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1,361 results for “section 68”+ Section 40clear

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Key Topics

Addition to Income69Section 143(3)47Section 201(1)35Section 14A32Disallowance31Section 133A30Section 10A27Section 6827Section 14827Section 201

MR. MOHAMMED HANIF MOHAMMED YUSUF DHARWADKAR,HUBLI vs. INCOME-TAX OFFICER, WARD-1(1), HUBLI

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

ITA 135/BANG/2023[2017-18]Status: DisposedITAT Bangalore25 Jul 2023AY 2017-18

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year: 2017-18

For Appellant: Smt. Prathibha R., A.RFor Respondent: Shri Veera Raghavan, D.R
Section 147Section 234ASection 68

Section 68 of the Act. Accordingly, he added Rs. 1,25,89,399/- to the income of the assessee and completed the assessment. Against this assessee went in appeal before ld. CIT(A). 8. The ld. CIT(A) observed that the assessee had opportunity before three forums - ITO(Inv.), AO and these proceedings — to furnish requisite material to establish

GEETHA PUNDALEEKA ,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION) CIRCLE-1(1), BANGALORE

Showing 1–20 of 1,361 · Page 1 of 69

...
26
TDS23
Deduction23

The appeal of the assessee is dismissed

ITA 1397/BANG/2018[2013-14]Status: DisposedITAT Bangalore19 Jan 2022AY 2013-14

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariassessment Year : 2013-14

For Appellant: Shri G. Venkatesh, AdvocateFor Respondent: Smt. Priyadarshini Besaganni, Jt. CIT(DR)(ITAT), Bengaluru

68,343 as professional consultancy expenses paid to V.J. Shraff & Co. The AO verified the details and evidences and noticed that the professional services were relating to advice and assistance in filing NIVAT/CST return, registration of company etc which were for the FYs 2007-09, 2008-09, 2009-10. The total expenses Rs.1,34,832/-claimed on this account

M/S INFOSYS LIMITED,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-3(1)(1), BANGALORE

In the result, the appeal filed by the assessee stands partly allowed

ITA 718/BANG/2017[2012-13]Status: DisposedITAT Bangalore28 Nov 2022AY 2012-13

Bench: Shri Chandra Poojaria & Smt. Beena Pillaiassessment Appeal No. Appellant Respondent Year M/S. Infosys Ltd., The Assistant Electronic City, Commissioner It(Tp)A No. Hosur Road, Of Income Tax, 2012-13 718/Bang/2017 Bangalore – 560 Circle – 100. 3(1)(1), Pan: Bangalore. Aaaci4798L : Shri Padamchand Khincha, Assessee By Ca : Shri K.V. Arvind & Shri Dilip, Revenue By Standing Counsels For Dept. Date Of Hearing : 15-09-2022 Date Of Pronouncement : 28-11-2022 Order Per Beena Pillaipresent Appeal Arises Out Of Final Assessment Order Dated 28/02/2017 Passed By The Ld.Acit, Circle – 3(1)(1), Bangalore For A.Y. 2012-13 On Following Grounds Of Appeal: General & Legal Grounds 1. The Order Passed By The Learned Assessing Officer & The Directions Of Hon’Ble Drp To The Extent Prejudicial To The Appellant Is Bad In Law & Liable To Be Quashed. Grounds On Denial Of Deduction Claimed Under Section 10Aa In Respect Of 4 Sez Units Viz., Chennai – Unit 1, Chandigarh, Mangalore - Unit 1 & Pune Unit 1 2. The Learned Assessing Officer Has Erred In Denying Deduction Claimed Under Section 10Aa In The Return Of Income Totally Amounting To Rs. 2227,82,65,630 In Respect

Section 10ASection 14ASection 2Section 2(24)Section 40

68,35,533/- under section 40(a)(ia) of the Act for non deduction of tax at source. 13.4. The Ld.AR

