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338 results for “condonation of delay”+ Section 90(2)clear

Sorted by relevance

Chennai628Mumbai535Delhi386Kolkata338Bangalore218Hyderabad213Ahmedabad177Karnataka128Jaipur126Pune85Surat82Raipur77Chandigarh69Nagpur59Visakhapatnam59Indore56Amritsar53Lucknow49Cochin45Calcutta41Rajkot32Patna22SC19Cuttack18Allahabad14Jodhpur12Varanasi11Agra9Jabalpur8Guwahati7Telangana5Panaji4Dehradun4Ranchi3Andhra Pradesh2Rajasthan2Orissa1Himachal Pradesh1A.K. SIKRI N.V. RAMANA1R.M. LODHA ANIL R. DAVE1

Key Topics

Addition to Income71Section 14865Section 143(3)57Section 25050Limitation/Time-bar47Section 14746Section 6839Condonation of Delay36Section 143(1)

M/S PREMIER IRRIGATION ADRITEC (P) LTD.,KOLKATA vs. ACIT, CIR-11(1), KOLKATA , KOLKATA

In the result, the appeal of the assessee is dismissed

ITA 387/KOL/2021[2014-15]Status: DisposedITAT Kolkata20 Jan 2023AY 2014-15

Bench: Shri Sanjay Garg & Shri Girish Agrawal

Section 2(24)Section 250Section 3Section 36(1)Section 36(1)(va)Section 43B

condoned. Ground No.1 & 2 – Vide Ground Nos.1 & 2, the assessee has 4. agitated the confirmation of addition of Rs.10,10,774/- made by the Assessing Officer invoking the provisions to section 43B of the Act for delay in depositing employees contribution to provident fund and employees state insurance. 5. Heard both the sides. At the outset, we note that

Showing 1–20 of 338 · Page 1 of 17

...
31
Section 26329
Section 9026
Disallowance21

MILK MANTRA DAIRY (P) LTD.,BHUBANESWAR vs. DCIT, CIR.-12(1), KOLKATA

In the result, the appeal of the assessee is partly allowed

ITA 413/KOL/2020[2013-14]Status: DisposedITAT Kolkata04 Jul 2022AY 2013-14

Bench: Shri Aby T. Varkey & Shri Girish Agrawalassessment Year: 2013-14 Milk Mantra Dairy Pvt. Ltd. Deputy Commissioner Of Pan: Aagcm1112L Income-Tax Vs. 7Th Floor, Z Tower, Patia Circle-12(1) Nandan Kanan Road, Kolkata. Bhubaneswar-751024. (Appellant) (Respondent) Present For: Appellant By : Shri Rajib Sharma & Shri Jai Somani, Ars Respondent By : Shri Sudipta Guha, Cit, Dr Date Of Hearing : 05.04.2022 Date Of Pronouncement : 04.07.2022 O R D E R Per Girish Agrawal: This Appeal By The Assessee Is Arising Out Of The Order Of Cit(A)-4, Kolkata In Appeal No. 491/Cit(A)-4/16-17 Dated 03.02.2020 Against The Assessment Order Of Dcit, Circle-12(1), Kolkata Passed U/S. 143(3) Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”) Dated 13.01.2017. 2. There Is A Delay Of 73 Days In Filing The Present Appeal For Which A Petition For Condonation Of Delay Is Placed On Record. From The Condonation Petition, We Note That The Present Appeal Ought To Have Been Filed On Or Before 17.04.2020 Which Falls During The Lockdown Period On Account Of Pandemic Of Covid-19. It Is Requested By The Assessee That Since It Is Prevented By Sufficient & Reasonable Cause, The Delay Of 73 Days In Filing The Appeal May Be Condoned & Appeal Be Admitted For Meritorious Disposal. We Have Heard Both The Sides & Find That Vide Order Dated 10.01.2022, Hon’Ble Supreme Court Has Directed That The Period From 15.03.2020 To 28.02.2022 Is To Be Excluded For The Purpose Of Computing The 2 Milk Mantra Dairy (P) Ltd. A.Y. 2013-14 Limitation Period During The Covid-19 Pandemic. Further, A Period Of 90 Days Is Allowed After 28.02.2022 Vide Same Order. Considering The Facts & The Explanation Of The Assessee, We Condone The Delay In Filing The Appeal & Admit It For Adjudication.

