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125 results for “section 68”+ Section 10(22)clear

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Key Topics

Section 1182Addition to Income75Section 12A46Section 6846Section 26342Section 143(3)39Exemption37Section 14833Section 14731Section 2(15)

ACIT, RANGE-1, LUCKNOW vs. MAA RAKTDANTIKA CONTRACTORS AND SUPPLIERS PVT. LTD., LUCKNOW

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

ITA 437/LKW/2020[2017-18]Status: DisposedITAT Lucknow30 Sept 2024AY 2017-18

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

Section 143(3)Section 28(2)(i)Section 68

10. 9.5 From the above, we note that the provisions of section 68 of the Act can be attracted where there is a credit found in the books of accounts and the assessee failed to offer any explanation or the offer made by the assessee is not satisfactory in the opinion of the assessing officer. The assessee has explained

M/S. MAA RAKLTDANTIKA CONTRACTORS AND SUPPLIERS PVT. LTD.,,LUCKNOW vs. THE DCIT/ACIT, RANGE-4, LUCKNOW

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

Showing 1–20 of 125 · Page 1 of 7

30
Disallowance26
Natural Justice25
ITA 384/LKW/2020[2017-18]Status: DisposedITAT Lucknow30 Sept 2024AY 2017-18

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

Section 143(3)Section 28(2)(i)Section 68

10. 9.5 From the above, we note that the provisions of section 68 of the Act can be attracted where there is a credit found in the books of accounts and the assessee failed to offer any explanation or the offer made by the assessee is not satisfactory in the opinion of the assessing officer. The assessee has explained

M/S. MOTOR FAB SALES PVT. LTD.,,LUCKNOW vs. THE DCIT/ACIT-4, LUCKNOW

In the result, Departmental appeal bearing

ITA 351/LKW/2020[2017-18]Status: DisposedITAT Lucknow30 Jun 2025AY 2017-18

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudharyassessment Year: 2017-18 M/S Motor Fab Sales Pvt. Ltd. V. The Dcit/Acit-4 11, Mahatma Gandhi Marg Lucknow Hazratganj, Lucknow Tan/Pan:Aaccm5754E (Appellant) (Respondent) Assessment Year: 2017-18 Theacit-1 V. M/S Motor Fab Sales Pvt. Ltd. Lucknow 11, Mahatma Gandhi Marg Hazratganj, Lucknow Tan/Pan:Aaccm5754E (Appellant) (Respondent) Assessee By: Shri Rakesh Garg, Advocate Revenue By: Shri H.S. Usmani, Cit(Dr)

For Appellant: Shri Rakesh Garg, AdvocateFor Respondent: Shri H.S. Usmani, CIT(DR)
Section 115BSection 143(3)Section 68

section 68 of the Act. 4.2 The Ld. A.R. also drew our attention to a compilation of case laws in support of his arguments and submitted that these case laws may be duly considered while adjudicating the issue. The list of case laws relied upon by the Ld. A.R. is as under: Sl. Details of case

ACIT, RANGE-1, LUCKNOW vs. MOTOR FAB SALES PVT. LTD., LUCKNOW

In the result, Departmental appeal bearing

ITA 431/LKW/2020[2017-18]Status: DisposedITAT Lucknow30 Jun 2025AY 2017-18

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudharyassessment Year: 2017-18 M/S Motor Fab Sales Pvt. Ltd. V. The Dcit/Acit-4 11, Mahatma Gandhi Marg Lucknow Hazratganj, Lucknow Tan/Pan:Aaccm5754E (Appellant) (Respondent) Assessment Year: 2017-18 Theacit-1 V. M/S Motor Fab Sales Pvt. Ltd. Lucknow 11, Mahatma Gandhi Marg Hazratganj, Lucknow Tan/Pan:Aaccm5754E (Appellant) (Respondent) Assessee By: Shri Rakesh Garg, Advocate Revenue By: Shri H.S. Usmani, Cit(Dr)

For Appellant: Shri Rakesh Garg, AdvocateFor Respondent: Shri H.S. Usmani, CIT(DR)
Section 115BSection 143(3)Section 68

section 68 of the Act. 4.2 The Ld. A.R. also drew our attention to a compilation of case laws in support of his arguments and submitted that these case laws may be duly considered while adjudicating the issue. The list of case laws relied upon by the Ld. A.R. is as under: Sl. Details of case

