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262 results for “condonation of delay”+ Addition to Incomeclear

Sorted by relevance

Mumbai3,217Chennai3,122Delhi2,712Kolkata2,152Pune1,239Bangalore1,196Ahmedabad1,089Hyderabad1,074Jaipur737Chandigarh551Surat496Indore429Patna388Raipur364Lucknow332Amritsar322Nagpur314Cochin306Visakhapatnam304Cuttack262Rajkot261Karnataka212Agra203Panaji145Calcutta123Guwahati79Jodhpur74Dehradun74Jabalpur67Allahabad49Telangana38Varanasi35Ranchi27SC27Kerala7Orissa6Rajasthan6Andhra Pradesh6Himachal Pradesh3Punjab & Haryana1Gauhati1

Key Topics

Section 26391Addition to Income79Section 12A62Limitation/Time-bar40Condonation of Delay34Section 143(3)32Section 14720Cash Deposit19Disallowance

RAVI METALLICS LIMITED,ROURKELA vs. PR.CIT, SAMBALPUR

In the result, appeal of the assessee is allowed

ITA 34/CTK/2021[2014-15]Status: DisposedITAT Cuttack05 Jul 2022AY 2014-15

Bench: Shri George Mathan & Shri Arun Khodpiaravi Metallics Limited, I/10, Civil Township, Rourkela-769004 Pan No.Adqps 4031 G ………………Assessee Versus Pr.Cit, Sambalpur ………………..Revenue Shri P.R.Mohanty, Ar For The Assessee Shri M.K.Gautam, Cit-Dr For The Revenue Date Of Hearing : 30/05/2022 Date Of Pronouncement : 30/05/2022 आदेश / O R D E R Per Bench : This Is An Appeal Filed By The Assessee Against The Order Of The Ld. Pr.Cit, Sambalpur, Passed U/S.263 Of The Act In Case No.Pcit/Sbp/263/26/2018-19, Dated 29.03.2019 For The Assessment Year 2014-2015. Heard On The Question Of Condonation Of Delay 2. On Perusal Of The Record, We Found That The Appeal Of The Assessee Is Barred By 686 Days. In This Regard, Ld. Ar Filed An Application Along With Affidavit For Condonation Of Delay, Wherein It Has Been Submitted That The Delay Occurred In Filing The Present Appeal Is Neither Intentional Nor Deliberate But Due To Unfortunate & Unavoidable Circumstances Beyond

Section 253Section 263

delay in filing the appeal stands condoned and the appeal is admitted for hearing. Heard on the merits of the appeal 7. Now, we shall proceed to decide the appeal of the assessee challenging the order passed u/s.263 of the Act. 8. It was submitted by the ld. AR that the Pr.CIT has invoked his powers u/s.263

Showing 1–20 of 262 · Page 1 of 14

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19
Section 14418
Section 14817
Section 271(1)(c)15

M/S. B.K. JENA & ASSOCIATES,KUJANG vs. PR. CIT, CUTTACK

In the result, appeal of the assessee stands partly allowed

ITA 365/CTK/2019[2014-15]Status: HeardITAT Cuttack16 Sept 2022AY 2014-15

Bench: Before S/Shri George Mathan, Judicial & Arun Khodpia & Arun Khodpia & Arun Khodpiaassessment Year : 2014-15 M/S. B.K.Jena & Associates, M/S. B.K.Jena & Associates, Vs. Pr. Cit, Cuttack Pr. Cit, Cuttack Rangiagarh, Rangiagarh, Jhimani, Jhimani, Kujang, Kujang, Jagatsinghpur Jagatsinghpur Pan/Gir No. No.Aagfb 4157 P (Appellant (Appellant) .. ( Respondent Respondent) Assessee By : Shri P.R.Mohanty P.R.Mohanty, Ar Revenue By : Shri M.K.Gautam, Cit ( Cit (Dr) Date Of Hearing : 16/9/ 20 / 2022 Date Of Pronouncement : 16/ /9/2022 O R D E R Per Bench

For Appellant: Shri P.R.MohantyFor Respondent: Shri M.K.Gautam, CIT (
Section 263

condone the delay. 8. On merits, ld AR drew our attention to the assessment order passed u/s.143(3) of the Act dated 27.12.2016 at para 1 of the assessment order to submit that this was a case of “Limited Scrutiny” under CASS. It was the submission that in the limited scrutiny, the notice issued u/s.142(1) categorically asked

