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45 results for “charitable trust”+ Section 40A(3)clear

Sorted by relevance

Delhi71Mumbai45Chennai23Bangalore21Chandigarh15Amritsar11Visakhapatnam11Pune10Kolkata10Jaipur10Ahmedabad8Surat8Rajkot6Cuttack4Hyderabad3Indore2Nagpur2Jodhpur1Dehradun1Agra1Karnataka1Patna1Telangana1Varanasi1

Key Topics

Section 1144Section 4034Addition to Income30Disallowance29Section 153A28Section 14A18Section 13(3)17Deduction15Exemption13Section 271(1)(c)

PEGASUS PROPERTIES P. LTD.,PUNE vs. DY CIT, CC-2(3), MUMBAI

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

ITA 943/MUM/2021[2015-16]Status: DisposedITAT Mumbai19 May 2022AY 2015-16

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Pavan Kumar Gadale, Hon'Ble

For Appellant: Shri Rajan VoraFor Respondent: Shri Dhramveer Singh
Section 153Section 153ASection 153CSection 22Section 23Section 23(4)

3 June 2010 (only relevant extract enclosed) - Circular 7 of 2010 - Association for Advocacy and Legal Initiates vs CIT (2011) 130 ITD 573 (Lucknow Tribunal) dated 28 February 2011 - Shri Vishav Namdhari Sangat Vs CIT (ITA No. 805/Chd/2011 dated 17 May 2012) (Chandigarh Tribunal) In relation to the Trust al Himmatial Charitable Trust Judicial precedents in the context of approvals

Showing 1–20 of 45 · Page 1 of 3

12
Section 12A12
Section 13(1)(c)11

MEDIA RESEARCH USERS COUNCIL,MUMBAI vs. ADIT (E) 1(1), MUMBAI

Appeal of the revenue is dismissed

ITA 6459/MUM/2012[2006-07]Status: DisposedITAT Mumbai29 Mar 2022AY 2006-07

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Pavan Kumar Gadale, Hon'Ble & Media Research Users Council V. Addl. Dit(E)– 1(1) 128, Tv Industrial Estate Piramal Chambers, Lalbaug S.K. Ahire Marg, Worli Mumbai – 400 012 Mumbai – 400012 Pan: Aaatm5433F (Appellant) (Respondent) Media Research Users Council V. Addl. Dit(E)– Range 1 128, Tv Industrial Estate Piramal Chambers, Lalbaug S.K. Ahire Marg, Worli Mumbai – 400 012 Mumbai – 400012 Pan: Aaatm5433F (Appellant) (Respondent)

For Appellant: Shri Niraj ShethFor Respondent: Shri C.T. Mathews
Section 11Section 12ASection 13Section 13(1)(c)Section 13(3)(e)Section 25

trust directly or indirectly for the benefit of any person referred to in section 133 Nothing contained in section 11 for section 12 shall operate as per the provisions of the section 13 of the Act. Therefore, the assessee is not entitled to the benefits of section 11 of the Act. 11 Media Research Users Council 6.15 The courts have

MEDIA RESEARCH USERS COUNCIL,MUMBAI vs. ADDL DIT (E) RG 1, MUMBAI

Appeal of the revenue is dismissed

ITA 7108/MUM/2010[2007-08]Status: DisposedITAT Mumbai29 Mar 2022AY 2007-08

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Pavan Kumar Gadale, Hon'Ble & Media Research Users Council V. Addl. Dit(E)– 1(1) 128, Tv Industrial Estate Piramal Chambers, Lalbaug S.K. Ahire Marg, Worli Mumbai – 400 012 Mumbai – 400012 Pan: Aaatm5433F (Appellant) (Respondent) Media Research Users Council V. Addl. Dit(E)– Range 1 128, Tv Industrial Estate Piramal Chambers, Lalbaug S.K. Ahire Marg, Worli Mumbai – 400 012 Mumbai – 400012 Pan: Aaatm5433F (Appellant) (Respondent)

For Appellant: Shri Niraj ShethFor Respondent: Shri C.T. Mathews
Section 11Section 12ASection 13Section 13(1)(c)Section 13(3)(e)Section 25

trust directly or indirectly for the benefit of any person referred to in section 133 Nothing contained in section 11 for section 12 shall operate as per the provisions of the section 13 of the Act. Therefore, the assessee is not entitled to the benefits of section 11 of the Act. 11 Media Research Users Council 6.15 The courts have