M/S HONEYWELL TECHNOLOGY SOLUTIONS LAB PRIVATE LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-3(1)(2), BANGALORE

In the result, the assessee's appeal is partly allowed

ITA 1210/BANG/2018[2010-11]Status: DisposedITAT Bangalore07 Jan 2021AY 2010-11

Bench: Shri N.V. Vasudevan & Shri Chandra Poojarim/S. Honeywell Technology Solutions Lab Pvt. Ltd., 151/1, Bannerghata Road, Doraisanpalya, Bangalore-560 076 ….Appellant Pan Aaach 4151J Vs. Dy. Commissioner Of Income Tax, Circle 3(1)(2), Bangalore. ……Respondent. Assessee By: Smt. Shreya Loyalka, C.A. Revenue By: Shri B.K. Panda, Cit (D.R)

For Appellant: Smt. Shreya Loyalka, C.AFor Respondent: Shri B.K. Panda, CIT (D.R)
Section 80J

68 had resigned on or before 25.01.2010, as such these employees did not complete period of 300 days in the employment and so, the salary of Rs 1,59,48,714/- paid to these employees cannot be considered for the purpose of computation of deduction under Section 80JJAA of the Act. 5 3.2 Similarly in relation to deduction claimed

JCIT, BANGALORE vs. M/S HEWLETT - PACKARD INDIA SALES PRIVATE LIMITED, BANGALORE

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

ITA 593/BANG/2015[2010-11]Status: DisposedITAT Bangalore21 Nov 2023AY 2010-11

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year : 2009-10 M/S. Hp India Sales Pvt. Ltd. (Formerly Known As The Joint Hewlett-Packard India Commissioner Sales Pvt. Ltd.), Of Income Tax, 24, Salarpuria Arena, Ltu, Hosur Main Road, Bangalore. Vs. Adugodi, Bangalore – 560 030. Pan: Aaacc9862F Appellant Respondent & Assessment Year : 2009-10 (By Revenue) : Shri Percy Pardiwala, Sr. Assessee By Advocate Revenue By : Shri Saravanan B, Cit-Dr

For Respondent: Shri Saravanan B, CIT-DR
Section 145(1)Section 40

section 40(a) and Page 32 ITA Nos. 579 & 593/Bang/2015 40(a)(ia), the Taxpayer reverses accruals created in the previous year and accounts for expenses in connection with the subject accruals and complies with the applicable withholding tax. As a part of the proceedings before the learned CIT(A), the Taxpayer has also furnished sample extract of such

HEWLETT PACKARD INDIA SALES PVT. LTD.,,BANGALORE vs. JCIT, BANGALORE

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

ITA 579/BANG/2015[2009-10]Status: DisposedITAT Bangalore21 Nov 2023AY 2009-10

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year : 2009-10 M/S. Hp India Sales Pvt. Ltd. (Formerly Known As The Joint Hewlett-Packard India Commissioner Sales Pvt. Ltd.), Of Income Tax, 24, Salarpuria Arena, Ltu, Hosur Main Road, Bangalore. Vs. Adugodi, Bangalore – 560 030. Pan: Aaacc9862F Appellant Respondent & Assessment Year : 2009-10 (By Revenue) : Shri Percy Pardiwala, Sr. Assessee By Advocate Revenue By : Shri Saravanan B, Cit-Dr

For Respondent: Shri Saravanan B, CIT-DR
Section 145(1)Section 40

section 40(a) and Page 32 ITA Nos. 579 & 593/Bang/2015 40(a)(ia), the Taxpayer reverses accruals created in the previous year and accounts for expenses in connection with the subject accruals and complies with the applicable withholding tax. As a part of the proceedings before the learned CIT(A), the Taxpayer has also furnished sample extract of such

ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-1-(4), BENGALURU vs. M/S KANSUR DEVELOPERS INDIA PVT. LTD., BENGALURU