KAPILDEV DUBEY,MAYURBHANJ vs. INCOME TAX OFFICER WARD-2,BARIPADA, MAYURBHANJ

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 185/CTK/2025[2017-18]Status: DisposedITAT Cuttack16 Jun 2025AY 2017-18
For Appellant: P.K. Mishra, AdvocateFor Respondent: S.C. Mohanty, Sr. DR
Section 143(3)Section 250Section 69A

condone the delay and admit the appeal for adjudication on merit. 4. Brief facts of the case are that the appellant is an individual and was engaged in retail trading of cloth and petrol pump. The return of income for the Assessment year 2017-18 was e-filed on 15.11.2017 declaring total income of Rs. 8,53,890/-. Subsequently

PASUPATI FEEDS,CUTTACK vs. PRINCIPAL CIT(CENTRAL), VISAKHAPATNAM

In the result, cross objections filed by the assessee for assessment years 2008-09 to 2010-2011 are allowed and that the appeals of revenue are dismissed

ITA 48/CTK/2019[2010-11]Status: DisposedITAT Cuttack09 Dec 2021AY 2010-11

Bench: S/ S/Shri Chandra Mohan Garg, Judicial & Manish Borad & Manish Borad & Manish Boradit(Ss)A Nos.45 To 47/Ctk/20 /Ctk/2018 Assessment Year Assessment Years : 2008-09 To 2010 09 To 2010-2011 Acit, Central Circle, Acit, Central Circle, Vs. M/S. Pasupati Feeds, Kota Sahi, M/S. Pasupati Feeds, Kota Sahi, Cuttack Tangi, Cuttack Tangi, Cuttack Pan/Gir No. No.Aaefp 4117 F (Appellant (Appellant) .. ( Respondent Respondent) C.O.Nos.33 To 35/Ctk/2018 C.O.Nos.33 To 35/Ctk/2018 (Arising Out Of It (Arising Out Of It(Ss)A Nos.45 To 47/Ctk/2018) A Nos.45 To 47/Ctk/2018) Assessment Years: 2008 Assessment Years: 2008-09 To 2010 09 To 2010-2011

For Appellant: Shri P.R.MohantyFor Respondent: Shri M.K.Gautam
Section 153A

income for A.Yrs. 2008-09 to 2013-14 on 7.11.2014. The case of the assessee is that the return for A.Y. 2012-13 was filed on 7.11.2012. As per section 143(2) of the Act, the last date on which notice for assessment would have been issued was 30.9.2013. All the other returns are filed on earliest date

PASUPATI FEEDS,CUTTACK vs. PRINCIPAL CIT(CENTRAL), VISAKHAPATNAM

In the result, cross objections filed by the assessee for assessment years 2008-09 to 2010-2011 are allowed and that the appeals of revenue are dismissed

ITA 47/CTK/2019[2009-10]Status: DisposedITAT Cuttack09 Dec 2021AY 2009-10

Bench: S/ S/Shri Chandra Mohan Garg, Judicial & Manish Borad & Manish Borad & Manish Boradit(Ss)A Nos.45 To 47/Ctk/20 /Ctk/2018 Assessment Year Assessment Years : 2008-09 To 2010 09 To 2010-2011 Acit, Central Circle, Acit, Central Circle, Vs. M/S. Pasupati Feeds, Kota Sahi, M/S. Pasupati Feeds, Kota Sahi, Cuttack Tangi, Cuttack Tangi, Cuttack Pan/Gir No. No.Aaefp 4117 F (Appellant (Appellant) .. ( Respondent Respondent) C.O.Nos.33 To 35/Ctk/2018 C.O.Nos.33 To 35/Ctk/2018 (Arising Out Of It (Arising Out Of It(Ss)A Nos.45 To 47/Ctk/2018) A Nos.45 To 47/Ctk/2018) Assessment Years: 2008 Assessment Years: 2008-09 To 2010 09 To 2010-2011

