaskar Arvind Kumar बिधम/ Acit-24(1) Hingad 601, 6Th Floor, Piramal Vs. Flat No. 1, Ratnakar Chambers, Lalbaug, Parel, Building, 26 Narayan Mumbai-400012. Dhabolkar Road, Mumbai- 400006. स्थधयी लेखध सं./जीआइआर सं./Pan/Gir No. : Aacph2812F (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) Assessee By: Shri Vijay Mehta Revenue By: Dr. Mahesh Akhade (Dr) सुनवाई की तारीख / Date Of Hearing: 29/08/2022 घोषणा की तारीख /Date Of Pronouncement: 21/10/2022 आदेश / O R D E R Per Aby T. Varkey, Jm: This Appeal Preferred By The Assessee Is Against The Order Of The Ld. Principal Commissioner Of Income Tax-20 [Hereinafter Referred To As The “Pcit”], Mumbai Dated 31.03.2022 For Assessment Year 2014- 15 Passed Under Section 263 Of The Income Tax Act, 1961 (Hereinafter Referred To As “The Act”).

For Appellant: Shri Vijay MehtaFor Respondent: Dr. Mahesh Akhade (DR)

Section 143(3)Section 263

error also caused prejudice to the interests of the Revenue. In our considered view one also has to understand the difference between "lack of inquiry" and "inadequate inquiry" and when can it be termed as erroneous for usurpation of jurisdiction u/s 263 of the Act. For better understanding of this ... revenue expenditure. Learned counsel for the assessee is right in his submission that one has to keep in mind the distinction between "lack of inquiry" and "inadequate inquiry". If there was any inquiry, even inadequate, that would not by itself, give occasion to the Commissioner to pass orders under section

Jabbar Khan, Dewas vs. CIT, Ujjain

In the result, this appeal of assessee is allowed

ITA 136/IND/2020[2009-10]Status: DisposedITAT Indore20 Oct 2022AY 2009-10

Bench: Ms. Madhumita Roy & Shri B.M. Biyaniassessment Year: 2009-10 Jabbar Khan, Pr. Cit, Village-Siya, Tehsil-Dewas बनाम/ Ujjain Vs. (Appellant / Assessee) (Respondent / Revenue) Pan: Cndpk 0362 H Assessee By Shri Ashok Mahajan, Ar Revenue By None Date Of Hearing 26.09.2022 Date Of Pronouncement 20.10.2022

Section 143(3)Section 147Section 148Section 263

this regard. 7.2 Delhi High Court in the case of CIT Vs. Sunbeam Auto 332 ITR 167 (Del.), made a distinction between lack of inquiry and inadequate inquiry. The Hon’ble court held that where the AO has made inquiry prior to the completion of assessment, the same cannot ... revenue expenditure. Learned counsel for the assessee is right in his submission that one has to keep in mind the distinction between “lack of inquiry” and “inadequate inquiry”. If there was any inquiry, even inadequate, that would not by itself, give occasion to the Commissioner to pass orders under section

Deputy Commissioner of Income Tax, Circle- 1(1), Raipur vs. Mesers Bhagwati Industries, Raipur

In the result, appeal of the revenue is partly allowed in terms of our aforesaid observations

ITA 184/RPR/2019[2013-14]Status: DisposedITAT Raipur17 Oct 2022AY 2013-14

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita No.184/Rpr/2019 "नधा"रण वष" / Assessment Year : 2013-14 The Assistant Commissioner Of Income Tax, Circle-1(1), Raipur (C.G.) .......अपीलाथ" / Appellant बनाम / V/S. M/S. Bhagawati Industries Behind Samrat Talkies, Station Road, Raipur-492 001 (C.G.) Pan : Aaifk4253H ……""यथ" / Respondent

For Appellant: S/shri G.S. Agarwal, Adv. &For Respondent: Shri G.N Singh, Sr. DR

Section 131Section 250(4)Section 69C

conduct proper inquiry shifts to commissioner(Appeals) and Tribunal and they cannot simply delete addition made by assessing office on ground of lack of inquiry." 13. "Whether on points of law and on facts and circumstances of the case, the Ld. CIT(A) was justified in giving a decision, thereby

Income Tax Officer, Ward-1(2), Raipur vs. Mesers Balaji Rice Industries, Raipur

In the result, appeal of the revenue is partly allowed in terms of our aforesaid observations

