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146 results for “disallowance”+ Section 24(1)clear

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Key Topics

Section 143(3)92Disallowance75Addition to Income59Section 143(1)53Section 36(1)(va)53Section 26342Section 139(1)32Section 80I32Deduction32Section 194Q

M/S TARUN CONSTRUCTION COMPANY,WARD NO.24, NEAR BHAGAT SINGH CHOWK, SURATGARH vs. CPC, BANGALORE/ ITO, WARD-1, SRIGANGANAGAR , SRIGANGANAGAR

In the result, appeals are dismissed

ITA 108/JODH/2023[2018-19]Status: DisposedITAT Jodhpur21 Sept 2023AY 2018-19

Bench: Shri Saktijit Dey, Vice- & Dr. Brr Kumar

For Appellant: Sh. P.C. Parwal, C.AFor Respondent: Sh. Rajeev Mohan, JCIT-DR
Section 10ASection 139Section 142Section 143(1)Section 143(1)(a)Section 36(1)(va)

24)(x) of the Act. In accordance with the statutory provision, the departmental authorities have made the disallowances. 7. The assessee has contested the disallowance broadly on the following grounds: • In the tax audit report, the auditor has only mentioned the details of contribution received from employees for various as to attract adjustment under section 143(1

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M/S TARUN CONSTRUCTION COMPANY,WARD NO.24, NEAR BHAGAT SINGH CHOWK, SURATGARH vs. CPC, BANGALORE/ ITO, WARD-1, SRIGANGANAGAR, SRIGANGANAGAR

In the result, appeals are dismissed

ITA 109/JODH/2023[2019-20]Status: DisposedITAT Jodhpur21 Sept 2023AY 2019-20

Bench: Shri Saktijit Dey, Vice- & Dr. Brr Kumar

For Appellant: Sh. P.C. Parwal, C.AFor Respondent: Sh. Rajeev Mohan, JCIT-DR
Section 10ASection 139Section 142Section 143(1)Section 143(1)(a)Section 36(1)(va)

24)(x) of the Act. In accordance with the statutory provision, the departmental authorities have made the disallowances. 7. The assessee has contested the disallowance broadly on the following grounds: • In the tax audit report, the auditor has only mentioned the details of contribution received from employees for various as to attract adjustment under section 143(1

NAHAR COLOURS AND COATINHGS PRIVATE LIMITED,UDAIPUR vs. PRINCIPAL COMMISSIONER OFINCOMETAX, UDAIPUR

In the result, appeal of the assessee is allowed

ITA 140/JODH/2023[2018-19]Status: DisposedITAT Jodhpur09 Aug 2023AY 2018-19
Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 263Section 801ASection 80I

disallowance of Rs. 15,24,003/- in terms of section 36(1)(va) r.w.s 2(24)(x) of the Act. The FAO passed

SANTOK SNGH GEHLOT,JODHPUR vs. ITO, WARD-3(3), JODHPUR, JODHPUR

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

ITA 64/JODH/2021[2018-19]Status: DisposedITAT Jodhpur29 Sept 2021AY 2018-19

Bench: Shri N.K.Saini & Shri Sandeep Gosainassessment Year : 2018-19 Arpit Gulecha, Vs. The Dcit, Jodhpur Cpc, Bengaluru Pan No: Ahdpg9415D Appellant Respondent Assessment Year : 2019-20 Shashi Maheshwari, Vs. The Adit, Jodhpur Cpc, Bengaluru Pan No: Aaspm0358H Appellant Respondent Assessment Year : 2018-19 Opel Sulz Private Limited, Vs. The Dcit, Bhilwara Cpc, Banglore Pan No: Aaaco2585R Appellant Respondent Assessment Year : 2019-20 Opel Sulz Private Limited, Vs. The Adit, Bhilwara Cpc, Banglore Pan No: Aaaco2585R Appellant Respondent Assessment Year : 2019-20 Kishori Lal Singhvi Vs. The Dcit, Balotra Cpc, Banglore Pan No: Abnps1994F Appellant Respondent

For Appellant: Smt.Raksha Birla, CAFor Respondent: Smt. Monisha, JCIT DR
Section 2Section 28Section 36Section 36(1)(va)Section 43Section 43B

