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In the result, both the appeals of the assessee are partly allowed for statistical purposes
Bench: Shri Waseem Ahmed & Shri Soundararajan K
section 254 only to decide the grounds which arise from the order of the Commissioner of Income-tax (Appeals). Both the assessee as well as the Department have a right to file an appeal/cross-objections before the Tribunal. The Tribunal should not be prevented from considering questions of law arising in assessment proceedings, although not raised earlier. 5.1 From the above