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33 results for “disallowance”+ Section 256(1)clear

Sorted by relevance

Mumbai315Delhi225Jaipur103Chennai94Ahmedabad82Bangalore80Cochin71Kolkata57SC39Raipur34Surat33Hyderabad33Nagpur30Chandigarh30Indore24Visakhapatnam23Pune22Lucknow20Guwahati11Rajkot10Allahabad6Patna6Agra5Jodhpur3Jabalpur3Cuttack3A.K. SIKRI ROHINTON FALI NARIMAN2Ranchi1RANJAN GOGOI PRAFULLA C. PANT1Amritsar1Panaji1

Key Topics

Section 143(3)28Addition to Income24Section 26316Section 14A15Section 13211Section 54F11Section 13910Section 132(4)10Section 14710Search & Seizure

ACIT., CIRCLE-5(1), HYDERABAD vs. PENNA CEMENT INDUSTRIES LIMITED, HYDERABAD

ITA 1084/HYD/2024[2018-19]Status: DisposedITAT Hyderabad21 Jan 2026AY 2018-19
For Appellant: Shri Sourabh Soparkar, Advocate Represented by Department : Dr. Narendra Kumar NFor Respondent: Dr. Narendra Kumar Naik, CIT-DR Date of Conclusion of Hearing : 11/11/2025
Section 143(3)Section 144BSection 14ASection 68Section 80Section 801ASection 80GSection 92C

disallowance of the claim of deduction of the assessee company under Section 801A of the Act: Rs. 24,35,05,411/-; and (iv) addition under section 68 in respect of alleged bogus transactions with M/s. Lakshin Infradev Pvt. Ltd: Rs. 1,29,91,000/-, determined he income of the assessee company vide his order passed under section 143(3) r.w.s

Showing 1–20 of 33 · Page 1 of 2

10
Deduction10
Disallowance9

ACIT., CIRCLE-5(1), HYDERABAD vs. PENNA CEMENT INDUSTRIES LIMITED, HYDERABAD

ITA 1083/HYD/2024[2017-18]Status: DisposedITAT Hyderabad21 Jan 2026AY 2017-18
Section 143(3)Section 144BSection 14ASection 68Section 80Section 801ASection 80GSection 92C

1,88,97,644/-; (iii) disallowance of\nthe claim of deduction of the assessee company under Section 801A of\nthe Act: Rs. 24,35,05,411/-; and (iv) addition under section 68 in respect\nof alleged bogus transactions with M/s. Lakshin Infradev Pvt. Ltd: Rs.\n1,29,91,000/-, determined he income of the assessee company vide his\norder passed

VIJAYAWADA TOLLWAY PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE-8(1), HYDERABAD

In the result, the appeal filed by the assessee is\nOrder pronounced in the Open Court on 6th February, 2026

ITA 1468/HYD/2025[2012-13]Status: DisposedITAT Hyderabad06 Feb 2026AY 2012-13
For Appellant: Shri A.V. Raghuram, Advocate
Section 143(3)Section 147Section 271(1)(c)

disallowance of\nexpenditure resulted in enhancement of income and therefore, the\nLd. AO was justified in initiating and levying penalty under section\n271(1)(c) of the Act.\n7.\nWe have carefully considered the rival submissions\nand perused the material available on record. We have also gone\nthrough page no. 8 of the reassessment order dated 05.12.2019\npassed

ACIT, CENTRAL CIRCLE-3(1), HYDERABAD vs. SRI CHAITANYA EDUCATIONAL COMMITTE, VIJAYAWADA

In the result, the appeal filed by the Revenue is dismissed

ITA 325/HYD/2023[2012-13]Status: DisposedITAT Hyderabad06 May 2025AY 2012-13

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Appellant: Shri AV Raghuram, AdvocateFor Respondent: MS. M. Narmada, CIT-DR
Section 11Section 12Section 12ASection 13(1)(c)Section 13(3)

section 13(1)(c) r.w.s.13(2)(c) of the Act. Further, the Assessing Officer after considering relevant provisions of the Act and also applying provisions of sec.40A(2)(a) observed that, appellant society has made excessive and unreasonable payment to the above two companies for rendering services which cannot be allowed as deduction. Thus, the Assessing Officer disallowed