For Appellant: Shri Rajib Sharma & Shri Jai Somani, ARsFor Respondent: Shri Sudipta Guha, CIT, DR
Section 143(3)Section 56(2)(viib)

2 Milk Mantra Dairy (P) Ltd. A.Y. 2013-14 limitation period during the COVID-19 pandemic. Further, a period of 90 days is allowed after 28.02.2022 vide same order. Considering the facts and the explanation of the assessee, we condone the delay in filing the appeal and admit it for adjudication. 3. Grounds taken by the assessee in the present

BISWAJIT ROY,JALPAIGURI vs. ITO, WARD 1(1), , JALPAIGURI

Appeal is dismissed

ITA 866/KOL/2025[2018-2019]Status: DisposedITAT Kolkata02 Jul 2025AY 2018-2019

Bench: Him, In Limine, By Not Condoning A Delay Of 436 Days Before Him.

Section 115BSection 250Section 271ASection 69A

2. That I have been assessed to income-tax under PAN: AHMPR4323E. 3. That I had been assessed u/s 143(3) of the Income Tax Act, 1961 r/w section 1448 for Assessment Year 2018-19 by the Assessing Officer, National Faceless Assessment Centre, Delhi vide order date 30.8.2021. 4. That 30 (thirty) days thereafter was 29.9.2021, by which

I.T.O.,WARD-1(1), KOLKATA vs. M/S PCM STRESCON OVERSEAS VENTURE LTD., KOLKATA

In the result, both appeal preferred by the revenue (ITA No

ITA 2652/KOL/2019[2012-13]Status: DisposedITAT Kolkata25 Aug 2021AY 2012-13

Bench: Shri P. M. Jagtap & Shri A. T. Varkey]

Section 143(3)Section 144CSection 153Section 263

condone the delay and admit the appeal for hearing. ITA No.2652/Kol/2019 & CO No. 15/Kol/2020 PCM Strescon Overseas Ventures Ltd., AY 2012-13 2. At the outset, the Ld. A.R. for the assessee Shri Akkal Dudhwewala submitted that ITA No. 2652/Kol/2019 is preferred by the Revenue against the order of the Ld. CIT(A) for AY 2012-13 dated 24.07.2019, wherein

M/S PCM STRESCON OVERSEAS VENTURE LTD.,SILIGURI vs. PCIT-1, , KOLKATA

In the result, both appeal preferred by the revenue (ITA No

ITA 112/KOL/2021[2012-13]Status: DisposedITAT Kolkata25 Aug 2021AY 2012-13

Bench: Shri P. M. Jagtap & Shri A. T. Varkey]

Section 143(3)Section 144CSection 153Section 263

condone the delay and admit the appeal for hearing. ITA No.2652/Kol/2019 & CO No. 15/Kol/2020 PCM Strescon Overseas Ventures Ltd., AY 2012-13 2. At the outset, the Ld. A.R. for the assessee Shri Akkal Dudhwewala submitted that ITA No. 2652/Kol/2019 is preferred by the Revenue against the order of the Ld. CIT(A) for AY 2012-13 dated 24.07.2019, wherein