MMTIS EDUCATION AND RESEARCH TRUST,MUMBAI vs. ITO (E) 2(1), MUMBAI

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

ITA 2974/MUM/2017[2012-13]Status: DisposedITAT Mumbai23 Jun 2023AY 2012-13

Bench: Shri Vikas Awasthy () & Shri Om Prakash Kant () Assessment Year: 2011-2012 Mmti’S Education & Research Trust, The Dy. Director Of Income- New Excel House, 2Nd Floor, 41-B, Tax(Exemption)-I(1), Vs. Azad Nagar Road No. 2, Off. Veera 5Th Floor, Piramal Chambers, Desai Road, Behind Icici Bank, Parel, Lalbaug, Andheri (West), Mumbai-400012. Mumbai-400053. Pan No. Aabtm 2192 E Appellant Respondent Assessment Year: 2012-2013 Mmti’S Education & Research Trust, Ito(E)-2(1), New Excel House, 2Nd Floor, 41-B, Income-Tax Office, Piramal Vs. Azad Nagar Road No. 2, Off. Veera Chambers, Parel, Mumbai- Desai Road, Behind Icici Bank, 12. Andheri (West), Mumbai-400053. Pan No. Aabtm 2192 E Appellant Respondent Assessment Year: 2013-2014 Mmti’S Education & Research Trust, Ito(E)-2(1), Victor House, 2Nd Floor, End Of Veera Income-Tax Office, Piramal Vs. Desai Road, Next To Chitralekha Chambers, Parel, Mumbai- House, Andheri (W), 12. Mumbai-400053. Pan No. Aabtm 2192 E Appellant Respondent

For Appellant: Ms. Arati Vissanji, Adv &For Respondent: Mr. Manish Ajudiya
Section 13(1)(c)Section 13(3)

charitable institution with the Income Department in terms of section 12AA of the Income-tax Act, 1961 Department in terms of section 12AA of the Income Department in terms of section 12AA of the Income (in short ‘the Act’) dated 09.09.2004. (in short ‘the Act’) dated 09.09.2004. During relevant year, t During relevant year, the assessee trust was engaged

MMTIS EDUCTION & RESEARCH TRUST,MUMBAI vs. DDIT (E) I(2), MUMBAI

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

ITA 5866/MUM/2015[2011-12]Status: DisposedITAT Mumbai23 Jun 2023AY 2011-12

Bench: Shri Vikas Awasthy () & Shri Om Prakash Kant () Assessment Year: 2011-2012 Mmti’S Education & Research Trust, The Dy. Director Of Income- New Excel House, 2Nd Floor, 41-B, Tax(Exemption)-I(1), Vs. Azad Nagar Road No. 2, Off. Veera 5Th Floor, Piramal Chambers, Desai Road, Behind Icici Bank, Parel, Lalbaug, Andheri (West), Mumbai-400012. Mumbai-400053. Pan No. Aabtm 2192 E Appellant Respondent Assessment Year: 2012-2013 Mmti’S Education & Research Trust, Ito(E)-2(1), New Excel House, 2Nd Floor, 41-B, Income-Tax Office, Piramal Vs. Azad Nagar Road No. 2, Off. Veera Chambers, Parel, Mumbai- Desai Road, Behind Icici Bank, 12. Andheri (West), Mumbai-400053. Pan No. Aabtm 2192 E Appellant Respondent Assessment Year: 2013-2014 Mmti’S Education & Research Trust, Ito(E)-2(1), Victor House, 2Nd Floor, End Of Veera Income-Tax Office, Piramal Vs. Desai Road, Next To Chitralekha Chambers, Parel, Mumbai- House, Andheri (W), 12. Mumbai-400053. Pan No. Aabtm 2192 E Appellant Respondent

For Appellant: Ms. Arati Vissanji, Adv &For Respondent: Mr. Manish Ajudiya
Section 13(1)(c)Section 13(3)

charitable institution with the Income Department in terms of section 12AA of the Income-tax Act, 1961 Department in terms of section 12AA of the Income Department in terms of section 12AA of the Income (in short ‘the Act’) dated 09.09.2004. (in short ‘the Act’) dated 09.09.2004. During relevant year, t During relevant year, the assessee trust was engaged

