TRIVENI GLASS LIMITED,ALLAHABAD vs. INCOME TAX OFFICER WARD 2(3), ALLAHABAD

In the result, the appeal filed by assessee in ITA no

Bench: Shri.Vijay Pal Rao& Shri Ramit Kochar

Section 40(a)(ia) and 43B. It was submitted by ld. DR that the assessee has submitted details/evidences / explanations for the first time before ld. CIT(A) , and that the no remand report was called by CIT(A) from AO , which is in breach of Rule 46A of Income-tax Rules, 1962.The prayers were made

DY. COMMISSIONER OF INCOME TAX, CIRCLE -1, ALLAHABAD vs. M/S DEORA ELECTRIC WORKS, ALLAHABAD

In the result, both appeals i

237 ITR 13 (SC). v. CIT vs. Abhoji Rao Phalke 156 ITR 604 1995(MP) vi. Vashishtha Bhargav vs. ITO, (1975) 99 ITR (148) Delhi. vii. CIT vs. First Leasing Co. of India Limited (2000) 241 ITR 248 (Madras). viii. Bharat Ply Wood and Timber Products Limited vs. CIT (1992) 198 ITR 692 (Kerela) xi. New Light Trading

M/S DEORA ELECTRIC WORKS,ALLAHABAD vs. DY. COMMISSIONER OF INCOME TAX, CIRCLE -1, ALLAHABAD

In the result, both appeals i

237 ITR 13 (SC). v. CIT vs. Abhoji Rao Phalke 156 ITR 604 1995(MP) vi. Vashishtha Bhargav vs. ITO, (1975) 99 ITR (148) Delhi. vii. CIT vs. First Leasing Co. of India Limited (2000) 241 ITR 248 (Madras). viii. Bharat Ply Wood and Timber Products Limited vs. CIT (1992) 198 ITR 692 (Kerela) xi. New Light Trading

SURENDRA KUMAR MISHRA,ALLAHABAD vs. ACIT, CIR-2, ALLAHABAD

In the result, the appeal of the assessee is dismissed

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudharya.Y. 2002-03 Surendra Kumar Mishra, Vs. Assistant Commissioner Of 794A/1, Sohabatiyabagh, Income Tax, Circle-2, Allahabad Allahabad-211006, U.P. Pan:Aibpm4858R (Appellant) (Respondent) Assessee By: Sh. Ashish Bansal, Advocate Revenue By: Sh. A.K. Singh, Sr. Dr Date Of Hearing: 14.11.2024 Date Of Pronouncement: 10.02.2025 O R D E R Per Nikhil Choudhary, A.M.: This Is An Appeal Filed By The Assessee Against The Order Of The Ld. Cit(A), Under Section 250 R.W.S. 254 Of The Income Tax Act, 1961 On 26.10.2023. The Grounds Of Appeal Preferred By The Assessee Are As Under:- “1. Because The Cit(A) Has Erred In Law As Well As On Facts In Dismissing The 'Additional Ground' Relating To Non-Issuance Of Notice Under Section 143(2) Of The Act, Raised Before The Appellate Authority During The Course Of First Round Of Litigation, Which Has Been Remanded Back By The Hon'Ble Itat In Terms Of Order Dated 09.11.2012, By Observing That The Return Filed By The Appellant In Terms Of Letter Dated 10.11.2008 As Not A Valid Return In Compliance To Notice Dated 11.02.2008 Issued Under Section 148 Of The Act, As The Said Letter Was Filed By The Appellant After The Time Limit Of 30 Days Provided To Do So In Terms Of Notice Dated 11.02.208 Issued Under Section 148 Of The Act. 2. Because The Cit(A) Has Erred In Law As Well As On Facts In Observing That The Appellant Could Not Have Demand For Issuance Of Notice Under Section 143(2) Of The 1 Surendra Kumar Mishra

237 ITR 570, after the observations made by the Id. Assessing Officer himself to the effect that the appellant did not have any source of income (other than salary income). 11. BECAUSE without prejudice to the contentions raised in grounds No. 8 & 10 above, payment of 'free hold charges' should have been considered as 'cost of improvement of the 'Capital