For Appellant: Shri P.R.MohantyFor Respondent: Shri M.K.Gautam
Section 153A

income for A.Yrs. 2008-09 to 2013-14 on 7.11.2014. The case of the assessee is that the return for A.Y. 2012-13 was filed on 7.11.2012. As per section 143(2) of the Act, the last date on which notice for assessment would have been issued was 30.9.2013. All the other returns are filed on earliest date

SUJATA NAYAK,RAYAGADA vs. ITO, RAYAGADA

In the result, appeal of the assessee stands partly allowed

ITA 151/CTK/2022[2010-11]Status: DisposedITAT Cuttack19 Jan 2023AY 2010-11

Bench: Before S/Shri George Mathan, Judicial & Arun Khodpia & Arun Khodpia & Arun Khodpiaassessment Year : 2010-2011 2011 Smt.Sujata Sujata Nayak Nayak, W/O. Vs. Ito, Ito, Rayagada Rayagada Ward, Ward, Shri Lokanath Nayak, Omp Shri Lokanath Nayak, Omp Rayagada Road, Indira Nagar, 6Th Lane, Road, Indira Nagar, 6 Po;Dist: Rayagada Po;Dist: Rayagada Pan/Gir No. Pan/Gir No.Addpn 2024 P (Appellant (Appellant) .. ( Respondent Respondent) Assessee By : Ms Archita Nayak, Ar : Ms Archita Nayak, Ar Revenue By : Shri S.C.Mohanty, Sr S.C.Mohanty, Sr Dr Date Of Hearing : 19/01 01/2023 Date Of Pronouncement : 19/01 /01/2023 O R D E R Per Bench This Is An Appeal Filed By The Assessee Against The Order Of The Ld This Is An Appeal Filed By The Assessee Against The Order Of The Ld This Is An Appeal Filed By The Assessee Against The Order Of The Ld Cit(A), Berhampur, In Appeal No.0055/13 , Berhampur, In Appeal No.0055/13-14 Dated Dated 31.7.2014 For The Assessment Year Assessment Year 2010-2011. 2. Ms Archita Nayak, Ms Archita Nayak, Ld Ar Appeared For The Assessee & Shri Ld Ar Appeared For The Assessee & Shri S.C.Mohanty, Ld Sr Dr Appeared For The Revenue. S.C.Mohanty, Ld Sr Dr Appeared For The Revenue.

For Appellant: Ms Archita Nayak, ARFor Respondent: Shri S.C.Mohanty, Sr
Section 143(3)

income Tax Act. one of the considerations for this decision : period of delay [perfect circle India Ltd' v. ACIT (2020) 120 taxmann.com 262 (Bom) following cenzure industries Ltd' v. rro (Notice of Motion No.492 and 493 of 2015 dt.15.1.2016 (Bom). The fact about the delay period in the present case is more than 7 years and 9 months' The issue

MR. NARENDRA KUMA RBAL,KEONJHAR vs. INCOME TAX OFFICER, KEONJHAR WARD, KEONJHAR

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 178/CTK/2025[2011-12]Status: HeardITAT Cuttack28 May 2025AY 2011-12

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 143(3)Section 250

condone the delay and admit the appeal for adjudication. 2. The assessee is in appeal before the Tribunal raising the following grounds of appeal: “A. For that, the order of the forums below are illegal absurd, improper and excessive in the facts and circumstances of the case, hence the orders passed are liable to be deleted. B. For that

TAPAN KUMAR SETHY,CUTTACK vs. ITO, WARD-2(4), CUTTACK

In the result, appeal of the assessee stands allowed for statistical purposes

ITA 227/CTK/2025[2017-18]Status: DisposedITAT Cuttack02 Jul 2025AY 2017-18

Bench: S/Shri Duvvuru Rl Reddy(Kz) & Rajesh Kumarassessment Year : 2017-18 Tapan Kumar Sethy Vs. Ito, Ward-2(4), Purighat Road, Telenga Bazar , Cuttack Cuttack- 753009 Pan/Gir No. Blzps 1048 F (Appellant) .. ( Respondent) Assessee By : Shri Sudhanshu Kr Das, Ar Revenue By : Shri Prateek Kr Mishra, Sr. Dr Date Of Hearing : 02 /07/2025 Date Of Pronouncement : 02 /07/2025 O R D E R Per Bench The Present Appeal Is Directed At The Instance Of Assessee Against The Order Of Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nafc), New Delhi Nfac), Delhi Dated 15/06/2022 In Appeal No.Cit(A), Cuttack/10917/2019-20 Passed For Assessment Year 2017-18. 2. The Appeal Is Time Barred By 952 Days. The Assessee Has Filed Condonation Petition Dated 7.4.2025 Supported With Affidavit Stating The Reasons That Due To Serious Illness Of The Assessee’S Mother & Change Of P A G E 1 | 5 Assessment Year : 2017-18