M/S MEDI DRIPS CARRIES PVT. LTD.,KOLKATA vs. ITO, WD-12(4), KOLKATA, KOLKATA

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

ITA 471/KOL/2014[2008-2009]Status: DisposedITAT Kolkata08 Mar 2017AY 2008-2009

Bench: Shri N.V.Vasudevan, Jm & Dr. A.L.Saini, Am आयकर अपील सं./Ita No.471/Kol/2014 ("नधा"रण वष" /Assessment Year:2008-2009) M/S Medi Drips Carries Pvt. Ltd Vs. Ito, Ward-12(4), 8Th Floor, R.No.818, P-7, Chowringhee Square, 4, Synagogue Street, Aayakar Bhawan, Kolkata-700001 Kolkata-700069 "थायी लेखा सं./जीआइआर सं./Pan/Gir No.: Aabcm 8139 Q .. (अपीलाथ" /Appellant) (""यथ" / Respondent) Assessee By : Shri Ashish Rustogi, Aca Revenue By : Shri Saurav Kumar, Jcit सुनवाई क" तार"ख / Date Of Hearing : 01/03/2017 घोषणा क" तार"ख/Date Of Pronouncement 08/03/2017 आदेश / O R D E R Per Dr. Arjun Lal Saini, Am: The Captioned Appeal Filed By The Assessee Pertaining To Assessment Year 2008-09, Is Directed Against The Order Passed By Ld. Cit(A)-Xii, Kolkata, In Appeal No.490/Xii/12(4)/10-11, Dated 11.11.2013, Which In Turn Arises Out Of An Order Passed By The Assessing Officer (Ao) Under Section 143(3) Of The Income Tax Act 1961, (Hereinafter Referred To As The ‘Act’), Dated 28.12.2010. 2. The Said Captioned Appeal Filed By The Assessee Is Time Barred By Four Days. The Assessee Filed The Petition For Condonation Of Delay & Expressed The Reasons Of Delay. After Verification Of Petition We Found That There Was A Reasonable Cause For Four Days Delay In Filing The Appeal. Even Ld Dr Did Not Object To Condone The Delay. Therefore, We Condone The Delay & Admit The Appeal For Hearing. 3. Brief Facts Of The Case Qua The Assessee Are That The Assessee Company Filed Its Return Of Income On 30.09.2008. Subsequently The 2 M/S Medi Drips Carries Pvt. Ltd. Assessee Company Filed Its Revised Return Of Income On 9-12-2008

For Appellant: Shri Ashish Rustogi, ACAFor Respondent: Shri Saurav Kumar, JCIT
Section 115Section 115JSection 143(3)

condone the delay and admit the appeal for hearing. 3. Brief facts of the case qua the assessee are that the assessee company filed its return of income on 30.09.2008. Subsequently the 2 M/s Medi Drips Carries Pvt. Ltd. assessee company filed its revised return of income on 9-12-2008 showing total loss at Rs.3

WEST BENGAL TRADE PROMOTION ORGANISATION LIMITED ,KOLKATA vs. ITO (EXEMPTION), WARD - 1(3), KOLKATA , KOLKATA

In the result, the appeal of the assessee is partly allowed

ITA 36/KOL/2018[2009-10]Status: DisposedITAT Kolkata28 Jul 2020AY 2009-10

Bench: Shri S.S.Godara, Jm &Dr. A.L.Saini, Am आयकरअपीलसं./Ita No.36/Kol/2018 ("नधा"रणवष" / Assessment Year:2009-10)

For Appellant: Shri B. R. Dutta, CA, Shri Saurabh Bagaria, Advocate & Shri RiteshFor Respondent: Shri I. Jamir, CIT, Sr. DR & Smt. Ranu Biswas, Addl. CIT
Section 11Section 12ASection 144Section 25

condonation of delay in seeking registration was not available. 19. This clearly goes to prove that the first proviso to section 12A(2) was brought in the statute only as a retrospective effect with a view not to affect genuine charitable trusts and societies carrying on genuine charitable objects in the earlier years and substantive conditions stipulated in section

ACIT, CIRCLE - 50(1), KOLKATA, KOLKATA vs. SHRI RANJIT KUMAR SAHA, KOLKATA

In the result, the appeal filed by the Revenue and cross objection filed by the Assesse, both are dismissed

ITA 2192/KOL/2017[2013-14]Status: DisposedITAT Kolkata30 Nov 2018AY 2013-14

Bench: Shri S. S. Ravi, J.M. & Dr.A.L.Saini, A.M.)

For Appellant: Shri Subash Agarwal, Advocate, ld.ARFor Respondent: Shri C.J. Singh, ld.Sr.DR
Section 131Section 143(3)Section 2(22)Section 2(22)(e)

condone the delay. 3. At the outset itself, the ld. Counsel for the assessee informed the Bench that the assessee does not want to press the cross objection, (CO. No. 40/Kol/2018 arising out of ITA No. 2192/Kol/2017 for the A.Y 2013-14). The ld. DR for the Revenue does not raise any objection. Therefore, we dismiss the Cross Objection filed

SUDHA DHOOT,KOLKATA vs. AO WARD 40 (4), KOLKATA

In the result, the appeal of the assessee is dismissed

ITA 127/KOL/2024[2018-19]Status: DisposedITAT Kolkata03 Jul 2024AY 2018-19

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishraassessment Year: 2018-19