ITA 181/RPR/2019[2013-14]Status: DisposedITAT Raipur17 Oct 2022AY 2013-14

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita No.168/Rpr/2019 "नधा"रण वष" / Assessment Year : 2013-14 M/S. Balaji Rice Industries, Kharora, Tah-Tilda, Raipur (C.G.)-493 225 Pan : Aacfb4543M .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer-1(2), Raipur (C.G.) ……""यथ" / Respondent आयकर अपील सं. / Ita No.181/Rpr/2019 "नधा"रण वष" / Assessment Year : 2013-14 The Income Tax Officer-1(2), Raipur (C.G.) .......अपीलाथ" / Appellant बनाम / V/S. M/S. Balaji Rice Industries, Kharora, Tah-Tilda, Raipur (C.G.)-493 225 Pan : Aacfb4543M ……""यथ" / Respondent

For Appellant: Shri Sunil Kumar Agrawal, CAFor Respondent: Shri G.N Singh, Sr. DR

Section 131Section 143(3)Section 250(4)Section 69C

conduct proper inquiry shifts to Commissioner(Appeals) and Tribunal and they cannot simply delete addition made by assessing officer on ground of lack of inquiry?" 11. "Whether on points of law and on facts and circumstances of the case, the Ld. CIT(A) was justified in giving a decision, thereby

Mesers Balaji Rice Industries, Raipur vs. Income Tax Officer, Ward-1(2), Raipur

In the result, appeal of the revenue is partly allowed in terms of our aforesaid observations

ITA 168/RPR/2019[2013-14]Status: DisposedITAT Raipur17 Oct 2022AY 2013-14

For Appellant: Shri Sunil Kumar Agrawal, CAFor Respondent: Shri G.N Singh, Sr. DR

Section 131Section 143(3)Section 250(4)Section 69C

Income Tax Officer, Ward 1(2), Raipur vs. Shri Rajendra Kumar Agrawal, Neora, Raipur

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

ITA 15/RPR/2019[2013-14]Status: DisposedITAT Raipur17 Oct 2022AY 2013-14

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं./ Ita No.15/Rpr/2019 "नधा"रण वष" / Assessment Year : 2013-14 The Income Tax Officer, Ward-1(2), Raipur (C.G.) .......अपीलाथ" / Appellant बनाम / V/S. Shri Rajendra Kumar Agrawal, M/S. Amit Chawal Udyog Neora, Tilda, Raipur (C.G.) Pan : Acipa5919L ……""यथ" / Respondent Assessee By :S/Shri G.S. Agrawal & N.C Gupta, Ar’S Revenue By : Shri Sanjay Kumar, Sr. Dr

For Appellant: S/shri G.S. Agrawal &For Respondent: Shri Sanjay Kumar, Sr. DR

Section 131Section 143(3)Section 250(4)Section 69C

conduct proper inquiry shifts to commissioner(Appeals) and Tribunal and they cannot simply delete addition made by assessing office on ground of lack of inquiry." 10. Whether on points of law and on points of facts & circumstances of the case, the Ld. CIT(A) having concurrent powers

Globalworth Securities Ltd., Mumbai vs. ACIT, Circle 4(1)(1), Mumbai

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

ITA 620/MUM/2022[2012-13]Status: DisposedITAT Mumbai14 Oct 2022AY 2012-13

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail () Assessment Year: 2012-13 Globalworth Securities Limited, Acit, Circle-4(1)(1), 716, Neelkanth Corporate Park, Room No. 640, 6Th Floor, Kirol Road, Vidyavihar (West), Vs. Aayakar Bhavan, Maharshi Mumbai-400086. Karve Road, Mumbai-400020. Pan No. Aadcg 7624 G Appellant Respondent Assessee By : Mr. Aditya Ramachndran, Ar Revenue By : Mr. Ashok Kumar Kardam, Cit-Dr Date Of Hearing : 07/10/2022 Date Of Pronouncement : 14/10/2022

For Appellant: Mr. Aditya Ramachndran, ARFor Respondent: Mr. Ashok Kumar Kardam, CIT-DR

Section 148Section 148(2)

reproduced above. We find that the L his para 5.3 reproduced above. We find that the Ld. PCIT has nowhere pointed out lack of inquiry or any inadequate inquiry in nowhere pointed out lack of inquiry or any inadequate inquiry in nowhere pointed out lack of inquiry or any inadequate