M/S U.P AWAS EVAM VIKAS PARISHAD,LUCKNOW vs. DEPUTY COMMISSIONER OF INCOME TAX (EXEMPTION), LUCKNOW

In the result, the appeals of the assessee are partly allowed whereas the Cross Objections of the Revenue are partly allowed for statistical purposes

ITA 166/LKW/2019[2016-17]Status: DisposedITAT Lucknow10 Jun 2022AY 2016-17

Bench: Shri A. D. Jain & Shri T. S. Kapoor

Section 11Section 12Section 12ASection 13(8)Section 2(15)

section 10(46) of the Act, introduced by the statute by the Finance Act 2011, the specified income arising to a body or trust or Board or Trust or Commission, which has been established or constituted by a Central or a State Act, for any activity for the benefit of general public and which is not engaged

M/S U.P AWAS EVAM VIKAS PARISHAD,LUCKNOW vs. DEPUTY COMMISSIONER OF INCOME TAX (EXEMPTION), LUCKNOW

In the result, the appeals of the assessee are partly allowed whereas the Cross Objections of the Revenue are partly allowed for statistical purposes

ITA 701/LKW/2019[2017-18]Status: DisposedITAT Lucknow10 Jun 2022AY 2017-18

Bench: Shri A. D. Jain & Shri T. S. Kapoor

Section 11Section 12Section 12ASection 13(8)Section 2(15)

section 10(46) of the Act, introduced by the statute by the Finance Act 2011, the specified income arising to a body or trust or Board or Trust or Commission, which has been established or constituted by a Central or a State Act, for any activity for the benefit of general public and which is not engaged

M/S U.P AWAS EVAM VIKAS PARISHAD,LUCKNOW vs. DEPUTY COMMISSIONER OF INCOME TAX (EXEMPTION), LUCKNOW

In the result, the appeals of the assessee are partly allowed whereas the Cross Objections of the Revenue are partly allowed for statistical purposes

ITA 165/LKW/2019[2015-16]Status: DisposedITAT Lucknow10 Jun 2022AY 2015-16

Bench: Shri A. D. Jain & Shri T. S. Kapoor

Section 11Section 12Section 12ASection 13(8)Section 2(15)

section 10(46) of the Act, introduced by the statute by the Finance Act 2011, the specified income arising to a body or trust or Board or Trust or Commission, which has been established or constituted by a Central or a State Act, for any activity for the benefit of general public and which is not engaged

DEPUTY COMMISSIONER OF INCOME TAX (EXEMPTION), LUCKNOW vs. INDIAN INSTITUTE OF MANAGEMENT ,, LUCKNOW

In the result, the appeal of the Revenue is dismissed

ITA 561/LKW/2018[2010-11]Status: DisposedITAT Lucknow22 Aug 2019AY 2010-11

Bench: Shri. A. D. Jain & Shri T. S. Kapoorassessment Year: 2010-11 Dy. Cit (Exemptions) V. M/S Indian Institute Of Management Lucknow Lucknow Off Sitapur Road, Prabandh Nagar Lucknow Tan/Pan:Aaati2622Q (Appellant) (Respondent) Appellant By: Shri S. K. Madhuk, Cit (Dr) Respondent By: Shri Ashish Kapoor, C.A. Date Of Hearing: 20 08 2019 Date Of Pronouncement: 22 08 2019 O R D E R Per A. D. Jain, V.P.: This Is Revenue’S Appeal Against The Order Of The Ld. Cit(A), Lucknow, Dated 8/5/2018, For The Assessment Year 2010-11, Taking The Following Grounds Of Appeal: 1. Ld. Commissioner Of Income Tax (A) Has Erred In Law & Facts By Allowing The Appeal Of The Assessee & Deleting The Addition Of Rs.4,05,76,925/- Made On Account Of The Assessee Had Not Maintained Separate Books Of Accounts In Respect Of The Business Activities, Which Are Not Incidental To The Objectives Of The Society. 2. Ld. Commissioner Of Income Tax (A) Has Erred In Law & Facts By Following Other Year'S Appellate Order & Thereby