VIRCHOW PETROCHEMICAL PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-8(1), HYDERABAD

ITA 1191/HYD/2025[2015-16]Status: DisposedITAT Hyderabad26 Feb 2026AY 2015-16
For Appellant: \nShri M.V. Prasad, CAFor Respondent: \nMs. U. Mini Chandran
Section 143(3)Section 147Section 148Section 250

disallow the entire\nclaim of depreciation of Rs.7.34 crores (supra). The Ld. AR submitted\nthat the enhancement directed by the CIT(A) in absence of any notice of\nenhancement issued to the assessee company/appellant cannot be\nsustained and is liable to be vacated.\n19. The Ld. AR submitted that as the assessee company had in its\nreturn of income

ASST. COMMISSIONER OF INCOME TAX, CIRCLE-10(1), HYDERABAD vs. VERTEX PROJECTS LLP (FORMERLY M/S VERTEX PROJECTS LTD) , HYDERABAD

In the result, the appeal of Revenue is partly allowed for statistical purposes

ITA 1187/HYD/2018[2014-15]Status: DisposedITAT Hyderabad28 Apr 2023AY 2014-15

Bench: Shri Rama Kanta Panda & Shri Laliet Kumarassessment Year: 2014-15 Acit,Circle-10(1) Vs. Vertex Projects Llp Room No.515, 5Th Floor, (Formerly M/S.Vertex A-Block, I.T.Towers, Projects Ltd.) A.C.Guards, #156-159, Paigah House Hyderabad. S.P.Road, Next To Pg College. Secunderabad-500 026. Pan : Aanfv0232C (Appellant) (Respondent) Assessee By: Shri Sriram Seshadri, Ca Revenue By: Shri Rajendra Kumar,Cit-Dr Date Of Hearing: 15.03.2023 Date Of Pronouncement: 28.04.2023 O R D E R Per Shri Laliet Kumar, J.M. This Is An Appeal Filed By The Revenue, Feeling Aggrieved By The Order Passed By The Learned Commissioner Of Income Tax (Appeals)-5, Dated 16.03.2018 For The Ay 2014-15, On The Following Grounds :

For Appellant: Shri Sriram Seshadri, CAFor Respondent: Shri Rajendra Kumar,CIT-DR
Section 115JSection 142(1)Section 143(2)Section 14ASection 14A(3)Section 47Section 56Section 56(2)(viia)Section 56(2)(viiia)

disallowance computed under section 14A of the Act pertains to computation of income under the normal provisions of the Act and cannot be read into the provisions of section 115JB of the Act pertaining to levy of minimum alternate tax and there is no express provision in clause (f) of Explanation 1 to section 115JB of the Act to that

DCIT., (INTERNATIONAL TAXATION)-1, HYDERABAD vs. SYAMA REDDY MALI REDDY, HYDERABAD

ITA 366/HYD/2025[2019-20]Status: DisposedITAT Hyderabad03 Sept 2025AY 2019-20
Section 143(2)Section 143(3)Section 144C(3)Section 54Section 54F

disallowed the claim of the assessee to\nthe extent of Rs.7,50,000/- as cost incurred for transfer.\n.xxxx.\n6. This brings us to the other question whether the assessee had\n\"purchased\" the second property and, therefore, payment made of\nRs.37,86,273/- was entitled to exemption under Section 54 of the\nAct. Section

SLR INFRASTRUCTURE PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE-3(1), HYDERABAD

In the result, the appeal filed by the assessee is allowed

ITA 544/HYD/2024[2018-19]Status: DisposedITAT Hyderabad17 Oct 2025AY 2018-19
Section 142(1)Section 143Section 143(3)Section 194CSection 263

disallowance u/s 36(1)(iii) of the Act, because, one of the objects of the assessee company is to make investment in subsidiary companies. In our considered view, on this aspect also assumption of jurisdiction by the PCIT fails.\n\n12. It is a well settled principle of law by various decisions of courts including the decision

SHARE MICROFIN LIMITED ,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-3(1), HYERABAD