Hindustan Sales Industrial Corporation, Jaipur vs. Principal Commissioner of Income Tax-1, Jaipur

In the result, the appeal of the assessee is allowed

ITA 94/JPR/2022[2016-17]Status: HeardITAT Jaipur10 Oct 2022AY 2016-17

For Appellant: Shri Rajeev Sogani, CA &For Respondent: Shri Sanjay Dhariwal, CIT-DR

Section 142(1)Section 143(2)Section 143(3)Section 263

Thus, the indexation was rightly claimed and allowed by the ld. AO after proper satisfaction. 12. It is further submitted that normally the lack of inquiry / non applicability of mind can't be alleged in limited scrutiny case. Reliance is placed on the judgement of Hon'ble Coordinate Bench

Sachchade Food Pvt. Ltd., Ahmedabad vs. The Pr. CIT-3, Ahmedabad

ITA 89/AHD/2021[2016-17]Status: DisposedITAT Ahmedabad07 Oct 2022AY 2016-17

Bench: Shri Waseem Ahmed & Shri T.R. Senthil Kumarआयकर अपील सं./Ita No. 89/Ahd/2021 िनधा"रण वष"/Asstt. Year: 2016-2017 Sachchade Food Private Limited, P.C.I.T., 407/3, New Ahmedabad Industrial Vs. Ahmedabad-3, Estate, Ahmedabad. Village: Moraiya Tal. Sanand, Ahmedabad-382213. Pan: Aatcs9292G

For Appellant: Shri Mehul Thakkar, A.RFor Respondent: Shri James Kurian, CIT. D.R

Section 143(2)Section 143(3)Section 263

this regard. 11.2 Delhi High Court in the case of CIT Vs. Sunbeam Auto 332 ITR 167 (Del.), made a distinction between lack of inquiry and inadequate inquiry. The Hon’ble court held that where the AO has made inquiry prior to the completion of assessment, the same cannot ... revenue expenditure. Learned counsel for the assessee is right in his submission that one has to keep in mind the distinction between “lack of inquiry” and “inadequate inquiry”. If there was any inquiry, even inadequate, that would not by itself, give occasion to the Commissioner to pass orders under section

M/S. Emboza Granito Pvt. Ltd., Morbi vs. The Pr. CIT-3, Rajkot

In the result, appeal filed by assessee is allowed

ITA 240/RJT/2019[2016-17]Status: DisposedITAT Rajkot30 Sept 2022AY 2016-17

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyalआयकर अपील सं./Ita No. 240/Rjt/2019 िनधा"रण वष"/Asstt. Years: 2016-2017

For Appellant: Shri Mehul Ranpura, A.RFor Respondent: Shri Aarsi Prasad, CIT. D.R

Section 143Section 143(3)Section 263Section 32ASection 68

this regard. 9.2 Delhi High Court in the case of CIT Vs. Sunbeam Auto 332 ITR 167 (Del.), made a distinction between lack of inquiry and inadequate inquiry. The Hon’ble court held that where the AO has made inquiry prior to the completion of assessment, the same cannot ... revenue expenditure. Learned counsel for the assessee is right in his submission that one has to keep in mind the distinction between “lack of inquiry” and “inadequate inquiry”. If there was any inquiry, even inadequate, that would not by itself, give occasion to the Commissioner to pass orders under section

M/S Om Contractor and Engineers, Sangrur vs. PCIT, Patiala

The appeals of the assessees stand allowed

ITA 485/CHANDI/2022[2012-13]Status: DisposedITAT Chandigarh30 Sept 2022AY 2012-13

Bench: Shri Sudhanshu Srivastava & Shri Vikram Singh Yadav

For Appellant: Sh. Ashwani Kumar, CAFor Respondent: Sh. Sarabjit Singh, CIT DR

Section 133(6)Section 148Section 44A

order is erroneous and prejudicial to the interest of the revenue. 6.10 We may further add that there is a difference between lack of inquiry and inadequate inquiry and it is for the Assessing Officer to decide the extent of inquiry to be made and it is his satisfaction which

M/S Omkar Engineer and Contractor, Sangrur vs. Pcti, Patiala

The appeals of the assessees stand allowed

ITA 484/CHANDI/2022[2012-13]Status: DisposedITAT Chandigarh30 Sept 2022AY 2012-13

