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21 results for “section 68”+ Section 142(1)clear

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Key Topics

Addition to Income19Section 143(3)12Section 14812Section 6810Section 143(2)10Section 80P10Section 142(1)9Section 1449Cash Deposit9Section 263

AMIT KUMAR YADAV,SEONI vs. INCOME TAX OFFICER, SEONI

In the result, the assessee’s appeal in ITA No

ITA 168/JAB/2024[2018-19]Status: DisposedITAT Jabalpur28 Aug 2025AY 2018-19

Bench: SH. KUL BHARAT, VICE PRESIDENT AND SH. NIKHIL CHOUDHARY (Accountant Member)

For Appellant: Sh. G.N. Purohit, Sr. AdvocateFor Respondent: Sh. Alok Bhura, Sr. DR
Section 144Section 250Section 271ASection 272A(1)(d)

68 of the Income Tax Act and brought the same to the tax, as per the provisions of section 115BBE. He also initiated penalty proceedings under section 271AAC(1) and 272A(1)(d) of the Act. Thereafter, the ld. AO issued penalty notices under section 274 r.w.s 271 AAC(1) asking the assessee why an order imposing

Showing 1–20 of 21 · Page 1 of 2

8
Disallowance7
Penalty6

AMIT KUMAR YADAV,SEONI vs. INCOME TAX OFFICER, SEONI

In the result, the assessee’s appeal in ITA No

ITA 166/JAB/2024[2018-19]Status: DisposedITAT Jabalpur28 Aug 2025AY 2018-19

Bench: SH. KUL BHARAT, VICE PRESIDENT AND SH. NIKHIL CHOUDHARY (Accountant Member)

For Appellant: Sh. G.N. Purohit, Sr. AdvocateFor Respondent: Sh. Alok Bhura, Sr. DR
Section 144Section 250Section 271ASection 272A(1)(d)

68 of the Income Tax Act and brought the same to the tax, as per the provisions of section 115BBE. He also initiated penalty proceedings under section 271AAC(1) and 272A(1)(d) of the Act. Thereafter, the ld. AO issued penalty notices under section 274 r.w.s 271 AAC(1) asking the assessee why an order imposing

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 2(1), JABALPUR vs. MADHYA PRADESH POWER GENERATING CO. LTD., JABALPUR

In the result, the Revenue's appeal is dismissed as not maintainable

ITA 251/JAB/2018[2008-09]Status: DisposedITAT Jabalpur23 Feb 2022AY 2008-09

Bench: Shri Sanjay Arora, Hon’Ble & Shri Manomohan Das, Hon'Ble

For Appellant: Shri Rahul Bardia, CAFor Respondent: Shri S.K. Halder, DR
Section 115Section 143(3)Section 147Section 154Section 271(1)(c)

68,638 vide order u/s. 147 r/w s. 143(3) dated 21.3.2016. The same was further modified u/s.154 (on 11.01.2017) to bring on record the income under Minimum Alternate Tax (MAT) regime at Rs. 817.29 lacs, which income had remained unchanged. The said reassessment and modification were not challenged in appeal', attaining finality. 2.2 In the penalty proceedings, initiated

BRAHTAKAR KRISHI SAKH SAHAKARI SAMITI MARYADIT,SAHAJPUR vs. INCOME TAX OFFICER WARD 1(2), JABALPUR

In the result, all the three appeals in ITA Nos

ITA 151/JAB/2025[2015-16]Status: DisposedITAT Jabalpur28 Aug 2025AY 2015-16

Bench: SH. KUL BHARAT, VICE PRESIDENT AND SH. NIKHIL CHOUDHARY (Accountant Member)

For Appellant: Sh. Sapan Usrethe, Advocate & ShFor Respondent: Sh. Alok Bhura, Sr. DR
Section 143(2)Section 147Section 148Section 250Section 80P

68,71,956 without appreciating that appellant is maintaining proper books of accounts and even otherwise appellant is entitled for deduction under section 80P of the act. 4. The learned Commissioner of Income tax (Appeal) NFAC was not justified in confirming the action of AO with regard to the deduction of Rs.6,35,489 claimed by the appellant under

