ACIT, RANGE-1, LUCKNOW vs. M/S MAHENDRA EDUCATIONAL PVT. LTD., LUCKNOW

In the result, the appeal is dismissed for statistical purposes

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

section 68 of the I.T. Act on account of cash deposits made by the assessee during demonetization period. On perusal of records, it is found that the I.T.A. No.433/Lkw/2020 Assessment Year:2017-18 12 Assessing Officer has accepted the books of account; and no defects have been pointed out either by the Assessing Officer or by the learned

M/S. APCO INFRATECH PVT. LTD.,,LUCKNOW vs. ACIT-I, LUCKNOW

In the result, appeals vide I

section 14A read with Rule 8D was made\nsolely on the basis of investment by Assessee Company in SPVs without\nverifying objects of investment and understanding of relevant provision of law.\nIt is also submitted that section 14A carries heading 'Expenditure\nincurred in relation to income not includible in total income'\n\nAs per Section

ACIT, RANGE-I, LUCKNOW vs. M/S APCO INFRATECH PVT. LTD.,, LUCKNOW

section 144(2) of the Act,\nAssessing Officer is duty bound to record his/her dissatisfaction on correctness\nof claim of assessee before invoking the provision of section 144. As it is\nevident from language of section 144 as well as of rule 8D, recording of the\ndissatisfaction of Assessing officer as regard to correctness of claim

ACIT, RANGE-I, LUCKNOW vs. M/S APCO INFRATECH PVT. LTD., LUCKNOW

section 251 of the IT Act, 1961 by\ndirecting the Assessing Officer to verify the claim made by the\nassessee u/s 80IA which amounts to setting aside the issue\nwhich is not permissible as per provisions of the aforesaid\nsection.\n\n2.\nThe Ld. CIT (A) has erred in law and on facts by deleting the\ndisallowance of Rs.2