For Appellant: Shri Ram Avtar Dhoot, CAFor Respondent: Smt Ranu Biswas, Addl. CIT, DR
Section 143(1)Section 21Section 250

2. Further to the power delegated to commissioner of Income Tax discussed above the CBDT here by directs that where there is delay of beyond 60 days in filling Form No. 36 for Assessment year. 2018-19 of for any subsequent Assessment year. The Pr. chief commissioner and applications of condonation of delay under section

RAMAKRISHNA RAO,KOLKATA vs. ITO, WARD-2(3), ALIPURDUAR

In the result, the appeal of the assessee is allowed

ITA 541/KOL/2024[2020-21]Status: DisposedITAT Kolkata12 Jun 2024AY 2020-21

Bench: Shri Sanjay Garg & Shri Rakesh Mishraassessment Year: 2020-21

For Appellant: Shri Siddarth Agarwal, AdvocateFor Respondent: Shri Sailen Samadder, Addl. CIT, Sr. DR
Section 143(1)Section 250Section 90

2. That thereafter, your petitioner, had filed a rectification petition and CPC had passed a rectification order on 03.08.2022 wherein they once again denied the relief claimed u/s 90 to the tune of Rs. 4,63,266/-. However, your petitioner was not aware of that rectification order since the same was not communicated to him either physically or through email

SRI UJJAL DUTTA ,BIRBHUM vs. ITO, WARD - 3(1), SURI , BIRBHUM

Appeals are allowed in above terms

ITA 2208/KOL/2017[2005-06]Status: DisposedITAT Kolkata27 Nov 2019AY 2005-06

Bench: Shri P.M. Jagtap, V.P & Shri S. S. Godara, Jm आयकर अपीलसं./I.T.A Nos.2208 & 2209/Kol/2017 ("नधा"रण वष" / Assessment Years: 2005-06 & 2005-06) Sri Ujjal Dutta Vs. Ito, Ward-3(1), Suri Netaji Subhas Rd. Bolpur, Birbhum. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Agtpd9357Q (Appellant) .. (Respondent) Appellant By : Shri Miraj D. Shah, Ar Respondent By : Smt. Ranu Biswas, Sr. Dr सुनवाईक"तार"ख/ Date Of Hearing : 24/09/2019 घोषणाक"तार"ख/Date Of Pronouncement : 27/11/2019 आदेश / O R D E R

For Appellant: Shri Miraj D. Shah, ARFor Respondent: Smt. Ranu Biswas, Sr. DR
Section 143(2)Section 147Section 148

condonation petition/affidavit dated 16.10.17 that his accountant in charge dealing with tax matters had quit the job without handing over all connected documents which could be found only in the year 2017. All these solemn averments have gone unrebutted from the Revenue’s side. It is fair enough in neither disputing the above factual averments nor the case law Collector

SRI UJJAL DUTTA ,BIRBHUM vs. ITO, WARD - 3(1), SURI , BIRBHUM

Appeals are allowed in above terms

ITA 2209/KOL/2017[2005-06]Status: DisposedITAT Kolkata27 Nov 2019AY 2005-06

Bench: Shri P.M. Jagtap, V.P & Shri S. S. Godara, Jm आयकर अपीलसं./I.T.A Nos.2208 & 2209/Kol/2017 ("नधा"रण वष" / Assessment Years: 2005-06 & 2005-06) Sri Ujjal Dutta Vs. Ito, Ward-3(1), Suri Netaji Subhas Rd. Bolpur, Birbhum. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Agtpd9357Q (Appellant) .. (Respondent) Appellant By : Shri Miraj D. Shah, Ar Respondent By : Smt. Ranu Biswas, Sr. Dr सुनवाईक"तार"ख/ Date Of Hearing : 24/09/2019 घोषणाक"तार"ख/Date Of Pronouncement : 27/11/2019 आदेश / O R D E R

For Appellant: Shri Miraj D. Shah, ARFor Respondent: Smt. Ranu Biswas, Sr. DR
Section 143(2)Section 147Section 148

condonation petition/affidavit dated 16.10.17 that his accountant in charge dealing with tax matters had quit the job without handing over all connected documents which could be found only in the year 2017. All these solemn averments have gone unrebutted from the Revenue’s side. It is fair enough in neither disputing the above factual averments nor the case law Collector