In the result, appeal filed by the assessee is dismissed

ITA 430/HYD/2020[2016-17]Status: DisposedITAT Hyderabad12 Jun 2023AY 2016-17

Bench: Shri R.K. Panda & Shri K. Narasimha Charyassessment Year: 2016-17 Share Microfin Ltd Vs. Dy. C. I. T. Hyderabad Circle 3(1) Pan:Aaecs9243C Hyderabad (Appellant) (Respondent) Assessee By: Shri A.G. Sitaraman, Ca Revenue By: Shri Jeevan Lal Lavidiya, Dr Date Of Hearing: 17/04/2023 Date Of Pronouncement: 12/06/2023 Order Per R.K. Panda, A.M This Appeal Filed By The Assessee Is Directed Against The Order Dated 23003.2020 Of The Learned Cit (A)-3, Hyderabad Relating To A.Y.2016-17. 2. There Is A Delay Of 5 Days In Filing Of This Appeal By The Assessee For Which The Assessee Has Filed A Condonation Application Along With An Affidavit Explaining The Reasons For Such Delay. The Reasons Given Therein Is Due To The Prevailing Covid 2019 Pandemic. After Considering The Contents Of The Condonation Application Explaining The Reasons Filed Along With The Affidavit, The Delay In Filing Of The Appeal By The Assessee Is Condoned & The Appeal Is Admitted For Adjudication.

For Appellant: Shri A.G. Sitaraman, CAFor Respondent: Shri Jeevan Lal Lavidiya, DR
Section 143(2)Section 28Section 41(1)

disallowance made by the Assessing Officer. He submitted that as per the One Time Settlement (OTS) claim dated 25.11.2015, the assessee paid an amount of Rs.4.20 crores to Blue Orchid Finance (BOF) out of the total amount of Rs.24.23 crores which consisted of principal outstanding of Rs.19.09 crores and interest of 5.14 crores. He submitted that the assessee

SHRI RAMPRIYA DEVELOPERS PRIVATE LIMITED,HYDERABAD vs. DEPUTY COMMISSIONER OF INCOMETAX, CIRCLE-3(1), HYDERABAD

In the result, appeal filed by the assessee is dismissed

ITA 1946/HYD/2017[1999-2000]Status: DisposedITAT Hyderabad14 Aug 2024AY 1999-2000

Bench: Shri Laliet Kumar & Shri Manjunatha, G.आ.अपी.सं /Ita No.1946/Hyd/2017 (िनधा"रण वष"/Assessment Year: 1999-2000) Shri Rampriya Developers Vs. Dy. C. I. T. (P) Ltd Circle 3(1) Hyderabad Hyderabad Pan:Aajcs6629P (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri A.V. Raghuram, Advocate राज" व "ारा/Revenue By:: Shri Shakeer Ahmed, Dr सुनवाई की तारीख/Date Of Hearing: 09/07/2024 घोषणा की तारीख/Pronouncement: 14/08/2024 आदेश/Order

For Appellant: Shri A.V. Raghuram, AdvocateFor Respondent: : Shri Shakeer Ahmed, DR
Section 143(3)Section 14A

1) of the Act and the High Court was justified in not calling for a statement of case under sub- section (2) of section 256.” In Bengal Enamel. Works Ltd. v. CIT/1970) 77 ITR 119, the .Supreme ,Court considered remuneration paid by the assessee to a technical adviser and taking into consideration that the taxing authorities had uniformly found that

SKANDA BUILDERS,KURNOOL vs. ACIT., CENTRAL CIRCLE-2(3), HYDERABAD

ITA 530/HYD/2025[2019-20]Status: DisposedITAT Hyderabad20 Aug 2025AY 2019-20

256,628 | 620,000 | 8,247,500 | | | | 25,501,428 |\n| 29th | 5,429,845 | 230,000 | 6,408,269 | 400,599 | 1,000,000 | 3,905,000 | | | 17,403,713 |\n| 30th | 1,345,000 | 25,000 | 1,070,000 | 20,000 | 2,105,000 | | | | 4,560,000 |\n| 31st

