In the result, both the Appeals are partly allowed
Bench: : Shri Laliet Kumar & Dr. Mitha Lal Meena
145 and, therefore, the applicability of section 40A(2)(b) is not proper. 4. That the appellant craves leave to add or amend the grounds of appeal before the appeal is finally heard or disposed off. Brief Facts 1. The Assessing Officer while framing the assessment had disallowed expenses paid by the Assessee towards consultancy and technical services