24)(x) of the Act was correct or not. It appears that the Tribunal below, in view of the decision of the Supreme Court in the case of Commissioner of Income Tax vs. Alom Extrusion Ltd., reported in 2009 Vol.390 ITR 306, held that the deletion was justified. Being dissatisfied, the Revenue has come up with the present appeal. After

OPEL SULZ PRIVATE LIMITED,BHILWARA vs. ACIT, CIRCLE, BHILWARA

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

ITA 74/JODH/2021[2019-20]Status: DisposedITAT Jodhpur29 Sept 2021AY 2019-20

Bench: Shri N.K.Saini & Shri Sandeep Gosainassessment Year : 2018-19 Arpit Gulecha, Vs. The Dcit, Jodhpur Cpc, Bengaluru Pan No: Ahdpg9415D Appellant Respondent Assessment Year : 2019-20 Shashi Maheshwari, Vs. The Adit, Jodhpur Cpc, Bengaluru Pan No: Aaspm0358H Appellant Respondent Assessment Year : 2018-19 Opel Sulz Private Limited, Vs. The Dcit, Bhilwara Cpc, Banglore Pan No: Aaaco2585R Appellant Respondent Assessment Year : 2019-20 Opel Sulz Private Limited, Vs. The Adit, Bhilwara Cpc, Banglore Pan No: Aaaco2585R Appellant Respondent Assessment Year : 2019-20 Kishori Lal Singhvi Vs. The Dcit, Balotra Cpc, Banglore Pan No: Abnps1994F Appellant Respondent

For Appellant: Smt.Raksha Birla, CAFor Respondent: Smt. Monisha, JCIT DR
Section 2Section 28Section 36Section 36(1)(va)Section 43Section 43B

24)(x) of the Act was correct or not. It appears that the Tribunal below, in view of the decision of the Supreme Court in the case of Commissioner of Income Tax vs. Alom Extrusion Ltd., reported in 2009 Vol.390 ITR 306, held that the deletion was justified. Being dissatisfied, the Revenue has come up with the present appeal. After

SHASHI MAHESHWARI,JODHPUR vs. ADIT, CPC, BENGALURU

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

ITA 58/JODH/2021[2019-20]Status: DisposedITAT Jodhpur29 Sept 2021AY 2019-20

Bench: Shri N.K.Saini & Shri Sandeep Gosainassessment Year : 2018-19 Arpit Gulecha, Vs. The Dcit, Jodhpur Cpc, Bengaluru Pan No: Ahdpg9415D Appellant Respondent Assessment Year : 2019-20 Shashi Maheshwari, Vs. The Adit, Jodhpur Cpc, Bengaluru Pan No: Aaspm0358H Appellant Respondent Assessment Year : 2018-19 Opel Sulz Private Limited, Vs. The Dcit, Bhilwara Cpc, Banglore Pan No: Aaaco2585R Appellant Respondent Assessment Year : 2019-20 Opel Sulz Private Limited, Vs. The Adit, Bhilwara Cpc, Banglore Pan No: Aaaco2585R Appellant Respondent Assessment Year : 2019-20 Kishori Lal Singhvi Vs. The Dcit, Balotra Cpc, Banglore Pan No: Abnps1994F Appellant Respondent

For Appellant: Smt.Raksha Birla, CAFor Respondent: Smt. Monisha, JCIT DR
Section 2Section 28Section 36Section 36(1)(va)Section 43Section 43B

24)(x) of the Act was correct or not. It appears that the Tribunal below, in view of the decision of the Supreme Court in the case of Commissioner of Income Tax vs. Alom Extrusion Ltd., reported in 2009 Vol.390 ITR 306, held that the deletion was justified. Being dissatisfied, the Revenue has come up with the present appeal. After