BRAHTAKAR KRISHI SAKH SAHAKARI SAMITI MARYADIT,SAHAJPUR vs. INCOME TAX OFFICER WARD 1(2), JABALPUR

In the result, all the three appeals in ITA Nos

ITA 149/JAB/2025[2013-14]Status: DisposedITAT Jabalpur28 Aug 2025AY 2013-14

Bench: SH. KUL BHARAT, VICE PRESIDENT AND SH. NIKHIL CHOUDHARY (Accountant Member)

For Appellant: Sh. Sapan Usrethe, Advocate & ShFor Respondent: Sh. Alok Bhura, Sr. DR
Section 143(2)Section 147Section 148Section 250Section 80P

68,71,956 without appreciating that appellant is maintaining proper books of accounts and even otherwise appellant is entitled for deduction under section 80P of the act. 4. The learned Commissioner of Income tax (Appeal) NFAC was not justified in confirming the action of AO with regard to the deduction of Rs.6,35,489 claimed by the appellant under

NAGAR PANCHAYAT,BANDA vs. THE ASSISSTANT COMMISSIONER OF INCOME TAX CIRCLE SAGAR, SAGAR

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

ITA 118/JAB/2024[2012-13]Status: DisposedITAT Jabalpur30 May 2025AY 2012-13

Bench: Sh. Kul Bharat & Sh. Nikhil Choudharya.Y. 2012-13 Nagar Panchayat, Banda, Vs. The Acit, Nagar Parishad Building, Banda, Sagar, Circle Sagar, Sagar Banda Nagar S.O. Madhya Pradesh Pan:Aaaln0246R (Appellant) (Respondent) Assessee By: Sh. Milind Wadhwani, C.A. Revenue By: Sh. Alok Bhura, Sr. Dr Date Of Hearing: 19.05.2025 Date Of Pronouncement: 30.05.2025 O R D E R Per Nikhil Choudhary, A.M. This Is An Appeal Filed By The Assessee Against The Order Of The Ld. Cit(A), Nfac Dated 7.05.2024 Whereby The Ld. Cit(A) Has Dismissed The Appeal Of The Assessee Against The Orders Of The Dcit, Circle-Sagar, Madhya Pradesh Passed On 10.12.2019 Under Section 147 R.W.S. 144 Of The Income Tax Act, 1961. The Grounds Of Appeal Are As Under:- “1. On The Facts & Circumstances Of The Case & In Law, The Ld. National Faceless Appeal Centre ('Nfac) Erred In Upholding The Action Of The Ld. Assistant Commissioner Of Income Tax Circle-Sagar ('Ao) In Adding A Sum Of Rs. 68,21,182/- To The Income Of The Assessee U/S. 69A As Unexplained Money. 2. On The Facts & Circumstances Of The Case & In Law, The Assessment Order Dated 10.12.2019 Is Without Jurisdiction, Bad In Law & Liable To Be Quashed.3 3. On The Facts & Circumstances Of The Case & In Law, The Assessment Order Is Opposed To The Principles Of Equity, Natural Justice & Fair Play.

For Appellant: Sh. Milind Wadhwani, C.AFor Respondent: Sh. Alok Bhura, Sr. DR
Section 115BSection 133(6)Section 142(1)Section 147Section 148Section 271(1)(b)Section 69A

1 (SC) and A. Govindarajulu Mudaliar vs. CIT (1958) 34 ITR 807 (SC). The ld. CIT(A), NFAC held that the provisions of section 69A were similar to that of section 68 and therefore, after placing reliance on various decisions that were quoted by him in his assessment order to the effect that the onus was upon