Bench: Shri Sudhanshu Srivastava & Shri Vikram Singh Yadav

For Appellant: Sh. Ashwani Kumar, CAFor Respondent: Sh. Sarabjit Singh, CIT DR

Section 133(6)Section 148Section 44A

M/S Maa Bhagwati Enterprises, Sangrur vs. PCIT, Patiala

The appeals of the assessees stand allowed

ITA 483/CHANDI/2022[2012-13]Status: DisposedITAT Chandigarh30 Sept 2022AY 2012-13

Bench: Shri Sudhanshu Srivastava & Shri Vikram Singh Yadav

For Appellant: Sh. Ashwani Kumar, CAFor Respondent: Sh. Sarabjit Singh, CIT DR

Section 133(6)Section 148Section 44A

M/S Shiv Shakti Construction, Sangrur vs. PCIT, Patiala

The appeals of the assessees stand allowed

ITA 481/CHANDI/2022[2012-13]Status: DisposedITAT Chandigarh30 Sept 2022AY 2012-13

Bench: Shri Sudhanshu Srivastava & Shri Vikram Singh Yadav

For Appellant: Sh. Ashwani Kumar, CAFor Respondent: Sh. Sarabjit Singh, CIT DR

Section 133(6)Section 148Section 44A

M/S Sudhir Forgings (P) Ltd., Ludhiana vs. Pr. CIT-3, Ludhiana

The appeal of the assessee stand dismissed

ITA 505/CHANDI/2018[2013-14]Status: DisposedITAT Chandigarh28 Sept 2022AY 2013-14

Bench: Shri Sudhanshu Srivastava & Shri Vikram Singh Yadavआयकर अपील सं./ Ita No. 505/Chd/2018 "नधा"रणवष" / Assessment Year :2013-14

For Appellant: None (Adj. Application)For Respondent: Sh. Sarabjeet Singh, CIT DR

Section 14ASection 263Section 68

High Court has emphasized in the case of ITO Vs. DG Housing Projects Ltd. [345 ITR 153 (Del)] that where there is complete lack of inquiry on the part of the AO, the assessment order would be erroneous. We also find that in terms of Explanation 2 below section ... distinction between the cases of ITA No. 505-Chd-2018 (A.Y. 2013-14) - M/s Sudhir Forgings (P) Ltd., Ludhiana 19 "inadequate inquiry" and "lack of inquiry" by also considering the ratio of the decision of Hon'ble Apex Court in the case of Rampyari Devi Sarogi

Nepal Singh Rathod (HUF), Hubli vs. Principal Commissioner of Income Tax, Hubli

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

ITA 400/BANG/2022[2017-18]Status: DisposedITAT Bangalore28 Sept 2022AY 2017-18

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariassessment Year: 2017-18

For Appellant: Shri K.R. Pradeep &For Respondent: Shri Sumer Singh Meena, D.R

Section 142(1)Section 143(2)Section 143(3)Section 263

tools was to be treated as revenue expenditure or not. Therefore, it could not be said that it was a case of lack of inquiry. The accounting practice followed for a number of years had the approval of the income-tax authorities. Even for future assessment years, the very same

Sericulturists Cum Farmers Service Co-Operative Society Limited, Bengaluru vs. The Principal Commissioner of Income Tax-2, Bengaluru

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

ITA 425/BANG/2022[2017-18]Status: DisposedITAT Bangalore26 Sept 2022AY 2017-18

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year : 2017-18 M/S. Sericulturists Cum Farmers Service Co-Operative Society Ltd., The Principal 01Sfcs Building, Commissioner Of Near Bus Stop, Income Tax – 2, Sarjapura Town, Bengaluru. Vs. Anekal Taluk, Bengaluru – 562 125. Pan: Aaaas6468H Appellant Respondent Assessee By : Shri Nitesh Ranjan, Ca Revenue By : Shri Praveen Karanth, Cit-Dr Date Of Hearing : 14-09-2022 Date Of Pronouncement : 26-09-2022 Order Per Beena Pillaipresent Appeal Is Filed By Assessee Against Order Dated 30/03/2022 Passed By Ld.Pr.Cit-2, Bangalore U/S. 263 Of The Act Relating To A.Y. 2017-18 On Following Grounds Of Appeal. Tax Effect Relating To Grounds Of Appeal Each Ground Of Appeal The Order Of The Learned Principal Commissioner Of Income-Tax, Bengaluru-2 ("Pr. Cit") Dated 30-Mar-2022, Passed Under I. Section 263 Of The Income-Tax Act,1961 ("The Act") N.A Insofar It Is Against The Appellant, Is Opposed To The Law, Weight Of Evidence, Facts & Circumstances Of The Appellant'S Case.