For Appellant: Shri S. K. Madhuk, CIT (DR)For Respondent: Shri Ashish Kapoor, C.A
Section 10

22 08 2019 O R D E R PER A. D. JAIN, V.P.: This is Revenue’s appeal against the order of the ld. CIT(A), Lucknow, dated 8/5/2018, for the Assessment Year 2010-11, taking the following grounds of appeal: 1. Ld. Commissioner of Income Tax (A) has erred in law and facts by allowing the appeal

SMT. SABREEN,KANPUR vs. INCOME TAX OFFICER-3(4), KANPUR

In the result, the appeal of the assessee stands partly allowed and Stay Application is dismissed as infructuous

ITA 498/LKW/2019[2014-15]Status: DisposedITAT Lucknow19 Jul 2021AY 2014-15

Bench: Shri A. D. Jain & Shri T. S. Kapoor

Section 10Section 10(38)Section 144Section 38

10(38) of the Act and to assess the sale proceeds of shares as undisclosed income of the assessee under section 68 of the Act :- (i) ITO vs. Ashok Kumar Bansal – ITA No. 289/Agr/2009 (Agra ITAT) (ii) ACIT vs.Amita Agarwal & Others - ITA Nos. 247/(Kol)/ of 2011 (Kol ITAT) (iii) Lalit Mohan Jalan (HUF) vs. ACIT – ITA No. 693/Kol/2009

ASSISTANT COMMISIONER OF INCOME TAX, CENTRAL CIRCLE, BAREILLY, BAREILLY vs. MOHIT ANAND, BAREILLY

Appeals of the Department stand dismissed

ITA 334/LKW/2025[2015-16]Status: DisposedITAT Lucknow13 Feb 2026AY 2015-16

Bench: Shri Sudhanshu Srivastava & Shri Nikhil Choudharyit(Ss) A Nos.336 & 337/Lkw/2025 Assessment Years: 2014-15 & 2015-16 Acit, Central Circle, Bareilly Vs. Ankur Anand Kamla Nehru Marg, Civil Lines, 148 Civil Lines, Bareilly, Bareilly, Bareilly-243001. Bareilly-243001. Tan/Pan:Agppa4219C (Appellant) (Respondent) It(Ss)A No.334/Lkw/2025 Assessment Year:2015-16 Acit, Central Circle, Bareilly Vs. Mohit Anand Kamla Nehru Marg, Civil Lines, 148 Civil Lines, Bareilly, Bareilly, Bareilly-243001. Bareilly-243001. Tan/Pan:Abupa3002H (Appellant) (Respondent)

For Appellant: Shri Neeraj Kumar, CIT (DR)For Respondent: Shri Rakesh Garg, Advocate
Section 10(38)Section 132Section 143(3)Section 153ASection 68

10(38) of the Act to the tune of Rs. 11,23,13,046/- on the sale of scrip Prem Cap for Rs. 11,53,13,047/- which was purchased for Rs. 30,00,000/-. On identical reasoning as in the two earlier cases, the AO went on to hold that the amount of LTCG being claimed as exempt

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, BAREILLY, BAREILLY vs. ANKUR ANAND, BAREILLY

Appeals of the Department stand dismissed

ITA 336/LKW/2025[2014-15]Status: DisposedITAT Lucknow13 Feb 2026AY 2014-15

Bench: Shri Sudhanshu Srivastava & Shri Nikhil Choudharyit(Ss) A Nos.336 & 337/Lkw/2025 Assessment Years: 2014-15 & 2015-16 Acit, Central Circle, Bareilly Vs. Ankur Anand Kamla Nehru Marg, Civil Lines, 148 Civil Lines, Bareilly, Bareilly, Bareilly-243001. Bareilly-243001. Tan/Pan:Agppa4219C (Appellant) (Respondent) It(Ss)A No.334/Lkw/2025 Assessment Year:2015-16 Acit, Central Circle, Bareilly Vs. Mohit Anand Kamla Nehru Marg, Civil Lines, 148 Civil Lines, Bareilly, Bareilly, Bareilly-243001. Bareilly-243001. Tan/Pan:Abupa3002H (Appellant) (Respondent)