DREAMLAND EDUCATION SOCIETY,HOOGHLY vs. ACIT, CIR-2, HOOGHLY, HOOGHLY

In the result the appeals of the assessee are allowed for statistical purposes

ITA 489/KOL/2016[2005-2006]Status: DisposedITAT Kolkata10 Aug 2016AY 2005-2006

Bench: Hon’Ble Sri N.V.Vasudevan, Jm & Dr.Arjun Lal Saini, Am] I.T.A Nos. 489-495/Kol/2016 Assessment Years : 2005-06 To 2011-12

For Appellant: Shri S.K.Tulsiyan, AdvocateFor Respondent: Shri G.Mallikarjuna, CIT(DR)
Section 11Section 12ASection 12A(2)Section 148Section 148(1)Section 249(4)

2 3 ITA Nos.489-495/Kol/2016 Dreamland Education Society A.Yrs.2005-06 to 2011-12 3. There is a delay of 103 days in filing these appeals by the assessee. The delay in filing the appeals of the assessee has been explained by the assessee on the ground that on receipt of the impugned order of CIT(A) dated 30.09.2015 which

D.C.I.T CIR - 2,KOLKATA, KOLKATA vs. M/S AMRI HOSPITAL LTD, KOLKATA

In the result, Revenue’s appeal is partly allowed for statistical purpose and that of assessee’s CO is allowed for statistical purpose

ITA 807/KOL/2013[2009-10]Status: DisposedITAT Kolkata22 Mar 2017AY 2009-10

Bench: Shri Aby.T Varkey & Shri Waseem Ahmed

Section 115JSection 143(3)

condone the delay and admit the appeal for hearing. 5. The inter-connected issue raised by assessee in its CO is whether Ld. CIT(A) is justified in applying the provisions of Sec. 115JB of the Act though the assessee has declared loss in its income return under the normal provision of the Act. 6. At the outset

ACIT, CC-3(2), KOLKATA , KOLKATA vs. M/S. SNOWTEX INVESTMENT LTD., KOLKATA

In the result, the appeal of the Revenue is dismissed

ITA 1799/KOL/2017[2012-13]Status: DisposedITAT Kolkata27 Feb 2019AY 2012-13

Bench: Shri A. T. Varkey, J.M. & Dr.A.L.Saini, A.M.) Asstt. Year : 2012-13 A.C.I.T, Cc-3(2), Kolkata Vs M/S. Snowtex Investment Ltd. Pan: Aaecs 0334C (Assessee/Department) (Respondent/Assessee)

For Appellant: Shri S.K. Tulsiyan, Sr. Advocate, ld.ARFor Respondent: Shri Radhey Shyam, CIT, ld.DR
Section 143(3)Section 14ASection 2(24)(x)Section 36Section 36(1)(va)Section 43B

condone the delay and admit the appeals for adjudication. 3. The grievances raised by the Revenue are as follows:- 1. That on the facts and in the circumstances of the case, the Ld. CIT(A) has erred in law to hold that disallowance under section 14A read with rule 8D will not apply where no exempt income is received

NEETU AGARWAL,KOLKATA vs. INCOME TAX OFFICER - WARD 7(1), KOLKATA

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

ITA 67/KOL/2024[2020-21]Status: DisposedITAT Kolkata13 Sept 2024AY 2020-21

Bench: Shri Sanjay Garg & Shri Rakesh Mishraassessment Year: 2020-21

For Appellant: Puja Agarwal, C.AFor Respondent: Abhishek Kumar, JCIT, Sr. DR
Section 143(1)Section 154Section 234BSection 250Section 90

section 250 of the Income Tax Act. 1961 ('the Act') which is bad in law and liable to be quashed. 2 Dismissing the appeal without providing an opportunity of being heard and thus the order is violative of principles of natural justice and unsustainable in law. 2 Neetu Agarwal AY: 2020-21 3. Holding that the delay in filing