SANJAY RATHI,CHHINDWARA vs. INCOME TAX OFFICER WARD-1, CHHINDWARA

In the result, appeal of the assessee is partly allowed

ITA 212/JAB/2015[2010-11]Status: DisposedITAT Jabalpur14 Mar 2018AY 2010-11

Bench: Shri Kul Bharat & Shri Manish Borad""./ Ita No. 212/Jab/2015 "" " " " " " "  / Assessment Year : 2010-11   Sanjay Rathi, Income Tax Officer, Prop. Of M/S. Rathi Industries, Vs Chindwara-1, Sausar, Chhindwara (Mp) Chindwara (Mp) Pan : Acppr 7820 Q / (Appellant) / (Respondent)         Assessee By : Shri G.N. Purohit, Sr. Adv. Revenue By : Shri. P.D. Chougule, Dr $ %&'/Date Of Hearing : 12/03/2018 ! "# $ %&' /Date Of Pronouncement: 14/03/2018 ()*+ "# .//O R D E R , - Per Manish Borad:- This Appeal Of Assessee Pertaining To Assessment Year 2010-11 Is Directed Against The Order Of The Cit(A)-I, Jabalpur Dated 11.08.2015 Vide Appeal No.J/Cit/A/I/Ito/W.1/Cwa/039/13-14, Arising Out Of Order Under Section 143(3) Of The Income-Tax Act, 1961 (Hereinafter Referred To As “The Act”) Dated 11.03.2013 Framed By The Ito-1, Chhindwara.

For Appellant: Shri G.N. Purohit, Sr. AdvFor Respondent: Shri. P.D. Chougule, DR
Section 142(1)Section 143(3)Section 68

142(1)/143(2) of the Act were duly served upon the assessee. The learned Assessing Officer observed that the assessee has taken unsecured loan of Rs.27 lakhs from three parties at Rs.9 lakhs each. Investigations were carried out to examine the alleged unsecured loans in the light of provisions of Section 68

SMT HANSA SHAH,JABALPUR vs. DCIT CIRCLE 2(1) JABALPUR, JABALPUR

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

ITA 52/JAB/2025[2016-17]Status: DisposedITAT Jabalpur30 Sept 2025AY 2016-17

Bench: SH. KUL BHARAT, VICE PRESIDENT AND SH. NIKHIL CHOUDHARY (Accountant Member)

For Appellant: Sh. Rahul Bardia, C.AFor Respondent: Sh. Alok Bhura, Sr. DR
Section 143(2)Section 143(3)Section 14ASection 250

142(1) were served upon the assessee, the details of which are recorded in the assessment order. During the course of assessment proceedings, the ld. AO noted that the assessee had incurred interest expenses for earning exempt income. She had shown investment to the tune of Rs. 2,29,71,470/- as on 31.03.2016 and earned exempt income

AMARJEER PRASAD JAISWAL,SINGRAULI vs. ITO,SINGRAULI WARD, SINGRAULI

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

ITA 50/JAB/2023[2013-14]Status: DisposedITAT Jabalpur20 Sept 2023AY 2013-14

Bench: Shri Om Prakash Kantshri Pavan Kumar Gadaleamarjeet Prasad Jaiswal, Vs Ito, Amarjeet Photocopy, Singrauli Ward, Chitrangi, Singrauli, Singrauli. Madhya Pradesh-486882 (Appellant) (Respondent) Pan No. Arzpa1544R Assessee By None Revenue By Shri Shiv Kumar, Sr.Dr Date Of Hearing 13/09/2023 Date Of Pronouncement 20/09/2023

Section 142(1)Section 144Section 147Section 148Section 68

68 of the IT Act, 1961. 1 | P a g e 02. Because the Learned CITA has failed to associate the fact that the Appellant is engaged in the business of providing E Pay services of MP Online Limited & earning service charges thereon and whole of the cash deposited in the bank account stands fully explained out of Cash collected

SHRI NITIN SHARMA,JABALPUR vs. PRINCIPAL COMMISSIONER OF INCOME TAX -2, JABALPUR

In the result, the appeal is partly allowed

ITA 25/JAB/2019[2014-15]Status: DisposedITAT Jabalpur28 Sept 2020AY 2014-15

Bench: Shri N.R.S. Ganesan & Shri Sanjay Arora

Section 132(4)Section 142(1)Section 143(2)Section 143(3)Section 153A(1)Section 153CSection 153C(1)Section 153DSection 263Section 7(1)

142(1) or the s. 263 notice, which would have at once clarified this aspect to him. Rather, if the assessee’s replies were found not satisfactory by him, it is the deficiency therein, or the likely course which ought to have been adopted by the AO in verification of the assessee’s explanation/s, that should have been pointed