For Appellant: Shri Nitesh Ranjan, CAFor Respondent: Shri Praveen Karanth, CIT-DR

Section 143(2)Section 143(3)Section 263Section 57Section 68Section 80P(2)(a)Section 80P(2)(d)

under section 263 of the Act is V. unsustainable as the power to revise can be invoked only in the case of lack of inquiry and not in the case of inadequate inquiry. The Learned Pr. CIT erred in not understanding the fact that scrutiny assessment has already been completed

Smt.Nidhi Jain, Bhopal vs. The Pr CIT-1, Bhopal

In the result, the appeal of Assessee is allowed

ITA 128/IND/2021[2015-16]Status: DisposedITAT Indore19 Sept 2022AY 2015-16

Bench: Ms. Suchitra Kamble & Shri B.M. Biyani(Conducted Through Virtual Court) Assessment Year: 2015-16 Smt. Nidhi Jain Pr. Cit-1 Bhopal बनाम/V Indore S. (Appellant / Assessee) (Respondent / Revenue) Pan: Aiwpj5820H Assessee By Shri S.S. Deshpande, Ar Revenue By None Date Of Hearing 24.08.2022 Date Of Pronouncement 19.09.2022

Section 142(1)Section 143(2)Section 144Section 263

stock and the assessee has also given detailed explanation with regard to these items. Ld. AR, therefore, argued that there is no lack of inquiry by the Ld. AO qua increase in closing-stock. For the sake of clarity, completeness and further arguments, Ld. AR also pointed out that

Shri Kuldipsinh Bhikhubha Basiya, Rajkot vs. The Pr. CIT-1, Rajkot

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

ITA 153/RJT/2022[2017-18]Status: DisposedITAT Rajkot16 Sept 2022AY 2017-18

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyalआयकर अपील सं./Ita No. 153/Rjt/2022 िनधा"रण वष"/Asstt. Years: 2017-2018 Shri Kuldipsinh Bhikhubha Basiya, The Principal Commissioner Office No. 330, Vs. Of Income Tax, Star Plaza, Rajkot-1, Nr. Circuit House, Rajkot. Phulchhab Chowk, Rajkot.

For Appellant: Shri Mehul Ranpura, A.RFor Respondent: Shri Aarsi Prasad, CIT. D.R

Section 142(1)Section 143(3)Section 144Section 154Section 234ASection 263Section 69C

this regard. 10.2 Delhi High Court in the case of CIT Vs. Sunbeam Auto 332 ITR 167 (Del.), made a distinction between lack of inquiry and inadequate inquiry. The Hon’ble court held that where the AO has made inquiry prior to the completion of assessment, the same cannot ... revenue expenditure. Learned counsel for the assessee is right in his submission that one has to keep in mind the distinction between “lack of inquiry” and “inadequate inquiry”. If there was any inquiry, even inadequate, that would not by itself, give occasion to the Commissioner to pass orders under section

The Rajkot Nagrik Sahakari Bank Ltd. Rajkot, Rajkot vs. The Pr. CIT-1, Rajkot

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

ITA 65/RJT/2022[2017-18]Status: DisposedITAT Rajkot14 Sept 2022AY 2017-18

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyalआयकर अपील सं./Ita No. 65/Rjt/2022 िनधा"रण वष"/Asstt. Years: 2017-2018 Rajkot Nagrik Sahakari Bank Ltd. The Principal Commissioner Of Sanghavi & Co. Vs. Income Tax, Chartered Accountants, Range-1, “Prasham”, 4Th Floor, Rajkot. Near Bilkha Plaza, Kasturba Road, Rajkot-360001. Pan: Aaaar2912F

For Appellant: Shri Gaurang Sanghvi, A.RFor Respondent: Shri Aarsi Prasad, CIT. D.R

Section 142(1)Section 143(3)Section 14ASection 263