OPEL SULZ PRIVATE LIMITED,BHILWRA vs. ACIT, CIRCLE, BHILWARA

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

ITA 73/JODH/2021[2018-19]Status: DisposedITAT Jodhpur29 Sept 2021AY 2018-19

Bench: Shri N.K.Saini & Shri Sandeep Gosainassessment Year : 2018-19 Arpit Gulecha, Vs. The Dcit, Jodhpur Cpc, Bengaluru Pan No: Ahdpg9415D Appellant Respondent Assessment Year : 2019-20 Shashi Maheshwari, Vs. The Adit, Jodhpur Cpc, Bengaluru Pan No: Aaspm0358H Appellant Respondent Assessment Year : 2018-19 Opel Sulz Private Limited, Vs. The Dcit, Bhilwara Cpc, Banglore Pan No: Aaaco2585R Appellant Respondent Assessment Year : 2019-20 Opel Sulz Private Limited, Vs. The Adit, Bhilwara Cpc, Banglore Pan No: Aaaco2585R Appellant Respondent Assessment Year : 2019-20 Kishori Lal Singhvi Vs. The Dcit, Balotra Cpc, Banglore Pan No: Abnps1994F Appellant Respondent

For Appellant: Smt.Raksha Birla, CAFor Respondent: Smt. Monisha, JCIT DR
Section 2Section 28Section 36Section 36(1)(va)Section 43Section 43B

24)(x) of the Act was correct or not. It appears that the Tribunal below, in view of the decision of the Supreme Court in the case of Commissioner of Income Tax vs. Alom Extrusion Ltd., reported in 2009 Vol.390 ITR 306, held that the deletion was justified. Being dissatisfied, the Revenue has come up with the present appeal. After

ARPIT GULECHA,JODHPUR vs. DCIT, CPC, BENGALURU

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

ITA 57/JODH/2021[2018-19]Status: DisposedITAT Jodhpur29 Sept 2021AY 2018-19

Bench: Shri N.K.Saini & Shri Sandeep Gosainassessment Year : 2018-19 Arpit Gulecha, Vs. The Dcit, Jodhpur Cpc, Bengaluru Pan No: Ahdpg9415D Appellant Respondent Assessment Year : 2019-20 Shashi Maheshwari, Vs. The Adit, Jodhpur Cpc, Bengaluru Pan No: Aaspm0358H Appellant Respondent Assessment Year : 2018-19 Opel Sulz Private Limited, Vs. The Dcit, Bhilwara Cpc, Banglore Pan No: Aaaco2585R Appellant Respondent Assessment Year : 2019-20 Opel Sulz Private Limited, Vs. The Adit, Bhilwara Cpc, Banglore Pan No: Aaaco2585R Appellant Respondent Assessment Year : 2019-20 Kishori Lal Singhvi Vs. The Dcit, Balotra Cpc, Banglore Pan No: Abnps1994F Appellant Respondent

For Appellant: Smt.Raksha Birla, CAFor Respondent: Smt. Monisha, JCIT DR
Section 2Section 28Section 36Section 36(1)(va)Section 43Section 43B

24)(x) of the Act was correct or not. It appears that the Tribunal below, in view of the decision of the Supreme Court in the case of Commissioner of Income Tax vs. Alom Extrusion Ltd., reported in 2009 Vol.390 ITR 306, held that the deletion was justified. Being dissatisfied, the Revenue has come up with the present appeal. After

WHEEL O CITY,SRI GANGANAGAR vs. ITO, WARD-1, SRI GANGANAGAR

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

ITA 63/JODH/2021[2019-20]Status: DisposedITAT Jodhpur29 Sept 2021AY 2019-20

Bench: Shri N.K.Saini & Shri Sandeep Gosainassessment Year : 2018-19 Arpit Gulecha, Vs. The Dcit, Jodhpur Cpc, Bengaluru Pan No: Ahdpg9415D Appellant Respondent Assessment Year : 2019-20 Shashi Maheshwari, Vs. The Adit, Jodhpur Cpc, Bengaluru Pan No: Aaspm0358H Appellant Respondent Assessment Year : 2018-19 Opel Sulz Private Limited, Vs. The Dcit, Bhilwara Cpc, Banglore Pan No: Aaaco2585R Appellant Respondent Assessment Year : 2019-20 Opel Sulz Private Limited, Vs. The Adit, Bhilwara Cpc, Banglore Pan No: Aaaco2585R Appellant Respondent Assessment Year : 2019-20 Kishori Lal Singhvi Vs. The Dcit, Balotra Cpc, Banglore Pan No: Abnps1994F Appellant Respondent