M/S. ELCON ESTATE PVT. LTD.,KOLKATA vs. I.T.O., WARD - 13(1), KOLKATA

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

ITA 2277/KOL/2024[2022-2023]Status: DisposedITAT Kolkata22 Apr 2025AY 2022-2023
Section 115BSection 143(1)Section 143(1)(a)Section 143(1)(b)Section 246

condoned the delay in filing Form 10-IC.\nConsequently, this ground of appeal is dismissed.\n7.2 It is essential to note that the appellant was not permitted to benefit\nfrom the new tax regime in the assessment year 2021-22. Consequently,\nthe appellant's claim of having opted for and being eligible for the new\nregime

DCIT, CC-1(4), KOLKATA, KOLKATA vs. JUPITER INTERNATIONAL LIMITED , KOLKATA

In the result, the appeal of the revenue is dismissed

ITA 1678/KOL/2025[2014-15]Status: DisposedITAT Kolkata21 Jan 2026AY 2014-15

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyassessment Year: 2014-15 Dcit, Cc-1(4), Kolkata ………….……………………….……….……….……Appellant Vs. Jupiter International Limited..……………………………….....……...…..…..Respondent Unnayanam, 20A, Ashutosh Chowdhury Avenue, Kol-19.. [Pan: Aaacj6956B] Appearances By: Shri P. N Barnwal, Cit-Dr, Appeared On Behalf Of The Appellant. Shri Soumitra Choudhury & Nandini Sureka, Advocate, Ar, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : November 12, 2026 Date Of Pronouncing The Order : January 21, 2026 Order Per Pradip Kumar Choubey: This Appeal Filed By The Revenue Is Directed Against The Order Dated 29.10.2024 Of The National Faceless Appeal Centre [‘Cit(A)’] Passed Under Section 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As “The Act”) For The Assessment Year 2014–15. 2. The Appeal Has Been Filed By The Revenue With A Delay Of 197 Days & The Revenue Has Filed A Petition For Condonation Of The Delay. After Going Over The Said Petition, We Find Sufficient Reasons Behind The Delay & Consequently, The Delay In Filing The Appeal Is Hereby Condoned & We Proceed To Dispose Of The Appeal On Merits.

Section 132Section 142(1)Section 143(2)Section 14ASection 153ASection 250Section 56(2)Section 56(2)(viib)

delay in filing the appeal is hereby condoned and we proceed to dispose of the appeal on merits. 3. Brief facts of the case are that the assessee company was established on 08.09.1978 and is engaged in the trading of computer peripherals and parts and manufacturing of CDR and DVDR. The Jupiter International Limited assessee company filed its original return

DCIT, CIR-5(1), KOLKATA, KOLKATA vs. M/S. PROFICIENT COMMODITIES PVT. LTD., KOLKATA

In the result, the cross objection filed by the assessee in CO No

ITA 1346/KOL/2016[2012-13]Status: DisposedITAT Kolkata18 Mar 2020AY 2012-13

Bench: Shri S.S.Godara, Jm &Dr. A.L.Saini, Am आयकरअपीलसं./Ita No.1346/Kol/2016 ("नधा"रणवष" / Assessment Year:2012-13)

For Appellant: Shri Ram Bilash Meena, CIT DRFor Respondent: Shri Somnath Ghosh, Advocate
Section 143(2)Section 143(3)

90,315/- being loss in National Multi Commodity Exchange (NMCE) when the disallowance was based on the information received from the Forward Markets Commissions(FMC) through I&CI wing that the assessee company had taken accommodation entries in form of bogus losses through NMCE and the same was independently adjudicated. 2. Whether on the facts and in the circumstances

D.C.I.T.,CIRCLE-6(1), KOLKATA vs. SHRI SAROJ KUMAR PODDAR, KOLKATA

In the result, the appeal of the Revenue is dismissed as not maintainable

ITA 2406/KOL/2019[2014-15]Status: DisposedITAT Kolkata29 Jun 2021AY 2014-15

Bench: Shri J. Sudhakar Reddy, Hon’Ble & Shri Aby T. Varkey, Hon’Ble]

Section 250

2)(vii) of the Act. He subm the taxability of the compensation u/s 56(2)(vii) of the Act. He submits that the averments of its that the averments of the special counsel before the Tribunal were his personal/private views and not the views of the special counsel before the Tribunal were his personal/private views and not the views