MMTI'S EDUCATION & RESEARCH TRUST,MUMBAI vs. ITO (E) 2 (1), MUMBAI

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

ITA 451/MUM/2019[2013-14]Status: DisposedITAT Mumbai23 Jun 2023AY 2013-14

Bench: Shri Vikas Awasthy () & Shri Om Prakash Kant () Assessment Year: 2011-2012 Mmti’S Education & Research Trust, The Dy. Director Of Income- New Excel House, 2Nd Floor, 41-B, Tax(Exemption)-I(1), Vs. Azad Nagar Road No. 2, Off. Veera 5Th Floor, Piramal Chambers, Desai Road, Behind Icici Bank, Parel, Lalbaug, Andheri (West), Mumbai-400012. Mumbai-400053. Pan No. Aabtm 2192 E Appellant Respondent Assessment Year: 2012-2013 Mmti’S Education & Research Trust, Ito(E)-2(1), New Excel House, 2Nd Floor, 41-B, Income-Tax Office, Piramal Vs. Azad Nagar Road No. 2, Off. Veera Chambers, Parel, Mumbai- Desai Road, Behind Icici Bank, 12. Andheri (West), Mumbai-400053. Pan No. Aabtm 2192 E Appellant Respondent Assessment Year: 2013-2014 Mmti’S Education & Research Trust, Ito(E)-2(1), Victor House, 2Nd Floor, End Of Veera Income-Tax Office, Piramal Vs. Desai Road, Next To Chitralekha Chambers, Parel, Mumbai- House, Andheri (W), 12. Mumbai-400053. Pan No. Aabtm 2192 E Appellant Respondent

For Appellant: Ms. Arati Vissanji, Adv &For Respondent: Mr. Manish Ajudiya
Section 13(1)(c)Section 13(3)

charitable institution with the Income Department in terms of section 12AA of the Income-tax Act, 1961 Department in terms of section 12AA of the Income Department in terms of section 12AA of the Income (in short ‘the Act’) dated 09.09.2004. (in short ‘the Act’) dated 09.09.2004. During relevant year, t During relevant year, the assessee trust was engaged

THE J.K. TRUST BOMBAY,MUMBAI vs. CIT (E), MUMBAI

The appeal of the assessee is allowed

ITA 3769/MUM/2017[2012-13]Status: DisposedITAT Mumbai25 Jul 2018AY 2012-13

Bench: Shri Joginder Singh & Shri N.K. Pradhanassessment Year: 2012-13 M/S The J. K. Trust Cit (Exemption) Bombay, R. No.617, 6Th Floor, बनाम/ New Hind House, Piramal Chambers, Vs. Narottam Morrjee Marg, Lalbaug, Ballard Estate, Mumbai-400012 Mumbai-400001

Section 11Section 263

40A(2)(b) was reasonable and not excessive. Whether the payment was excessive or not would depend upon the prevalent market prices. However, the Assessing Officer did not make any enquiry regarding prevalent market price of the goods purchased by the assessee from the sister concern. In the absence of such enquiry on the part of Assessing Officer