For Appellant: Shri Sudhanshu Kr Das, ARFor Respondent: Shri Prateek Kr Mishra, Sr. DR
Section 253(3)

Income Tax (Appeals), National Faceless Appeal Centre (NAFC), New Delhi NFAC), Delhi dated 15/06/2022 in Appeal No.CIT(A), Cuttack/10917/2019-20 passed for Assessment Year 2017-18. 2. The appeal is time barred by 952 days. The assessee has filed condonation petition dated 7.4.2025 supported with affidavit stating the reasons that due to serious illness of the assessee’s mother and change

M/S. PRAMOD KUMAR ROUT,CUTTACK vs. ACIT, CENTRAL CIRCLE, CUTTACK

In the result, all the appeals of the all the assessees are allowed

ITA 307/CTK/2018[2013-14]Status: DisposedITAT Cuttack29 Oct 2021AY 2013-14
For Appellant: Shri P.R.Mohanty, AdvocateFor Respondent: Shri M.K.Gautam, CITDR
Section 139(1)Section 271Section 271ASection 274

condone the delay of 525 days in filing all the present appeals before the Tribunal and admit all the appeals for adjudication. 4. The sole issue raised in all the appeals is against the levy of penalty u/s.271AAB of the Act by the AO and confirmed by the CIT(A). 5. The AO in case of all the assessees under

M/S. PRAKASH KUMAR ROUT,CUTTACK vs. ACIT, CENTRAL CIRCLE, CUTTACK

In the result, all the appeals of the all the assessees are allowed

ITA 311/CTK/2018[2014-15]Status: DisposedITAT Cuttack29 Oct 2021AY 2014-15
For Appellant: Shri P.R.Mohanty, AdvocateFor Respondent: Shri M.K.Gautam, CITDR
Section 139(1)Section 271Section 271ASection 274

condone the delay of 525 days in filing all the present appeals before the Tribunal and admit all the appeals for adjudication. 4. The sole issue raised in all the appeals is against the levy of penalty u/s.271AAB of the Act by the AO and confirmed by the CIT(A). 5. The AO in case of all the assessees under

M/S. PRAKASH KUMAR ROUT,CUTTACK vs. ACIT, CENTRAL CIRCLE, CUTTACK

In the result, all the appeals of the all the assessees are allowed

ITA 310/CTK/2018[2013-14]Status: DisposedITAT Cuttack29 Oct 2021AY 2013-14
For Appellant: Shri P.R.Mohanty, AdvocateFor Respondent: Shri M.K.Gautam, CITDR
Section 139(1)Section 271Section 271ASection 274

condone the delay of 525 days in filing all the present appeals before the Tribunal and admit all the appeals for adjudication. 4. The sole issue raised in all the appeals is against the levy of penalty u/s.271AAB of the Act by the AO and confirmed by the CIT(A). 5. The AO in case of all the assessees under

M/S. PRAGATI MILK PRODUCT PVT. LTD.,CUTTACK vs. ACIT, CENTRAL CIRCLE, CUTTACK

In the result, all the appeals of the all the assessees are allowed

ITA 312/CTK/2018[2014-15]Status: DisposedITAT Cuttack29 Oct 2021AY 2014-15
For Appellant: Shri P.R.Mohanty, AdvocateFor Respondent: Shri M.K.Gautam, CITDR
Section 139(1)Section 271Section 271ASection 274

condone the delay of 525 days in filing all the present appeals before the Tribunal and admit all the appeals for adjudication. 4. The sole issue raised in all the appeals is against the levy of penalty u/s.271AAB of the Act by the AO and confirmed by the CIT(A). 5. The AO in case of all the assessees under