DEVENRA KUMAR GUPTA,REWA vs. ACIT, CIRCLE SATNA, SATNA

In the result, the appeal of the assessee is allowed

ITA 38/JAB/2024[2017-18]Status: DisposedITAT Jabalpur18 Sept 2025AY 2017-18

Bench: Shri Kul Bharatassessment Year: 2017-18 Devendra Kumar Gupta V. Acit Circle Satna 17/304, Venkat Road, Ghoghar, Income Tax Office, Aaykar Rewa-486001. Bhawan, Civil Lines, Satna-485001. Pan: Ahapg6843Q (Appellant) (Respondent) Appellant By: Shri Sapan Usrethe, Advocate. Respondent By: Shri N.M. Prasad, Sr.Dr-1 Date Of Hearing: 16 09 2025 Date Of Pronouncement: 18 09 2025 O R D E R

For Appellant: Shri Sapan Usrethe, AdvocateFor Respondent: Shri N.M. Prasad, Sr.DR-1
Section 142(1)Section 143(1)Section 143(2)Section 68

section 68 and mechanical order was passed which is bad in law . Page 2 of 6 4. The learned Commissioner of Income tax (Appeal) of NFAC New Delhi was not justified in confirming the action of AO without appreciating the fact that appellant have duly filed the figures of earlier year also and further there was sufficient cash balance

HAJARIMAL MISHRIMAL BAFANA vs. ADDITIONAL COMMISSIONER OF INCOME TAX RANGE,

In the result, the assessee’s appeal for AY 2004-05 is dismissed, and that of AY 2005-06 is partly allowed

ITA 176/JAB/2016[2005-06]Status: DisposedITAT Jabalpur29 Nov 2022AY 2005-06

Bench: Shri Sanjay Arora, Hon’Ble & Shri Manomohan Das, Hon'Ble

For Appellant: NoneFor Respondent: Shri Ravi Mehrotra Sr. DR
Section 142(1)Section 143(3)Section 254(2)Section 43B

142(1) is clearly toward obtaining information deemed relevant by the assessing authority from the assessee. The second function of the said notice is to cause furnishing of a return of income where the same has not been furnished u/s. 139, and which is clearly not the case. In sum, the Ground is without merit and, accordingly, dismissed. 6. Ground

ABDUL RAZAQUE,JABALPUR vs. ACIT CIRCLE 2(1), JABALPUR

In the result, ground no. 1 is allowed while ground nos

ITA 84/JAB/2024[2016-17]Status: DisposedITAT Jabalpur16 Oct 2025AY 2016-17

Bench: Sh. Kul Bharat & Sh. Nikhil Choudharya.Y. 2016-17 Abdul Razaque, Vs. Acit, 903, Badi Omti, Jabalpur, M.P. Circle-2(1), Jabalpur Pan:Afgpr9967N (Appellant) (Respondent) Assessee By: Sh. Sapan Usrethe, Advocate Revenue By: Sh. Alok Bhura, Sr. Dr Date Of Hearing: 18.09.2025 Date Of Pronouncement: 16.10.2025 O R D E R Per Nikhil Choudhary, A.M. This Is An Appeal Filed By The Assessee Against The Order Of The Ld. Addl Jcit(A), Mysore, Wherein The Ld. Addl Jcit(A) Has Partly Allowed The Appeals Of The Assessee Against The Orders Of The Ld. Ao Dated 19.11.2018, Passed Under Section 143(3) Of The Income Tax Act, 1961. The Grounds Of Appeal Are As Under:- “1. The Learned Commissioner Of Income Tax (Appeal) Addl/Jaddl Jcit(A)- Mysore Was Not Justified In Deciding The Legal Ground That Case Was Selected For Limited Scrutiny Under Cass To Examine The Reasons Of (I) Return Filed After 7.11.2016' & Cash Deposit During Demonetization Period & Addition Was Made On Some Other Issue Which Was Not The Reason For Selection & Without Taking Any Approval From Higher Authorities. 2. The Learned Commissioner Of Income Tax (Appeal) Addl/Jaddl Jcit(A)-Mysore Was Not Justified In Confirming The Addition Of Rs. 4,48,584 By Ignoring All The Evidences & Documents By Simply Observing That No New Documents Were Filed Even Though Documents Which Are Filed Are Sufficient & Self-Explanatory & The Order Of Learned Cit Appeals Is Passed In A Mechanical Manner, Without Any Application Of Mind & Appears That It Was Passed With Predetermined Mind.