For Appellant: Smt.Raksha Birla, CAFor Respondent: Smt. Monisha, JCIT DR
Section 2Section 28Section 36Section 36(1)(va)Section 43Section 43B

24)(x) of the Act was correct or not. It appears that the Tribunal below, in view of the decision of the Supreme Court in the case of Commissioner of Income Tax vs. Alom Extrusion Ltd., reported in 2009 Vol.390 ITR 306, held that the deletion was justified. Being dissatisfied, the Revenue has come up with the present appeal. After

WHEEL O CITY,SRI GANGANAGAR vs. ITO, WARD-1, SRI GANGANAGAR

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

ITA 62/JODH/2021[2018-19]Status: DisposedITAT Jodhpur29 Sept 2021AY 2018-19

Bench: Shri N.K.Saini & Shri Sandeep Gosainassessment Year : 2018-19 Arpit Gulecha, Vs. The Dcit, Jodhpur Cpc, Bengaluru Pan No: Ahdpg9415D Appellant Respondent Assessment Year : 2019-20 Shashi Maheshwari, Vs. The Adit, Jodhpur Cpc, Bengaluru Pan No: Aaspm0358H Appellant Respondent Assessment Year : 2018-19 Opel Sulz Private Limited, Vs. The Dcit, Bhilwara Cpc, Banglore Pan No: Aaaco2585R Appellant Respondent Assessment Year : 2019-20 Opel Sulz Private Limited, Vs. The Adit, Bhilwara Cpc, Banglore Pan No: Aaaco2585R Appellant Respondent Assessment Year : 2019-20 Kishori Lal Singhvi Vs. The Dcit, Balotra Cpc, Banglore Pan No: Abnps1994F Appellant Respondent

For Appellant: Smt.Raksha Birla, CAFor Respondent: Smt. Monisha, JCIT DR
Section 2Section 28Section 36Section 36(1)(va)Section 43Section 43B

24)(x) of the Act was correct or not. It appears that the Tribunal below, in view of the decision of the Supreme Court in the case of Commissioner of Income Tax vs. Alom Extrusion Ltd., reported in 2009 Vol.390 ITR 306, held that the deletion was justified. Being dissatisfied, the Revenue has come up with the present appeal. After

LUBI GEL LLP,JODHPUR vs. DCIT,CPC, BENGALURU

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

ITA 68/JODH/2021[2018-19]Status: DisposedITAT Jodhpur27 Sept 2021AY 2018-19
For Appellant: Shri Arun Chordia, C.AFor Respondent: Smt. Monisha, JCIT DR
Section 2Section 28Section 36Section 36(1)(va)Section 43Section 43B

24)(x) of the Act was correct or not. It appears that the Tribunal below, in view of the decision of the Supreme Court in the case of Commissioner of Income Tax vs. Alom Extrusion Ltd., reported in 2009 Vol.390 ITR 306, held that the deletion was justified. Being dissatisfied, the Revenue has come up with the present appeal. After

LUBI GEL LLP,JODHPUR vs. ADIT CPC, BENGALURU

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

ITA 69/JODH/2021[2019-20]Status: DisposedITAT Jodhpur27 Sept 2021AY 2019-20
For Appellant: Shri Arun Chordia, C.AFor Respondent: Smt. Monisha, JCIT DR
Section 2Section 28Section 36Section 36(1)(va)Section 43Section 43B

24)(x) of the Act was correct or not. It appears that the Tribunal below, in view of the decision of the Supreme Court in the case of Commissioner of Income Tax vs. Alom Extrusion Ltd., reported in 2009 Vol.390 ITR 306, held that the deletion was justified. Being dissatisfied, the Revenue has come up with the present appeal. After

C.G. TECHNOSOFT PVT. LTD. ,JODHPUR vs. ITO, WARD-3(1), , JODHPUR

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

ITA 49/JODH/2021[2018-19]Status: DisposedITAT Jodhpur27 Sept 2021AY 2018-19
For Appellant: Shri Arun Chordia, C.AFor Respondent: Smt. Monisha, JCIT DR
Section 2Section 28Section 36Section 36(1)(va)Section 43Section 43B