ECI ENGINEERING & CONSTRUCTION COMPANY LTD., HYD,HYDERABAD vs. ACIT, CIRCLE-2(2), HYD, HYDERABAD

In the result, the appeal of the assessee is allowed

ITA 968/HYD/2016[2006-07]Status: DisposedITAT Hyderabad15 May 2023AY 2006-07

Bench: Shri R.K. Panda & Shri Laliet Kumarassessment Year: 2006-07 The Asst. Commissioner Of Vs. M/S. Eci Engineering & Income Tax, Construction Co., Ltd., Circle 17(1), Hyderabad. Hyderabad. Pan : Aaace74411G (Appellant) (Respondent) Ita 968/Hyd/2016 Assessment Year 2006-07 M/S. Eci Engineering & Vs. The Asst. Commissioner Of Construction Co., Ltd., Income Tax, Hyderabad. Circle 2(2), Hyderabad. Pan : Aaace74411G (Appellant) (Respondent) Assessee By: Shri K.C. Devdas Revenue By: Shri K.P.R.R. Murthy. Date Of Hearing: 27.03.2023 Date Of Pronouncement: 15.05.2023 O R D E R Per Laliet Kumar, J.M. These Two Appeals Filed By The Assessee & The Revenue, Respectively, Are Directed Against The Order Of Commissioner Of Income Tax (Appeals) – 5, Hyderabad Dated 30.03.2016 For The Assessment Year 2006-07. 2. The Abridged Grounds Raised By The Assessee In Ita No.968/Hyd/2016 Read As Under : “1. The Order Of Ld.Cit(A) - 5 Is Erroneous In Law In Facts & In Law. 2. The Ld.Cit(A) Erred In Upholding The Decision Of The Ld.Ao In Treating Sale Of Partly Paid Up Shares As Fully Paid & Confirming The Addition Of Rs.50,14,625/- As Long Term Capital Gain. 3. The Ld.Cit(A) Erred In Confirming The Addition Of Rs.27,69,422/- Towards Difference In Interest. 4. Further, The Ld.Cit(A) Failed To Observe That The Notes To Financial Statements Clearly Mentioned The Interest Income Which Pertained To The Previous Year & Accordingly Erred In Upholding The Action Of The Ld.Ao In Assessing The Difference In Interest Of Rs.27,69,422/-. 5. The Ld.Cit(A) Erred In Confirming The Addition Of Difference Of Prior Period Income Of Rs.1,26,71,371/-.”

For Appellant: Shri K.C. DevdasFor Respondent: Shri K.P.R.R. Murthy
Section 143(1)Section 143(3)Section 148Section 40

256 ITR 1) (Del.HC) ii. CIT v. Kelvinator of India Ltd (320 . ITR 561) (SC) iii. ACIT vs. ICICI Securities Primary . Dealership Ltd. (348 ITR 299) (SC) iv. Ganga Saran & Sons (P.) Ltd. v. ITO 1 [(1981) 130 ITR 1] (SC) v. Kohinoor Hatcheries (P.) 1 Ltd. v. Deputy Commissioner of Income-tax [2016] 76 taxmann.com 150 (AP.HC