For Appellant: Sh. Sapan Usrethe, AdvocateFor Respondent: Sh. Alok Bhura, Sr. DR
Section 143(2)Section 143(3)Section 68

142(1) were served upon the assessee through ITBA Portal and through email. In response, assessee filed submissions. The ld. AO observed that the assessee had deposited cash in his bank account at Union Bank of India to the extent of Rs. 4,48,584/- and he was asked to furnish the sources of the cash deposits vide questionnaire dated

SHRI GAURAV AGRAWAL,JABALPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX (CENTRAL), JABALPUR

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

ITA 37/JAB/2019[2016-17]Status: DisposedITAT Jabalpur01 Dec 2023AY 2016-17

Bench: Dr. B. R. R. Kumarsh. Yogesh Kumar Us

For Appellant: Sh. Sapan Usrethe, AdvFor Respondent: Sh. Garima Chaudhary, CIT-DR
Section 127Section 127(2)Section 132Section 153A

68,950/- on account of unaccounted money and Rs. 1,04,33,573/- on account of unexplained transaction in books of account. 6. Aggrieved, the assessee filed appeal before the CIT(A). The ld. CIT(A) deleted addition of Rs. 67,85,00,100/- made by the AO on account of unexplained cash credit, Rs. 2,58,60,033/- made

DEPUTY COMMISSIONER OF INCOME TAX (CENTRAL), JABALPUR vs. SHRI GAURAV AGRAWAL, JABALPUR

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

ITA 39/JAB/2019[2016-17]Status: DisposedITAT Jabalpur01 Dec 2023AY 2016-17

Bench: Dr. B. R. R. Kumarsh. Yogesh Kumar Us

For Appellant: Sh. Sapan Usrethe, AdvFor Respondent: Sh. Garima Chaudhary, CIT-DR
Section 127Section 127(2)Section 132Section 153A

68,950/- on account of unaccounted money and Rs. 1,04,33,573/- on account of unexplained transaction in books of account. 6. Aggrieved, the assessee filed appeal before the CIT(A). The ld. CIT(A) deleted addition of Rs. 67,85,00,100/- made by the AO on account of unexplained cash credit, Rs. 2,58,60,033/- made

SUDEEP PANDYA L/H LLA JAYESH PANDEYA,CHHINDWARA vs. PR.COMMISSIONER OF INCOME TAX, JABALPUR

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

ITA 36/JAB/2022[2017-18]Status: DisposedITAT Jabalpur17 Oct 2023AY 2017-18

Bench: Shri Om Prakash Kant & Shri Pavan Kumar Gadalesudeep Pandya L/H, Vs. Pr.Cit, Smt.Ila Jayesh Centralrevenuebuilding, Pandya, Napier Town, 14-15 Patni Jabalpur-482002, Complex, Madhya Pradesh. Parasiya Road, Chhindwara-480001 Madhya Pradesh. Pan/Gir No. : Ahkpp7408G Appellant .. Respondent Assessee By : Shri G.N Purohit.Sr.Adv & Smt.Uma Parashar. Adv.Ar Respondent By : Shri Saad Kidwai.Cit-Dr Date Of Hearing 21.09.2023 Date Of Pronouncement 12.10.2023 आदेश / O R D E R Per Pavan Kumar Gadale Jm: The Assessee Has Filed The Appeal Against The Order Of The Principal Commissioner Of Income Tax (Pr.Cit) Jabalpur Passed U/Sec 263 Of The Act. The Assessee Has Raised The Following Grounds Of Appeal: Sudeep Pandya L/H Ila Jayesh Pandya Jabalpur. 1 The Learned Pcit Has Erred In Law & On Facts Of The Case In Passing An Order Under Section 263 Against A Dead Person, The Notice Of Hearing Where Issued In The Name Of Deceased & Were Not Served On The Legal Here The Order Passed Under Section 263 Is Illegal Without Jurisdiction & Void Ab-Intio Same Should Be Placed Into Toto.