In the result, the revenue appeals in ITA Nos

ITA 1441/BANG/2018[2009-10]Status: DisposedITAT Bangalore28 Oct 2022AY 2009-10

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariita Nos.1441 & 1442/Bang/2018 Assessment Year: 2009-10 & 2012-13 Acit Central Circle- M/S. Kansur Developers India Pvt. Ltd. 1(4) No.2650, Ground Floor Bengaluru Vs. 37Th B Cross, 28Th Main, 9Th Block Jayanagar Bangalore 560 009 Pan No : Aacck9866F Appellant Respondent C.O. Nos.103&104/Bang/2018 (Arising Out Of Ita Nos.1441 & 1442/Bang/2018) Assessment Years: 2009-10 & 2012-13

For Appellant: Shri Dilip, Junior Standing Counsel forFor Respondent: Dept
Section 147

68 or 69, in our opinion, have limited application in the case of nonresident." 18. Likewise, in the case of Smt. Susila Ramasamy V. ACIT, Central Circle – II(2), Chennai [008 ITR (Trib) 18 (Chennai)], Chennai Bench has held as under: "A non-resident person having money in foreign country could not be called upon to pay income

ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE - 1(4), BENGALURU vs. M/S SNOWSHINE REALTORS PVT.LTD. , BENGALURU

In the result, the revenue appeals in ITA Nos

ITA 1443/BANG/2018[2008-09]Status: DisposedITAT Bangalore28 Oct 2022AY 2008-09

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariita Nos.1441 & 1442/Bang/2018 Assessment Year: 2009-10 & 2012-13 Acit Central Circle- M/S. Kansur Developers India Pvt. Ltd. 1(4) No.2650, Ground Floor Bengaluru Vs. 37Th B Cross, 28Th Main, 9Th Block Jayanagar Bangalore 560 009 Pan No : Aacck9866F Appellant Respondent C.O. Nos.103&104/Bang/2018 (Arising Out Of Ita Nos.1441 & 1442/Bang/2018) Assessment Years: 2009-10 & 2012-13

For Appellant: Shri Dilip, Junior Standing Counsel forFor Respondent: Dept
Section 147

68 or 69, in our opinion, have limited application in the case of nonresident." 18. Likewise, in the case of Smt. Susila Ramasamy V. ACIT, Central Circle – II(2), Chennai [008 ITR (Trib) 18 (Chennai)], Chennai Bench has held as under: "A non-resident person having money in foreign country could not be called upon to pay income

ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE - 1(4), BENGALURU vs. M/S KANSUR DEVELOPERS INDIA PVT. LTD. , BENGALURU

In the result, the revenue appeals in ITA Nos

ITA 1442/BANG/2018[2012-13]Status: DisposedITAT Bangalore28 Oct 2022AY 2012-13

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariita Nos.1441 & 1442/Bang/2018 Assessment Year: 2009-10 & 2012-13 Acit Central Circle- M/S. Kansur Developers India Pvt. Ltd. 1(4) No.2650, Ground Floor Bengaluru Vs. 37Th B Cross, 28Th Main, 9Th Block Jayanagar Bangalore 560 009 Pan No : Aacck9866F Appellant Respondent C.O. Nos.103&104/Bang/2018 (Arising Out Of Ita Nos.1441 & 1442/Bang/2018) Assessment Years: 2009-10 & 2012-13

For Appellant: Shri Dilip, Junior Standing Counsel forFor Respondent: Dept
Section 147

68 or 69, in our opinion, have limited application in the case of nonresident." 18. Likewise, in the case of Smt. Susila Ramasamy V. ACIT, Central Circle – II(2), Chennai [008 ITR (Trib) 18 (Chennai)], Chennai Bench has held as under: "A non-resident person having money in foreign country could not be called upon to pay income

BHUWALKA SALES CORPORATION,BANGALORE vs. ACIT, BANGALORE

In the result, the assessee's appeal for Assessment Year 2009-10 is treated as allowed for statistical purposes