SAVITA OIL TECHNOLOGIES LTD,MUMBAI vs. ACIT, CC-8(4), MUMBAI

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

ITA 1258/MUM/2023[2017-18]Status: DisposedITAT Mumbai25 Oct 2023AY 2017-18

Bench: Shri Aby T. Varkey, Jm & Shri Amarjit Singh, Am आयकर अपील सं/ I.T.A. No.1258/Mum/2023 (निर्धारण वर्ा / Assessment Year: 2017-18) Savita Oil Technologies बिधम/ Acit, Central Circle-8(4) Ltd. Room No. 659, Aayakar Vs. 66/67, Nariman Bhavan, Bhavan, M. K. Road, Nariman Point, Mumbai- New Marine Line, 400021. Mumbai-400020. स्थधयी लेखध सं./जीआइआर सं./Pan/Gir No. : Aaafs3513J (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) Assessee By: Shri Yogesh Thar/Chaitanya Joshi Revenue By: Shri Ram Krishna Kedia (Sr. Ar) Shri Virabhadra Mahanjan (Sr. Ar) सुनवाई की तारीख / Date Of Hearing: 04/07/2023/ (20/10/2023) घोषणा की तारीख /Date Of Pronouncement: 25/10/2023 आदेश / O R D E R Per Aby T. Varkey, Jm: This Is An Appeal Preferred By The Assessee Against The Order Of The Ld. Commissioner Of Income Tax-50, Mumbai Dated 24.02.2023 For Assessment Year 2017-18. 2. The First Ground Of Appeal Of The Assessee Is As Under: - “1(A) The Appellant Submits That The Learned Commissioner Of Income-Tax (Appeals) [(“Cit(A)”)] Erred In Not Allowing The Claim Towards Expenditure On Account Of Gratuity Representing Amount Actual Paid To An Approved Gratuity Fund Of Rs.83,69,981/- Representing Employer'S Contribution. (B) The Appellant Submits That Cit(A) Failed To Appreciate That The Aforesaid Amount Of Rs.83,69,981/- Was Paid On Or Before The Due Date For Filing Its Return Of Income For Assessment Year 2017-18 To An Approved Gratuity Fund

For Appellant: Shri Yogesh Thar/Chaitanya JoshiFor Respondent: Shri Ram Krishna Kedia (Sr. AR)
Section 139(1)Section 143(3)Section 36(1)(v)Section 40A(7)Section 43BSection 80GSection 80I

3) of the Act after calling for specific details on this issue i.e. gratuity amount debited to other comprehensive income as noted (supra). In the light of the aforesaid facts, we have to examine whether assessee’s claim regarding deduction in respect of amount actually paid to approved 6 A.Y. 2017-18 Savita Oil Technologies Ltd gratuity fund of Rs.83

SHEKHAR DADARKAR PROP M/S, S.D. CONSTRUCTION,MUMBAI vs. DCIT 24(3), MUMBAI

In the result, appeals of assessee in ITA

ITA 7642/MUM/2012[2009-10]Status: DisposedITAT Mumbai09 Apr 2018AY 2009-10

Bench: Shri Mahavir Singh & Shri Rajesh Kumarassessment Year: 2009-10

For Appellant: NoneFor Respondent: Shri V. Justin, D.R
Section 193Section 194Section 40Section 40A(3)

40A(3) of the Act and while rejecting the contentions of the assessee that as per rule 6DD(f) the said payments by way of cash are exempted as these expenses were incurred for purchase of products manufactured or processed without the aid of power in a cottage industry and thus added the same to the income of the assessee

SHEKHAR DADARKAR PROP,MUMBAI vs. ACIT 31(3), MUMBAI

In the result, appeals of assessee in ITA

ITA 1032/MUM/2017[2010-11]Status: DisposedITAT Mumbai09 Apr 2018AY 2010-11

Bench: Shri Mahavir Singh & Shri Rajesh Kumarassessment Year: 2009-10

For Appellant: NoneFor Respondent: Shri V. Justin, D.R
Section 193Section 194Section 40Section 40A(3)

40A(3) of the Act and while rejecting the contentions of the assessee that as per rule 6DD(f) the said payments by way of cash are exempted as these expenses were incurred for purchase of products manufactured or processed without the aid of power in a cottage industry and thus added the same to the income of the assessee

SHEKHAR DADARKAR PROP,MUMBAI vs. DCIT 34(3), MUMBAI

In the result, appeals of assessee in ITA

ITA 2411/MUM/2017[2011-12]Status: DisposedITAT Mumbai09 Apr 2018AY 2011-12

Bench: Shri Mahavir Singh & Shri Rajesh Kumarassessment Year: 2009-10

For Appellant: NoneFor Respondent: Shri V. Justin, D.R
Section 193Section 194Section 40Section 40A(3)

40A(3) of the Act and while rejecting the contentions of the assessee that as per rule 6DD(f) the said payments by way of cash are exempted as these expenses were incurred for purchase of products manufactured or processed without the aid of power in a cottage industry and thus added the same to the income of the assessee