DCIT, CIRCLE-17(1), HYD, HYDERABAD vs. ECI ENGINEERING & CONSTRUCTION CO. LTD., HYD, HYDERABAD

In the result, the appeal of the assessee is allowed

ITA 930/HYD/2016[2006-07]Status: DisposedITAT Hyderabad15 May 2023AY 2006-07

Bench: Shri R.K. Panda & Shri Laliet Kumarassessment Year: 2006-07 The Asst. Commissioner Of Vs. M/S. Eci Engineering & Income Tax, Construction Co., Ltd., Circle 17(1), Hyderabad. Hyderabad. Pan : Aaace74411G (Appellant) (Respondent) Ita 968/Hyd/2016 Assessment Year 2006-07 M/S. Eci Engineering & Vs. The Asst. Commissioner Of Construction Co., Ltd., Income Tax, Hyderabad. Circle 2(2), Hyderabad. Pan : Aaace74411G (Appellant) (Respondent) Assessee By: Shri K.C. Devdas Revenue By: Shri K.P.R.R. Murthy. Date Of Hearing: 27.03.2023 Date Of Pronouncement: 15.05.2023 O R D E R Per Laliet Kumar, J.M. These Two Appeals Filed By The Assessee & The Revenue, Respectively, Are Directed Against The Order Of Commissioner Of Income Tax (Appeals) – 5, Hyderabad Dated 30.03.2016 For The Assessment Year 2006-07. 2. The Abridged Grounds Raised By The Assessee In Ita No.968/Hyd/2016 Read As Under : “1. The Order Of Ld.Cit(A) - 5 Is Erroneous In Law In Facts & In Law. 2. The Ld.Cit(A) Erred In Upholding The Decision Of The Ld.Ao In Treating Sale Of Partly Paid Up Shares As Fully Paid & Confirming The Addition Of Rs.50,14,625/- As Long Term Capital Gain. 3. The Ld.Cit(A) Erred In Confirming The Addition Of Rs.27,69,422/- Towards Difference In Interest. 4. Further, The Ld.Cit(A) Failed To Observe That The Notes To Financial Statements Clearly Mentioned The Interest Income Which Pertained To The Previous Year & Accordingly Erred In Upholding The Action Of The Ld.Ao In Assessing The Difference In Interest Of Rs.27,69,422/-. 5. The Ld.Cit(A) Erred In Confirming The Addition Of Difference Of Prior Period Income Of Rs.1,26,71,371/-.”

For Appellant: Shri K.C. DevdasFor Respondent: Shri K.P.R.R. Murthy
Section 143(1)Section 143(3)Section 148Section 40

256 ITR 1) (Del.HC) ii. CIT v. Kelvinator of India Ltd (320 . ITR 561) (SC) iii. ACIT vs. ICICI Securities Primary . Dealership Ltd. (348 ITR 299) (SC) iv. Ganga Saran & Sons (P.) Ltd. v. ITO 1 [(1981) 130 ITR 1] (SC) v. Kohinoor Hatcheries (P.) 1 Ltd. v. Deputy Commissioner of Income-tax [2016] 76 taxmann.com 150 (AP.HC

SRK CONSTRUCTIONS AND PROJECTS PRIVATE LIMITED,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-3(2), HYDERABAD

ITA 389/HYD/2020[2017-18]Status: DisposedITAT Hyderabad24 Apr 2025AY 2017-18
For Appellant: Shri Mohd. Afzal, AdvocateFor Respondent: Shri LV Bhaskara Reddy, CIT-DR
Section 139(1)Section 143(3)Section 263

1, 3, 5 and 6\nof table provided by the Assessing Officer in page-2 of his\norder. However, denied deduction in respect of Sl.Nos.2 and\n\n21\nITA.No.359/Hyd./2022, ITA.No.1415/Hyd./2019\nAnd ITA.No.389/Hyd./2020\n\n4 of the table provided at page-2 of the assessment order\nand made addition of Rs.4

SRK CONSTRUCTIONS AND PROJECTS PRIVATE LIMITED,,HYDERABAD vs. DCIT, CIRCLE-3(1),, HYDERABAD

In the result, ITA.No.389/Hyd

ITA 359/HYD/2022[2016-17]Status: DisposedITAT Hyderabad24 Apr 2025AY 2016-17

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Appellant: Shri Mohd. Afzal, AdvocateFor Respondent: Shri LV Bhaskara Reddy, CIT-DR
Section 139(1)Section 143(3)Section 263

1, 3, 5 and 6 of table provided by the Assessing Officer in page-2 of his order. However, denied deduction in respect of Sl.Nos. 2 and 22 ITA.No.359/Hyd./2022, ITA.No.1415/Hyd./2019 And ITA.No.389/Hyd./2020 4 of the table provided at page-2 of the assessment order and made addition of Rs.4,09,53,977/-. 15. Being

DY. COMMISSIONER OF INCOME TAX , CIRCLE-3(2), HYDERABAD vs. SRK CONSTRUCTION PROJECTS PRIVATE LIMITED, HYDERABAD

In the result, ITA.No.389/Hyd

ITA 1415/HYD/2019[2016-17]Status: DisposedITAT Hyderabad24 Apr 2025AY 2016-17

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Appellant: Shri Mohd. Afzal, AdvocateFor Respondent: Shri LV Bhaskara Reddy, CIT-DR
Section 139(1)Section 143(3)Section 263