ITA 1436/BANG/2013[2009-10]Status: DisposedITAT Bangalore01 Apr 2015AY 2009-10

Bench: Smt. P. Madhavi Devi & Shri Jason P. Boazi.T. A. No.1436/Bang/2013 (Assessment Year : 2009-10) M/S. Bhuwalka Sales Corporation, No.5, Walker Lane, Bhuwalka Landmark, Langford Road, Richmond Town, Bangalore-560 025 …. Appellant. Pan Aaifb 0063G Vs. Asst. Commissioner Of Income Tax, Circle 1(1), Bangalore. ….. Respondent. Appellant By : Shri K. Seshadri, C.A. Respondent By : Shri P. Dhivahar, Jcit (D.R). Date Of Hearing : 2.2.2015. Date Of Pronouncement : 1.4.2015. O R D E R Per Shri Jason P. Boaz, A.M. : This Appeal By The Assessee Is Directed Against The Order Of The Commissioner Of Income Tax (Appeals)-I, Bangalore Dt.12.8.2013 For Assessment Year 2009-10. 2. The Facts Of The Case, Briefly, Are As Under :- 2.1 The Assessee, In The Business Of Trading In Rolled Products, Filed The Return Of Income For Assessment Year 2009-10 On 26.9.2009 Declaring Income Of Rs.49,25,026. The Return Was Processed Under Section 143(1) Of The Income Tax Act, 1961 (In Short 'The Act') & The Case Was Taken Up For Scrutiny. The Assessment Was Completed Under Section 143(3) Of The Act Vide

For Appellant: Shri K. Seshadri, C.AFor Respondent: Shri P. Dhivahar, JCIT (D.R)
Section 143(1)Section 143(3)Section 2(22)(e)Section 251(1)(a)Section 68

68 of the Act in place of deemed dividend u/s.2(22)(e) of the Act, the learned CIT (Appeals) on the merits of the issue, at para 3.16 of the order, held that the addition of Rs.1.25 Crores is to be made as unexplained cash credit u/s.68 of the Act instead of the addition as deemed dividend under Section

M/S ONMOBILE GLOBAL LIMITED ,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-5(1)(2), BANGALORE

In the result, both these appeals are partly allowed

ITA 139/BANG/2019[2014-15]Status: DisposedITAT Bangalore10 Aug 2022AY 2014-15

Bench: Shri George George K. & Ms. Padmavathy S

For Appellant: Shri T. Suryanarayana, AdvocateFor Respondent: Dr. Manjunath Karkihalli, CIT(DR)(ITAT), Bengaluru
Section 143(3)Section 14ASection 234BSection 244ASection 32

Section 10AA of the Act. IT(TP)A Nos.139 & 2560/Bang/2019 Page 5 of 40 6. Aggrieved, the Assessee filed its objections before the DRP which vide its directions dated 28.09.2018, rejected the Assessee’s objections to a large extent while granting marginal relief. Pursuant to the directions of the DRP, the AO passed the final assessment order dated

M/S. ONMOBILE GLOBAL LIMITED,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE- 5(1)(2), BENGALURU

In the result, both these appeals are partly allowed

ITA 2560/BANG/2019[2015-16]Status: DisposedITAT Bangalore10 Aug 2022AY 2015-16

Bench: Shri George George K. & Ms. Padmavathy S

For Appellant: Shri T. Suryanarayana, AdvocateFor Respondent: Dr. Manjunath Karkihalli, CIT(DR)(ITAT), Bengaluru
Section 143(3)Section 14ASection 234BSection 244ASection 32

Section 10AA of the Act. IT(TP)A Nos.139 & 2560/Bang/2019 Page 5 of 40 6. Aggrieved, the Assessee filed its objections before the DRP which vide its directions dated 28.09.2018, rejected the Assessee’s objections to a large extent while granting marginal relief. Pursuant to the directions of the DRP, the AO passed the final assessment order dated

VEERENDRA KUMAR PATIL,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME, CENTRAL CIRCLE-1(2), BANGALORE

In the result, the appeal of the assessee for AY 2013-14 is partly allowed

ITA 1658/BANG/2024[2017-18]Status: DisposedITAT Bangalore22 May 2025AY 2017-18

Bench: Shri. Laxmi Prasad Sahu & Shri. Soundararajan K

For Appellant: Shri. Ramesh, CAFor Respondent: Shri. Subramanian S, JCIT(DR)(ITAT), Bangalore
Section 132(4)Section 133(6)Section 133ASection 147Section 148Section 151Section 153CSection 234A