For Appellant: Shri Neeraj Kumar, CIT (DR)For Respondent: Shri Rakesh Garg, Advocate
Section 10(38)Section 132Section 143(3)Section 153ASection 68

10(38) of the Act to the tune of Rs. 11,23,13,046/- on the sale of scrip Prem Cap for Rs. 11,53,13,047/- which was purchased for Rs. 30,00,000/-. On identical reasoning as in the two earlier cases, the AO went on to hold that the amount of LTCG being claimed as exempt

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, BAREILLY, BAREILLY vs. ANKUR ANAND, BAREILLY

Appeals of the Department stand dismissed

ITA 337/LKW/2025[2015-16]Status: DisposedITAT Lucknow13 Feb 2026AY 2015-16

Bench: Shri Sudhanshu Srivastava & Shri Nikhil Choudharyit(Ss) A Nos.336 & 337/Lkw/2025 Assessment Years: 2014-15 & 2015-16 Acit, Central Circle, Bareilly Vs. Ankur Anand Kamla Nehru Marg, Civil Lines, 148 Civil Lines, Bareilly, Bareilly, Bareilly-243001. Bareilly-243001. Tan/Pan:Agppa4219C (Appellant) (Respondent) It(Ss)A No.334/Lkw/2025 Assessment Year:2015-16 Acit, Central Circle, Bareilly Vs. Mohit Anand Kamla Nehru Marg, Civil Lines, 148 Civil Lines, Bareilly, Bareilly, Bareilly-243001. Bareilly-243001. Tan/Pan:Abupa3002H (Appellant) (Respondent)

For Appellant: Shri Neeraj Kumar, CIT (DR)For Respondent: Shri Rakesh Garg, Advocate
Section 10(38)Section 132Section 143(3)Section 153ASection 68

10(38) of the Act to the tune of Rs. 11,23,13,046/- on the sale of scrip Prem Cap for Rs. 11,53,13,047/- which was purchased for Rs. 30,00,000/-. On identical reasoning as in the two earlier cases, the AO went on to hold that the amount of LTCG being claimed as exempt

UP GOVERNMENT EMPLOYEES WELFARE,LUCKNOW vs. ACIT, NFAC, DELHI, DELHI

In the result appeals in ITA No

ITA 743/LKW/2024[2017-18]Status: DisposedITAT Lucknow30 Apr 2025AY 2017-18

Bench: Sh. Kul Bharat & Sh. Nikhil Choudharyita Nos.743 & 746/Lkw/2024 & Ita No. 30/Lkw/2024 A.Y. 2017-18 U.P. Government Employees Vs. Assessing Officer, Nfac Welfare, Lucknow Pan:Aaatu0957A (Appellant) (Respondent) Assessee By: None Revenue By: Sh. Manu Chaurasia, Cit (Dr) Date Of Hearing: 15.04.2025 Date Of Pronouncement: 30.04.2025 O R D E R Per Bench.: These Three Appeals Have Been Filed By The Assessee Against The Orders Passed By The Ld. Cit(A), Nfac On 23.10.2024, 28.10.2024 & 2.01.2024 In The Appeals Preferred Against The Assessment Order Under Section 143(3), The Penalty Order Under Section 271Aac(1) & The Penalty Order Under Section 270A. The Grounds Of Appeal In These Three Appeals Are As Under:-

For Appellant: NoneFor Respondent: Sh. Manu Chaurasia, CIT (DR)
Section 143(3)Section 2(24)(x)Section 234ASection 270ASection 271ASection 36(1)(va)Section 40Section 68

68 of I.T. Act, 1961 when these have been shown in Profit & Loss Account and declared in I.T.R., it is biased, bad in law because of the facts and circumstances of the case. 3. That the Learned Commissioner of Income tax (A) erred in law and on facts and add Interest on Unsecured Loan of Rs. 7018853/-. 4. That