1, 3, 5 and 6 of table provided by the Assessing Officer in page-2 of his order. However, denied deduction in respect of Sl.Nos. 2 and 22 ITA.No.359/Hyd./2022, ITA.No.1415/Hyd./2019 And ITA.No.389/Hyd./2020 4 of the table provided at page-2 of the assessment order and made addition of Rs.4,09,53,977/-. 15. Being

MRL TRADING COMPANY,HYDERABAD vs. ITO., WARD-7(1), HYDERABAD

In the result, appeal of the Assessee is allowed

ITA 29/HYD/2025[2017-18]Status: DisposedITAT Hyderabad07 Jan 2026AY 2017-18
For Appellant: \nCA A SrinivasFor Respondent: \nMS Kritika Jaiswal, Sr. AR
Section 143(3)Section 69A

1), Hyderabad.\nPIN - 500 084.\nTelangana.\n(Respondent)\nनिर्धारिती द्वारा / Assessee by:\nCA A Srinivas\nराजस्व द्वारा / Revenue by:\nMS Kritika Jaiswal, Sr. AR\nसुनवाई की तारीख/Date of hearing:\n16.12.2025\nघोषणा की तारीख / Pronouncement:\n07.01.2026\nआदेश/ORDER\nPER VIJAY PAL RAO, VICE PRESIDENT :\nThis appeal by the Assessee is directed against the\nOrder dated 01.01.2025 of the learned

KRISHNA KISHORE REDDY MANYAM ,HYDERABAD vs. INCOME TAX OFFICER, WARD-6(4) , HYDERABAD

In the result, the appeal filed by the assessee is partly allowed\nfor statistical purposes in terms of our aforesaid observations

ITA 58/HYD/2020[2008-09]Status: DisposedITAT Hyderabad02 Jun 2025AY 2008-09
Section 143(2)Section 143(3)Section 2(14)Section 548Section 54BSection 54F

disallowed the same.\n5. Ostensibly, the assessee during the course of the assessment\nproceedings came up with a new claim, wherein based on a revised\nstatement of computation of income that was filed with the A.O.\non 29.08.2010, it was claimed by him that as the agricultural land\nsituated at Village: Manchirevula was not a “capital asset” within\nthe meaning

IMAGE BROADCASTING INDIA PRIVATE LIMITED,HYDERABAD vs. DEPUTY COMMISSIONER OF INCOME TAX 14(1), HYDERABAD

ITA 582/HYD/2023[2017-18]Status: DisposedITAT Hyderabad14 May 2025AY 2017-18
For Appellant: Shri Ravi Bhardwaj, ARFor Respondent: Ms. Reema Yadav, DR
Section 143(2)Section 143(3)Section 37Section 68

256 ITR 701\nand held that the appellant had not discharged the onus to prove\nthe genuineness of the expenses claimed that the said expenses\nwere incurred wholly and exclusively for the purposes of\nbusiness of the appellant. Accordingly, 10% of such expenses\nclaimed were disallowed. During the appellate proceedings, no\nfurther details were furnished in support of the claim

BHARGAVI MARKETERS,HYDERABAD vs. ITO., WARD 6(1), HYDERABAD

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

ITA 732/HYD/2024[2016-17]Status: DisposedITAT Hyderabad05 Dec 2024AY 2016-17

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdiaassessment Year: 2016-17 Bhargavi Marketers, Vs. The Income Tax Officer, Ward – 6(1), Hyderabad. Hyderabad. Pan : Aapfb3209D (Appellant) (Respondent) Assessee By: Shri V. Venkata Rao, C.A. Revenue By: Ms. Kavitha Rani, Sr.A.R. Date Of Hearing: 04.12.2024 Date Of Pronouncement: 05.12.2024

For Appellant: Shri V. Venkata Rao, C.AFor Respondent: Ms. Kavitha Rani, Sr.A.R
Section 143(3)Section 147Section 148Section 194CSection 270ASection 40Section 40a

256 ITR 1(Del)(FB) approved by the supreme court in (2010) 320 ITR 561 (SC) which has been held to be against the provisions of law by various appellate authorities and hence the order of the ld CIT(A) required to be quashed.” 3. The brief facts of the case are that assessee, a firm e-filed its return