24)(x) of the Act was correct or not. It appears that the Tribunal below, in view of the decision of the Supreme Court in the case of Commissioner of Income Tax vs. Alom Extrusion Ltd., reported in 2009 Vol.390 ITR 306, held that the deletion was justified. Being dissatisfied, the Revenue has come up with the present appeal. After

C G TECHNOSOFT PVT. LTD.,JODHPUR vs. ASST. DIRECTOR OF INCOME TAX, BENGALURU

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

ITA 52/JODH/2021[2019-20]Status: DisposedITAT Jodhpur27 Sept 2021AY 2019-20
For Appellant: Shri Arun Chordia, C.AFor Respondent: Smt. Monisha, JCIT DR
Section 2Section 28Section 36Section 36(1)(va)Section 43Section 43B

24)(x) of the Act was correct or not. It appears that the Tribunal below, in view of the decision of the Supreme Court in the case of Commissioner of Income Tax vs. Alom Extrusion Ltd., reported in 2009 Vol.390 ITR 306, held that the deletion was justified. Being dissatisfied, the Revenue has come up with the present appeal. After

INDER BAHADUR GURUNG,JODHPUR vs. JURISDICTIONAL ASSESSING OFFICER, ITO, W-3(2), JU

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

ITA 55/JODH/2021[2018-19]Status: DisposedITAT Jodhpur24 Sept 2021AY 2018-19

Bench: Shri N.K.Saini & Shri Sandeep Gosainassessment Year : 2018-19 Mohan Ram Chaudhary, Vs. The Ito, Jodhpur Ward 3(2), Jodhpur Pan No: Acgpc8070L Appellant Respondent Assessee By : Shri Kapil Taparia & Miss Divya, Cas. Revenue By : Smt. Monisha, Jcit Dr Assessment Year : 2018-19 Muthia Muruganantham, Vs. The Ito, Jodhpur Ward 3(2), Jodhpur Pan No: Abipm1535F Appellant Respondent Assessee By : Shri Kapil Taparia & Miss Divya, Cas. Revenue By : Smt. Monisha, Jcit Dr Assessment Year : 2018-19 Inder Bahadur Gurung, Vs. The Ito, Jodhpur Ward 3(1), Jodhpur Pan No: Aempg9230N Appellant Respondent Assessee By : Shri Kapil Taparia & Miss Divya, Cas. Revenue By : Smt. Monisha, Jcit Dr

For Appellant: Shri Kapil Taparia and Miss Divya, CAsFor Respondent: Smt. Monisha, JCIT DR
Section 2Section 28Section 36Section 36(1)(va)Section 43Section 43B

24)(x) of the Act was correct or not. It appears that the Tribunal below, in view of the decision of the Supreme Court in the case of Commissioner of Income Tax vs. Alom Extrusion Ltd., reported in 2009 Vol.390 ITR 306, held that the deletion was justified. Being dissatisfied, the Revenue has come up with the present appeal. After

SWARUP RAM ,JODHPUR vs. ITO, WARD-1(1), JODHPUR

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

ITA 65/JODH/2021[2018-19]Status: DisposedITAT Jodhpur24 Sept 2021AY 2018-19

Bench: Shri N.K.Saini & Shri Sandeep Gosain

For Appellant: Shri Akash Phophalia, CAFor Respondent: Smt. Monisha, JCIT DR
Section 139Section 2Section 28Section 36Section 36(1)(va)Section 43Section 43B

24)(x) of the Act was correct or not. It appears that the Tribunal below, in view of the decision of the Supreme Court in the case of Commissioner of Income Tax vs. Alom Extrusion Ltd., reported in 2009 Vol.390 ITR 306, held that the deletion was justified. Being dissatisfied, the Revenue has come up with the present appeal. After

SWARUP RAM ,JODHPUR vs. ITO, WARD-1(1), JODHPUR

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

ITA 66/JODH/2021[2019-20]Status: DisposedITAT Jodhpur24 Sept 2021AY 2019-20

Bench: Shri N.K.Saini & Shri Sandeep Gosain

For Appellant: Shri Akash Phophalia, CAFor Respondent: Smt. Monisha, JCIT DR
Section 139Section 2Section 28Section 36Section 36(1)(va)Section 43Section 43B