DCIT 24(3), MUMBAI vs. SHEKHAR S. DADARKAR, MUMBAI

In the result, appeals of assessee in ITA

ITA 819/MUM/2013[2009-10]Status: DisposedITAT Mumbai09 Apr 2018AY 2009-10

Bench: Shri Mahavir Singh & Shri Rajesh Kumarassessment Year: 2009-10

For Appellant: NoneFor Respondent: Shri V. Justin, D.R
Section 193Section 194Section 40Section 40A(3)

40A(3) of the Act and while rejecting the contentions of the assessee that as per rule 6DD(f) the said payments by way of cash are exempted as these expenses were incurred for purchase of products manufactured or processed without the aid of power in a cottage industry and thus added the same to the income of the assessee

SHEKHAR DADARKAR PROP,MUMBAI vs. ACIT 31(3), MUMBAI

In the result, appeals of assessee in ITA

ITA 1033/MUM/2017[2012-13]Status: DisposedITAT Mumbai09 Apr 2018AY 2012-13

Bench: Shri Mahavir Singh & Shri Rajesh Kumarassessment Year: 2009-10

For Appellant: NoneFor Respondent: Shri V. Justin, D.R
Section 193Section 194Section 40Section 40A(3)

40A(3) of the Act and while rejecting the contentions of the assessee that as per rule 6DD(f) the said payments by way of cash are exempted as these expenses were incurred for purchase of products manufactured or processed without the aid of power in a cottage industry and thus added the same to the income of the assessee

ASST CIT CIR 2(2)(1), MUMBAI vs. STATE BANK OF INDIA, MUMBAI

In the result, the appeal by the Revenue is partly allowed for statistical purposes

ITA 4564/MUM/2016[2009-10]Status: DisposedITAT Mumbai06 Jun 2023AY 2009-10

Bench: Shri B.R. Baskaran & Shri Sandeep Singh Karhail

For Appellant: S/Shri P.J. Pardiwala a/w Ninad PatadeFor Respondent: Ms. Surabhi Sharma
Section 142(1)Section 143(2)Section 143(3)Section 14ASection 250Section 36(1)Section 36(1)(vii)Section 36(1)(viia)

40A(9) of the Act will not be applicable since the provision is not towards contribution to any pension fund. We are of the view that sections 36(1)(iv) and 36(1)(v) of the Act specifically deal with contribution to a recognized provident fund or an approved superannuation fund or an approved gratuity fund. The said sections

STATE BANK OF INDIA,MUMBAI vs. ADDL CIT RG 2(2), MUMBAI

In the result, the appeal by the Revenue is partly allowed for statistical purposes

ITA 3645/MUM/2016[2009-10]Status: DisposedITAT Mumbai06 Jun 2023AY 2009-10

Bench: Shri B.R. Baskaran & Shri Sandeep Singh Karhail

For Appellant: S/Shri P.J. Pardiwala a/w Ninad PatadeFor Respondent: Ms. Surabhi Sharma
Section 142(1)Section 143(2)Section 143(3)Section 14ASection 250Section 36(1)Section 36(1)(vii)Section 36(1)(viia)

40A(9) of the Act will not be applicable since the provision is not towards contribution to any pension fund. We are of the view that sections 36(1)(iv) and 36(1)(v) of the Act specifically deal with contribution to a recognized provident fund or an approved superannuation fund or an approved gratuity fund. The said sections

ITO (E) 2(2), MUMBAI vs. PABODHAN PRAKASHAN, MUMBAI

In the result, the appeals are dismissed

ITA 3831/MUM/2015[2007-08]Status: DisposedITAT Mumbai18 Jan 2017AY 2007-08

Bench: Shri C. N. Prasad () & Shri N.K. Pradhan ()

For Appellant: Shri Rajesh Ojha, DRFor Respondent: Shri Anil Sathe, AR
Section 11Section 12ASection 271(1)(c)

charitable objects. 7.4 Now we come to the order of the ITAT ‘’C’’ Bench, Mumbai in the case of the assessee for the impugned assessment years (ITA No. 8490/M/2010 & 1880/M/2012). The principal grounds of appeal raised by the assessee for the impugned assessment years as mentioned at para 3.1 of the order of the Tribunal are as under