M/S. PASUPATI BREEDING FARM PVT. LTD.,CUTTACK vs. ACIT, CENTRAL CIRCLE, CUTTACK

In the result, all the appeals of the all the assessees are allowed

ITA 313/CTK/2018[2014-15]Status: DisposedITAT Cuttack29 Oct 2021AY 2014-15
For Appellant: Shri P.R.Mohanty, AdvocateFor Respondent: Shri M.K.Gautam, CITDR
Section 139(1)Section 271Section 271ASection 274

condone the delay of 525 days in filing all the present appeals before the Tribunal and admit all the appeals for adjudication. 4. The sole issue raised in all the appeals is against the levy of penalty u/s.271AAB of the Act by the AO and confirmed by the CIT(A). 5. The AO in case of all the assessees under

ARYA AGRI & AQUA PRIVATE LIMITED,BHUBANESWAR vs. DCIT, CIRCLE 1(1), BHUBANESWAR, BHUBANESWAR

In the result, both appeals of the assesee are allowed

ITA 460/CTK/2024[2018-19]Status: DisposedITAT Cuttack23 Jan 2025AY 2018-19

Bench: Shri George Mathan & Shri Manish Agarwal

Section 68

condone the respective delay in filing both the appeals and appeals are heard finally. 3. First, we shall take up the appeal of the assesee in ITA No.461/CTK/2024 for A.Y.2016-2017, wherein the assesee has raised the following grounds :- 1. That the impugned Appellate Order by the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Income Tax Department, Govt

ARYA AGRI & AQUA PRIVATE LIMITED,BHUBANESWAR vs. DCIT, CIRCLE 1(1), BHUBANESWAR

In the result, both appeals of the assesee are allowed

ITA 461/CTK/2024[2016-17]Status: DisposedITAT Cuttack23 Jan 2025AY 2016-17

Bench: Shri George Mathan & Shri Manish Agarwal

Section 68

condone the respective delay in filing both the appeals and appeals are heard finally. 3. First, we shall take up the appeal of the assesee in ITA No.461/CTK/2024 for A.Y.2016-2017, wherein the assesee has raised the following grounds :- 1. That the impugned Appellate Order by the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Income Tax Department, Govt

ITO,WARD-1(1), CUTTACK vs. THE CUTTACK CREDIT CO-OP. SOCEITY LTD, CUTTACK

In the result, appeal of the revenue is dismissed

ITA 27/CTK/2021[2015-16]Status: DisposedITAT Cuttack09 Mar 2022AY 2015-16
For Appellant: Shri N.R.BiswalFor Respondent: Shri Sovesh Chandra Mohnanty, Sr
Section 80P(2)(a)

delay of 111 days in filing the appeal by the revenue is condoned and the appeal is admitted for adjudication. 4. The revenue is aggrieved by the order of the ld CIT(A) in deleting addition of Rs.1,58,80,813/- from interest on fixed deposits made in the co-operative banks u/s. 80P(2)(a)(i)/80P

BHAVENDRA HASMUKHLAL PATADIA. LEGAL HEIR OF HASMUKHLAL PATADIA.,CUTTACK vs. ITO WARD-!(1), CUTTACK

In the result, appeal of the assessee is allowed

ITA 125/CTK/2022[2015-16]Status: DisposedITAT Cuttack26 Dec 2022AY 2015-16

Bench: Shri George Mathan & Shri Arun Khodpiaआयकर अऩीऱ सं/Ita No.125/Ctk/2022 (ननधाारण वषा / Assessment Year :2015-2016) Bhavendra Hasmukhlal Patadia, Vs Ito, Ward-1(1), Cuttack Legal Heir Of Hasmukhlal Patadia, Nayabazar, Chauliaganj, Cuttack-753004 Pan No. :Adapp 6256 G (अऩीऱाथी /Appellant) .. (प्रत्यथी / Respondent) ननधााररती की ओर से /Assessee By : Shri Deepak Shah, Ar राजस्व की ओर से /Revenue By : Shri M.K.Gautam, Cit-Dr सुनवाई की तारीख / Date Of Hearing : 26/12/2022 घोषणा की तारीख/Date Of Pronouncement : 26/12/2022 आदेश / O R D E R Per Bench : This Is An Appeal Filed By The Assessee Against The Order Of The Ld Pr.Cit, Cuttack, Passed In Itba/Com/F/17/2019-20/1026790827(1), Dated 19.03.2020, For The Assessment Year 2015-2016. Head On The Question Of Condonation Of Delay 2. On Perusal Of The Appeal Record, It Is Found That The Appeal Of The Assessee Is Barred By 784 Days. In This Regard, The Assessee Has Filed An Application For Condonation Of Delay Dated 11.07.2022 Along With Affidavit Stating Therein That Due To Continuous Lockdown On Account Of Spread Of Covid-19, The Assessee Could Not File The Present Appeal In Time, Therefore, He Prayed That Delay Of 784 Days In Filing The Present Appeal May Kindly Be Condoned. On The Other Hand, Ld. Cit-Dr Did Not Object To The Above Submission Of The Ld. Ar. Considering The Above, We Condone