24)(x) of the Act was correct or not. It appears that the Tribunal below, in view of the decision of the Supreme Court in the case of Commissioner of Income Tax vs. Alom Extrusion Ltd., reported in 2009 Vol.390 ITR 306, held that the deletion was justified. Being dissatisfied, the Revenue has come up with the present appeal. After

RIDHI SIDHI MILLS (INDIA) PVT. LTD.,PALI vs. DCIT, CPC, BANGALORE

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

ITA 71/JODH/2021[2018-19]Status: DisposedITAT Jodhpur24 Sept 2021AY 2018-19

Bench: Shri N.K.Saini & Shri Sandeep Gosain

For Appellant: Shri Amit Kothari, CAFor Respondent: Smt. Monisha, JCIT DR
Section 139Section 2Section 28Section 36Section 36(1)(va)Section 43Section 43B

24)(x) of the Act was correct or not. It appears that the Tribunal below, in view of the decision of the Supreme Court in the case of Commissioner of Income Tax vs. Alom Extrusion Ltd., reported in 2009 Vol.390 ITR 306, held that the deletion was justified. Being dissatisfied, the Revenue has come up with the present appeal. After

MOHAN RAM CHAUDHARY,JODHPUR vs. ITO, WARD-3(2), JODHPUR, JODHPUR

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

ITA 51/JODH/2021[2018-19]Status: DisposedITAT Jodhpur24 Sept 2021AY 2018-19

Bench: Shri N.K.Saini & Shri Sandeep Gosainassessment Year : 2018-19 Mohan Ram Chaudhary, Vs. The Ito, Jodhpur Ward 3(2), Jodhpur Pan No: Acgpc8070L Appellant Respondent Assessee By : Shri Kapil Taparia & Miss Divya, Cas. Revenue By : Smt. Monisha, Jcit Dr Assessment Year : 2018-19 Muthia Muruganantham, Vs. The Ito, Jodhpur Ward 3(2), Jodhpur Pan No: Abipm1535F Appellant Respondent Assessee By : Shri Kapil Taparia & Miss Divya, Cas. Revenue By : Smt. Monisha, Jcit Dr Assessment Year : 2018-19 Inder Bahadur Gurung, Vs. The Ito, Jodhpur Ward 3(1), Jodhpur Pan No: Aempg9230N Appellant Respondent Assessee By : Shri Kapil Taparia & Miss Divya, Cas. Revenue By : Smt. Monisha, Jcit Dr

For Appellant: Shri Kapil Taparia and Miss Divya, CAsFor Respondent: Smt. Monisha, JCIT DR
Section 2Section 28Section 36Section 36(1)(va)Section 43Section 43B

24)(x) of the Act was correct or not. It appears that the Tribunal below, in view of the decision of the Supreme Court in the case of Commissioner of Income Tax vs. Alom Extrusion Ltd., reported in 2009 Vol.390 ITR 306, held that the deletion was justified. Being dissatisfied, the Revenue has come up with the present appeal. After

MANIBHADRA UDHYOG,PALI vs. DCIT, CPC, BANGALORE

In the result, the appeal of the assessee is allowed

ITA 70/JODH/2021[2017-18]Status: DisposedITAT Jodhpur24 Sept 2021AY 2017-18

Bench: Shri N.K.Saini & Shri Sandeep Gosainassessment Year : 2017-18 Manibhadra Udhyog, Vs. The Dcit, Pali Cpc, Banglore Pan No: Aagfm4258G Appellant Respondent Assessee By : Shri Amit Kothari, Ca Revenue By : Smt. Monisha, Jcit Dr Date Of Hearing : 28.09.2021 Date Of Pronouncement : 28.09.2021 आदेश/Order

For Appellant: Shri Amit Kothari, CAFor Respondent: Smt. Monisha, JCIT DR
Section 139Section 2Section 28Section 36Section 36(1)(va)Section 43Section 43B

24)(x) of the Act was correct or not. It appears that the Tribunal below, in view of the decision of the Supreme Court in the case of Commissioner of Income Tax vs. Alom Extrusion Ltd., reported in 2009 Vol.390 ITR 306, held that the deletion was justified. Being dissatisfied, the Revenue has come up with the present appeal. After