ITO (E) 2(2), MUMBAI vs. PRABHODHAN PRAKASHAN, MUMBAI

In the result, the appeals are dismissed

ITA 3833/MUM/2015[2008-09]Status: DisposedITAT Mumbai18 Jan 2017AY 2008-09

Bench: Shri C. N. Prasad () & Shri N.K. Pradhan ()

For Appellant: Shri Rajesh Ojha, DRFor Respondent: Shri Anil Sathe, AR
Section 11Section 12ASection 271(1)(c)

charitable objects. 7.4 Now we come to the order of the ITAT ‘’C’’ Bench, Mumbai in the case of the assessee for the impugned assessment years (ITA No. 8490/M/2010 & 1880/M/2012). The principal grounds of appeal raised by the assessee for the impugned assessment years as mentioned at para 3.1 of the order of the Tribunal are as under

STATE BANK OF INDIA,MUMBAI vs. ACIT CIR 2(2),

In the result, appeal of the revenue is dismissed

ITA 4736/MUM/2010[1999-2000]Status: DisposedITAT Mumbai31 Jan 2018AY 1999-2000

Bench: Shri G.S. Pannu & Shri Pawan Singhstate Bank Of India Acit Circle (2)(2), Financial Reporting, Compliance & Mumbai. Taxation Department, 19Th Floor, Vs. Corporate Centre, Madam Cama Road, Mumbai-400021. Pan: Aaacs8577K (Appellant) (Respondent) Acit Circle (2)(2), State Bank Of India Mumbai. Financial Reporting, Compliance & Taxation Department, 19Th Floor, Vs. Corporate Centre, Madam Cama Road, Mumbai-400021. Pan: Aaacs8577K (Appellant) (Respondent)

For Respondent: Shri R.P. Meena (CIT-DR)
Section 14ASection 195Section 253Section 254(1)Section 36(1)(viia)Section 40Section 43D

3) order of the said year”. Quite clearly, the aforesaid manner of determination by the AO leaves much to be desired. In fact in the earlier part of this order, we have enumerated in some detail, the various propositions which have been raised by the assessee in the context of the disallowance under section 14A of the Act which require

ACIT CIR 2(2), MUMBAI vs. STATE BANK OF INDIA, MUMBAI

In the result, appeal of the revenue is dismissed

ITA 4598/MUM/2010[1999-00]Status: DisposedITAT Mumbai31 Jan 2018AY 1999-00

Bench: Shri G.S. Pannu & Shri Pawan Singhstate Bank Of India Acit Circle (2)(2), Financial Reporting, Compliance & Mumbai. Taxation Department, 19Th Floor, Vs. Corporate Centre, Madam Cama Road, Mumbai-400021. Pan: Aaacs8577K (Appellant) (Respondent) Acit Circle (2)(2), State Bank Of India Mumbai. Financial Reporting, Compliance & Taxation Department, 19Th Floor, Vs. Corporate Centre, Madam Cama Road, Mumbai-400021. Pan: Aaacs8577K (Appellant) (Respondent)

For Respondent: Shri R.P. Meena (CIT-DR)
Section 14ASection 195Section 253Section 254(1)Section 36(1)(viia)Section 40Section 43D

3) order of the said year”. Quite clearly, the aforesaid manner of determination by the AO leaves much to be desired. In fact in the earlier part of this order, we have enumerated in some detail, the various propositions which have been raised by the assessee in the context of the disallowance under section 14A of the Act which require

PROBODHAN PRAKASHAH,MUMBAI vs. ITO (E) II(1), MUMBAI

In the result, appeals of the assessee are allowed

ITA 1529/MUM/2016[2003-04]Status: DisposedITAT Mumbai28 May 2018AY 2003-04

Bench: Shri C.N. Prasad, Hon'Ble & Shri Ramit Kochar, Hon'Ble

For Appellant: Shri Anil SatheFor Respondent: Shri M.C. Omi Ningshen
Section 11Section 271(1)(c)

charitable objects. 7.4 Now we come to the order of the ITAT ‘’C’’ Bench, Mumbai in the case of the assessee for the impugned assessment years (ITA No. 8490/M/2010 & 1880/M/2012). The principal grounds of appeal raised by the assessee for the impugned assessment years as mentioned at para 3.1 of the order of the Tribunal are as under