ROHILKHAND EDUCATIONAL CHARITABLE TRUST,BAREILLY vs. DCIT, CENTRAL CIRCLE, BAREILLY

In the result, both appeals of the assessee in ITA No

ITA 181/LKW/2024[2017-18]Status: DisposedITAT Lucknow22 Sept 2025AY 2017-18

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudharyita Nos.181 & 182/Lkw/2024 A.Ys.2017-18 & 2018-19 Rohilkhand Educational Vs. Dcit, Charitable Trust, Bareilly Central Circle, Bareilly Pan: Aaatr6902J (Appellant) (Respondent) Assesseeby: Sh. Rakesh Garg, Adv Revenue By: Sh. S.H. Usmani, Cit Dr Date Of Hearing: 14.08.2025 Date Of Pronouncement: 22.09.2025 O R D E R Per Bench: [ These Two Appeals Have Been Filed By The Assessee Against The Separate Orders Of The Ld. Cit(A)-3, Lucknow Dated 19.03.2024 & 22.03.2024, Passed Under Section 250 Of The Income Tax Act, 1961, For The A.Ys. 2017-18 & 2018-19, Dismissing The Appeals Of The Assessee Against Orders Passed By The Assessing Officer Under Section 143(3) Of The Income Tax Act, 1961. The Grounds Of Appeal Are As Under:- “(1).That The Ld. Authorities Below Have Erred In Law As Well As On Facts In Not Considering The Fact That In The Alleged Assessment Order, The Columns Of Name Of Assessee, Pan, Asst Year, Date Of Assessment & Section Under Which Passed, Are Blank. (2)That The Ld. Authorities Below Have Erred In Law As Well As On Facts In Treating The Demand As Valid Which Was Not Computed On The Basis Of Orderthat May Not Be Termed To Be An Order Under Section 143(3). (3) That A Demand Of Tax As Computed In The Computation Sheet Is Without Jurisdiction Void-Ab-Inito & Is Liable To Be Annulled. (4) That The Ld. Authorities Below Have Erred In Law As Well As On Facts In Confirming The Addition Of Rs. 736591857/-Comprising  Corpus Donation Aggregating To Rs 7,68,95,000/-, A.Ys. 2017-18 & 2018-19

For Appellant: Sh. Rakesh Garg, AdvFor Respondent: Sh. S.H. Usmani, CIT DR
Section 11Section 11(1)Section 11(2)Section 12ASection 13(3)Section 143(3)Section 250Section 80GSection 80G(5)

10 stating the general purpose for accumulation. We believe the answer to this question lies in the provisions of section 11(3A). Section 11(3A) of the Act reads that, where due to circumstances beyond the control of a person in receipt of income, which has been invested or deposited in accordance with the provisions of clause

PRADEEP KUMAR,LUCKNOW vs. ACIT-1, LUCKNOW

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

ITA 198/LKW/2024[2017-18]Status: DisposedITAT Lucknow04 Sept 2024AY 2017-18

Bench: Shri G. D. Padamahshali & Shri Subhash Malguriaassessment Year: 2017-18 Pradeep Kumar V. The Acit-1 A-1/46, Vikas Khand Lucknow Gomti Nagar Lucknow Pan:Ablpk8392B (Appellant) (Respondent) Appellant By: Shri Vijay Prakash Agrawal, Adv. Respondent By: Shri Sanjeev Krishna Sharma, D.R. Date Of Hearing: 10 07 2024 Date Of Pronouncement: 04 09 2024 O R D E R

For Appellant: Shri Vijay Prakash Agrawal, AdvFor Respondent: Shri Sanjeev Krishna Sharma, D.R
Section 143(3)Section 37Section 68

22 to 26 of the paper book. The Assessing Officer after verification of the details so furnished by the assessee, made an addition of Rs.1,50,00,000/- under section 68 of the Act, on random basis on a presumption that the same was generated in old SBNs during the demonetization period, as in the opinion of the Assessing

DY. COMMISSIONER OF INCOME TAX (EXEMPTION), LUCKNOW vs. M/S SHRI RAMSWAROOP CHARITABLE TRUST, LUCKNOW

In the result, appeal of the Revenue is dismissed

ITA 557/LKW/2017[2013-14]Status: DisposedITAT Lucknow08 Mar 2019AY 2013-14

Bench: Shri A.D Jain & Shri T.S. Kapoora.Y. 2013-14

Section 11Section 32Section 68

10] Further section 68 had no application to the facts of the instant case because the assessee had in fact disclosed the donations as its income and it could not be disputed that all receipts, other than corpus donations, would be income in the hands of the assessee. There was, therefore, full disclosure of income by the assessee