For Appellant: Shri Deepak Shah, ARFor Respondent: Shri M.K.Gautam, CIT-DR
Section 143(3)Section 263

condone 2 the delay of 784 days in filing the present appeal by the assessee and appeal is heard finally. 3. It was submitted by the ld. AR that the assessee is an individual, who derives income from letting out of house property and income from share transaction. The assessee had filed its return of income

SHRI PADMA LOCHAN PANDA,BHUBANESWAR vs. ITO,WARD-1(2),, BHUBANESWAR

In the result, appeal of the assessee is partly allowed

ITA 113/CTK/2019[1999-2000]Status: DisposedITAT Cuttack19 May 2021AY 1999-2000

Bench: Shri Shrichandra Mohan Garg, Judicialassessment Year : 1999-2000 Sri Padma Lochan Panda, C Lochan Panda, C- Vs. Ito, Ward-1(2), 77/3, Palaspali, Bhubaneswar. 77/3, Palaspali, Bhubaneswar. Bhubaneswar. Pan/Gir No.Agkpp 4821 C Agkpp 4821 C (Appellant) (Appellant .. ( Respondent Respondent) Assessee By : Shri P.K.Mishra, Ar Revenue By : Shri S.C.Mohanty, Dr : Shri S.C.Mohanty, Dr Date Of Hearing : 01/4/ 2021 Date Of Pronouncement : 11/5/20 /2021 O R D E R

For Appellant: Shri P.K.Mishra, ARFor Respondent: Shri S.C.Mohanty, DR

condone the delay of 5207 days in filing the appeal and admit for adjudication. Ground Nos.1 to 4 of appeal 6. Facts of the case are that the assessee filed his return of income declaring total income of Rs.62,820.00 and agricultural income at Rs.1,00,000.00. The return was processed U/s.143(1)(a) of the I.T Act, 1961. Thereafter

BARUAN SERVICE CO OPERATIVE SOCIETY LIMITED,JAJPUR vs. INCOME TAX OFFICER, JAJPUR WARD, JAJPUR, JAJPUR

In the result, appeal of the assessee stands allowed for statistical\npurposes

ITA 277/CTK/2025[2019-20]Status: DisposedITAT Cuttack02 Jul 2025AY 2019-20
For Appellant: Shri N.R.Biswal, CAFor Respondent: Shri Ashim Kr Chakraborty, CIT DR
Section 142(1)Section 147Section 148Section 250Section 69A

condone the delay of 1 days and admit the\nappeal for hearing.\n3. Brief facts of the case are that the assessee is an AOP filed his return\nof income for A.Y. 2019-20. The case was reopened u/s.147 of the Act and\nnotice u/s.148 of the Act was issued to the assessee requiring to file the\nreturn of income

DCIT,CORPORATE CIRCLE-1(1), BHUBANESWAR vs. M/S. RADHIKAPUR (WEST) COAL MINING (P) LIMITED, BHUBANESWAR

In the result, both appeals of the Revenue are dismissed

ITA 12/CTK/2021[2015-16]Status: DisposedITAT Cuttack08 Mar 2022AY 2015-16
For Appellant: Shri S.C.BhadraFor Respondent: Shri Manoj Kumar Goutam
Section 56

delay of 417 days in filing the appeal by the revenue is condoned and the appeal is admitted for adjudication. 4. The revenue is aggrieved by the deletion of addition made by the AO amounting to Rs.1,69,25,714/- representing interest on fixed deposits. 5. Facts of the case are that the assessee is a joint venture (JV) company