68. Cash credits. - Where any sum is found credited in the books of an assessee maintained for any previous year, and the assessee offers no explanation about the nature and source thereof or the explanation offered by him is not, in the opinion of the [Assessing Officer] [ Substituted by Act 4 of 1988, Section 2, for " Income-tax Officer

DCIT, BANGALORE vs. M/S CORE OBJECTS INDIA PVT. LTD.,, BANGALORE

In the result appeal filed by assessee stands allowed as indicated hereinabove and appeal filed by revenue stands allowed partly

ITA 517/BANG/2015[2010-11]Status: DisposedITAT Bangalore01 Apr 2021AY 2010-11

Bench: Shri. Chandra Poojari & Smt. Beena Pillaiit(Tp)A No.517/Bang/2015 Assessment Year : 2010-11

For Appellant: Shri Muzaffar Hussain, CIT (DR)For Respondent: Smt. Tanmayee Rajkumar
Section 10ASection 143Section 144CSection 144C(13)Section 194JSection 40Section 9(1)(iv)

40. The DRP thus following decision of Hon’able Karnataka High Court in case of Yokogawa reported in (2012) 341 ITR 385 and Page 26 of 55 IT(TP)A No.517 & 570/Bang/2015 the decision of Mumbai Tribunal in case of Deloitte Consulting India Pvt. Ltd., reported in (2014) 151 ITD 454, held that, no TP adjustment would enter the computation

KOGOD BASAVARAJU JAYACHANDRA ,HASSAN vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(2), BANGALORE

In the result the ITA No

ITA 1618/BANG/2024[2017-18]Status: DisposedITAT Bangalore26 May 2025AY 2017-18

Bench: Shri. Laxmi Prasad Sahu & Shri. Soundararajan K

For Appellant: Shri. Ramesh, CAFor Respondent: Shri.Shivanand Kalakeri, CIT(DR)(ITAT), Bangalore
Section 132(4)Section 133(6)Section 133ASection 143(3)Section 147Section 148Section 151Section 153CSection 234A

40 the list of parties names are there with quantification for the different Assessment Years. At Sl. No.06, the name of assessee is appearing but there amount is quantified in the breakup of Rs.68,45,21,295/-. Further, a search was conducted under ection 132(1) of the Act on 28.08.2017 and the statement has been recorded under section

SAP INDIA PRIVATE LIMITED ,BANGALORE vs. COMMISSIONER INCOME TAX (A) BANGALORE-6, BANGALORE

In the result, both the appeals of the assessee are partly allowed

ITA 682/BANG/2017[2010-11]Status: DisposedITAT Bangalore16 Nov 2021AY 2010-11

Bench: Shri N.V. Vasudevanand Shri B. R. Baskaran

For Appellant: Shri. Chavali Narayan, CAFor Respondent: Shri. Sumer Singh Meena, CIT(DR)(OSD)(ITAT), Bengaluru
Section 143(3)Section 28Section 36(1)(vii)

68,26,037/- as bad debts written off. The AO did not dispute the fact that the amounts that were claimed as bad debts were written off had been booked as sales and maintenance charges for the Financial Year 2009-10 (Assessment Year 2010-11). He noticed that some of the outstandings have been written off as bad debts

SAP INDIA PRIVATE LIMITED,BANGALORE vs. COMMISSIONER INCOME TAX (A) BANGALORE-6, BANGALORE

In the result, both the appeals of the assessee are partly allowed

ITA 683/BANG/2017[2009-10]Status: DisposedITAT Bangalore16 Nov 2021AY 2009-10

Bench: Shri N.V. Vasudevanand Shri B. R. Baskaran

For Appellant: Shri. Chavali Narayan, CAFor Respondent: Shri. Sumer Singh Meena, CIT(DR)(OSD)(ITAT), Bengaluru
Section 143(3)Section 28Section 36(1)(vii)