For Appellant: Shri G.N Purohit.Sr.Adv &For Respondent: Shri Saad Kidwai.CIT-DR
Section 10Section 133ASection 143(3)Section 263Section 68

142(1) of the Act along with the questionnaire are issued. In compliance to the notices the L/H of the assessee has filed information/ written submissions through ITBA System. In the course of assessment proceedings, legal heir of the assessee has submitted the details of purchase and sale of goods in credit and cash for the F.Y 2016-17.The Assessing Officer

GAYATRI DEVI AGRAWAL,BALAGHAT vs. INCOME TAX OFFICER, WARD -BALAGHAT , BALAGHAT

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

ITA 106/JAB/2022[2014-15]Status: DisposedITAT Jabalpur12 Sept 2023AY 2014-15
For Appellant: NoneFor Respondent: Shri Rajesh Kumar Gupta.Sr.DR
Section 143(2)Section 143(3)Section 68

142(1) of the Act along with the questionnaire are issued. In compliance to the notice, the Ld. AR of the assessee appeared from time to time and submitted the details. The Assessing Officer (AO) on perusal of the financial statements found that most of the expenses are not properly supported and in respect of unsecured loan the assessee could

ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE- SATNA vs. SHRI JAMMU BEG,

In the result, the levy of penalty is cancelled and the appeal of the appellant is allowed

ITA 196/JAB/2016[2012-13]Status: FixedITAT Jabalpur20 Sept 2023AY 2012-13

Bench: Shri Om Prakash Kant & Shri Pavan Kumar Gadaleacit, Vs. Shri Jammu Beg, Satna, M/S Mirza Transport, Madhya Pradesh. Main Road, Waidhan, Singrauli. Madhya Pradesh.

For Appellant: NoneFor Respondent: Shri Shravan Kumar Gotru, CIT-DR
Section 143(2)Section 143(3)Section 269SSection 271D

142(1) of the Act was issued. In compliance to the notice, the Ld. AR of the assessee appeared from time to time and submitted the details and the case was discussed. The AO dealt on the facts with respect to unsecured loans accepted by the assessee and was not satisfied with the explanations and made addition

ABHISHEK PUROHIT, SAGAR,SAGAR vs. ITO WARD (3) SAGAR, SAGAR

Appeal of the assessee stands allowed for statistical purposes

ITA 47/JAB/2022[2016-17]Status: DisposedITAT Jabalpur07 Jul 2023AY 2016-17

Bench: Shri Sudhanshu Srivastava & Shri Anadee Nath Misshraassessment Year: 2016-17 Abhishek Purohit, Vs. Ito, Kotwali Road, Ward (3), Behind Putrishala School, Sagar Sagar. Pan : Asbpp 4859M (Appellant) (Respondent) Appellant By Shri Rahul Bardia, Ca Respondent By Shri Ravi Mehrotra, Sr. Dr Date Of Hearing 05/07/2023 Date Of Pronouncement 07/07/2023

Section 144Section 234BSection 271(1)(C)Section 271(1)(b)Section 68

Sections 143(2) of the Income Tax Act, 1961 (hereinafter called ‘the Act’) and 142(1) of the Act were issued from time to time. However, there was non-compliance on the part of the assessee. The Assessing Officer also proceeded to impose penalty u/s. 271(1)(b) of the Act amounting to Rs.10,000/- for non compliance. Thereafter

M/S.ASIT DIXIT,JABALPUR vs. INCOME TAX OFFICER WARD2(2), JABALPUR

In the result, the assessee’s appeal is partly allowed for statistical purposes

ITA 19/JAB/2020[2005-06]Status: DisposedITAT Jabalpur07 Oct 2021AY 2005-06

Bench: Sh. Sanjay Arora, Hon'Bleassessment Year : 2005-06 Asit Dixit, Income Tax Officer, Vs. Ward-2(2), Jabalpur (M.P.) Jabalpur [Pan: Aanfm 5798A] (Appellant) (Respondent) Appellant By Sh. Sanjay Seth, Ca Respondent By Sh. S.K. Halder, Sr. Dr Date Of Hearing 16/09/2021 Date Of Pronouncement 07/10/2021

Section 142(1)Section 143(2)Section 144Section 145(3)

section 144 of the Income Tax Act, 1961 (‘the Act’ hereinafter) for the Assessment Year (AY) 2005-06 vide Order dated 24/11/2010. 2. The appeal raises two grounds, as under, which shall be taken up in seriatim: ‘1. That the assessee had filed ITR declaring loss of Rs. 26,130 and the AO has estimated profit