DY. COMMISSIONER OF INCOME TAX (EXEMPTION), LUCKNOW vs. M/S SHRI RAMSWAROOP CHARITABLE TRUST, LUCKNOW

In the result, appeal of the Revenue stands dismissed

ITA 557/LKW/2018[2014-15]Status: DisposedITAT Lucknow28 Jun 2019AY 2014-15

Bench: Shri A. D. Jain & Shri T. S. Kapoorassessment Year:2014-2015

Section 11

22 unaccounted money by way of donation receipts. That was more particularly so in the facts of the case where admittedly, more than 75 per cent of the donations were applied for charitable purposes. [Para 10] Further section 68

MAHESH MITTAL,LUCKNOW vs. ACIT, RANGE-5, LUCKNOW, LUCKNOW

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

ITA 73/LKW/2023[2014-15]Status: DisposedITAT Lucknow14 Aug 2025AY 2014-15

Bench: Shri Kul Bharat & Shri Anadee Nath Misshramahesh Mittal V. Acit, Range-5 1/16, Vinay Khand Gomti Income Tax Office Ashok Nagar, Lucknow-226010. Marg, Lucknow-226001. Pan:Acqpm4459B (Appellant) (Respondent) Appellant By: Shri Akshay Agarwal, Adv Respondent By: Shri Amit Singh Chauhan, Cit(Dr) O R D E R

For Appellant: Shri Akshay Agarwal, AdvFor Respondent: Shri Amit Singh Chauhan, CIT(DR)
Section 10(38)Section 68

Section 68 of the Act. 11)That, the Appellant craves leave to alter, amend, add or delete one or all the Grounds of appeals mentioned above.” Page 3 of 31 (B). In this case, assessment order dated 27.03.2023 was passed by the Assessing Officer u/s 143(3) of the Income Tax Act, 1961 (“Act”, for short) whereby the assessee

INCOME TAX OFFICER-3(4), KANPUR vs. SHRI SANTOSH KUMAR AGARWAL, KANPUR

In the result, the appeal of the Revenue is dismissed

ITA 153/LKW/2020[2014-15]Status: DisposedITAT Lucknow17 Feb 2022AY 2014-15

Bench: Shri T. S. Kapoor

Section 10(38)Section 143(3)Section 69A

Section 68 of the Act. Upon appeal the assessee adduced evidence in the shape of contract notes/bills receipt; payments made through I.T.A. No.153/Lkw/2020 Assessment. Year:2014-15 17 banking channel; contract notes and; copies of passbook of its Demat account in support of it thus asserted its claim of long term capital gain as genuine and correct

M/S. SAHARA CITY HOMES,BAREILLY vs. INCOME TAX OFFICER - 3(4), RANGE- 3, LUCKNOW

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

ITA 24/LKW/2019[2012-13]Status: DisposedITAT Lucknow31 Jan 2022AY 2012-13

Bench: Shri. A. D. Jain & Shri T. S. Kapoorassessment Year: 2012-13 M/S Sahara City Homes – Bareilly V. Ito-3(4) 2, Sahara India Centre Range 3 Kapoorthala Complex Lucknow Aliganj, Lucknow Tan/Pan:Abzfs2472C (Appellant) (Respondent) Assessment Year: 2012-13 M/S Sahara City Homes – Amritsar V. Ito-3(4) 2, Sahara India Centre Lucknow Tan/Pan:Abzfs4654E (Appellant) (Respondent) Assessment Year: 2012-13 M/S Sahara City Homes – Kanpur(I) V. Acit 2, Sahara India Centre Range 3 Kapoorthala Complex Lucknow Aliganj, Lucknow Tan/Pan:Abzfs2468Q (Appellant) (Respondent) Assessment Year: 2012-13 M/S Sahara City Homes – Guwahati V. Acit 2, Sahara India Centre Range 3 Kapoorthala Complex Lucknow Aliganj, Lucknow Tan/Pan:Abzfs2462E (Appellant) (Respondent)

10 of 46 under section 69C of the Act, which was confirmed by the ld. CIT(A). This forms the issue in Ground No. 4. 14. The ld. CIT(A) directed the Assessing Officer to issue notice under section 148 of the Act, for Assessment Year 2011- 12, on a protective basis. Ground no.5 challenges this action