68,26,037/- as bad debts written off. The AO did not dispute the fact that the amounts that were claimed as bad debts were written off had been booked as sales and maintenance charges for the Financial Year 2009-10 (Assessment Year 2010-11). He noticed that some of the outstandings have been written off as bad debts

M/S. KHODAY INDIA LIMITED,BANGALORE vs. INCOME TAX OFFICER, WARD- 4(1)(2), BANGALORE

In the result appeal filed by assessee stands allowed

ITA 97/BANG/2022[2015-16]Status: DisposedITAT Bangalore30 Jun 2022AY 2015-16

Bench: Smt. Beena Pillai & Shri. Laxmi Prasad Sahuassessment Year : 2015-16 M/S. Khoday India Ltd., The Income-Tax 7Th Mile, Brewery House, Officer, Kanakapura Road, Ward 4 (1)(2), Bangalore – 560 062. Bangalore. Pan: Aaack6734C Vs. Appellant Respondent Assessee By : Shri V. Sridhar, Ca : Shri Ramesh B.R., Addl. Cit Revenue By (Dr) Date Of Hearing : 09-06-2022 Date Of Pronouncement : 30-06-2022 Order Per Beena Pillaipresent Appeal Is Filed By The Assessee Against Order Dated 09/12/2021 Passed By The Ld.Cit(A)-11, Bangalore For Assessment Year 2015-16 On Following Grounds Of Appeal: “1. The Order Of The Learned Commissioner Of Income-Tax (Appeals), Bengaluru-11, Bengaluru In Ita No.Cit(A)- 11/Bng/Tr.10036/2018-19 (Din: Itba /Apl /M/ 250 /2021-22/ 1037634908(1) Dated:09.12.2021 Is Opposed To Law, Weight Of Evidence, Probabilities & Facts & Circumstances Of The Case. 2. The Learned Commissioner Of Income-Tax (Appeals) Erred In Confirming The Order Of The Assessing Officer Passed U/S.154 Of The Income Tax Act, 1961 Dated:14.02.2018. 3. The Learned Commissioner Of Income-Tax (Appeals) Erred In Not Directing The Assessing Officer To Set Off The Entire

For Appellant: Shri V. Sridhar, CA
Section 115BSection 154Section 68Section 71

40 crores as unexplained, by invoking provisions of section 68 of the Act. The Ld.AR in response to the notice

TOTAL ENVIRONMENT BUILDING SYSTEMS PRIVATE LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-7(1)(1), BANGALORE

In the result, revenue’s appeal stands dismissed and the assessee’s appeals for A

ITA 45/BANG/2017[2010-11]Status: DisposedITAT Bangalore29 Jun 2022AY 2010-11

Bench: Shri. Chandra Poojari & Smt. Beena Pillai

For Respondent: Shri Vilas V Shinde, CIT DR
Section 250Section 37Section 40Section 43B

section 40(a)(ia) of the Act. 3.8 Aggrieved by the additions made, assessee preferred appeal before the Ld.CIT(A). 3.9 The Ld.CIT(A) in the impugned order partly allowed the appeal by granting relief in respect of the disallowance made towards a long-term capital gain. 3.10 Aggrieved by the order of the Ld.CIT(A), the assessee

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-7(1)(1), BANGALORE vs. M/S TOTAL ENVIRONMENT BUILDING SYSTEMS PVT LTD , BANGALORE

In the result, revenue’s appeal stands dismissed and the assessee’s appeals for A

ITA 40/BANG/2017[2010-11]Status: DisposedITAT Bangalore29 Jun 2022AY 2010-11

Bench: Shri. Chandra Poojari & Smt. Beena Pillai

For Respondent: Shri Vilas V Shinde, CIT DR
Section 250Section 37Section 40Section 43B

section 40(a)(ia) of the Act. 3.8 Aggrieved by the additions made, assessee preferred appeal before the Ld.CIT(A). 3.9 The Ld.CIT(A) in the impugned order partly allowed the appeal by granting relief in respect of the disallowance made towards a long-term capital gain. 3.10 Aggrieved by the order of the Ld.CIT(A), the assessee