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816 results for “condonation of delay”+ Section 10(23)clear

Sorted by relevance

Delhi956Chennai924Mumbai816Kolkata521Bangalore420Pune354Ahmedabad313Hyderabad288Jaipur286Karnataka180Chandigarh159Nagpur138Raipur131Visakhapatnam120Surat118Amritsar115Cochin107Indore91Lucknow82Panaji62Cuttack61Rajkot54Calcutta44Guwahati39SC37Patna32Jodhpur25Telangana21Agra14Varanasi14Allahabad13Dehradun8Jabalpur7Orissa4Rajasthan4A.K. SIKRI ROHINTON FALI NARIMAN2Andhra Pradesh2R.M. LODHA ANIL R. DAVE1Ranchi1A.K. SIKRI N.V. RAMANA1Kerala1DIPAK MISRA R.K. AGRAWAL PRAFULLA C. PANT1Himachal Pradesh1Gauhati1

Key Topics

Addition to Income56Section 143(3)48Section 14832Condonation of Delay30Disallowance29Section 25028Deduction24Section 14723Section 14A

STATE BANK OF INDIA HRMS DEPARTMENT ,MUMBAI vs. ASSTT. COMMISSIONER OF INCOME TAX (TDS)RANGE-2(2), MUMBAI

In the result, all the appeals of the assessee are allowed for In the result, all the appeals of the assessee are allowed for In the result, all the appeals of the assessee are allowed for statisti...

ITA 3111/MUM/2022[2012-2013]Status: DisposedITAT Mumbai27 Apr 2023AY 2012-2013

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Ita Nos. 3111& 3112/Mum/2022 Assessment Years: 2012-13& 2013-14 State Bank Of India Hrms Acit (Tds) Rg-2(2), Department, Peddar Road, Vs. 4Th Floor, Cidco Tower No. 7, Mumbai-400014. Belapur Railway Station Complex-400614. Tan No. Mums 63193 E Appellant Respondent Assessee By : Mr. Anand Desai & Mr. Sachin Lopes, Ar Revenue By : Mr. Paresh Deshpande, Dr

For Appellant: Mr. Anand Desai &For Respondent: Mr. Paresh Deshpande, DR

condonation of delay in filing of appeal of 249 days to the Appellant delay in filing of appeal of 249 days to the Appellant delay in filing of appeal of 249 days to the Appellant without appreciating without appreciating the facts of the case the facts of the case the facts of the case. the case. Opportunity of being heard

STATE BANK OF INDIA,MUM vs. ACIT-TDS-2(2),, MUM

Showing 1–20 of 816 · Page 1 of 41

...
23
Section 6822
Section 143(1)21
Limitation/Time-bar20

In the result, all the appeals of the assessee are allowed for In the result, all the appeals of the assessee are allowed for In the result, all the appeals of the assessee are allowed for statisti...

ITA 3086/MUM/2022[2014-15]Status: DisposedITAT Mumbai27 Apr 2023AY 2014-15

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Ita Nos. 3111& 3112/Mum/2022 Assessment Years: 2012-13& 2013-14 State Bank Of India Hrms Acit (Tds) Rg-2(2), Department, Peddar Road, Vs. 4Th Floor, Cidco Tower No. 7, Mumbai-400014. Belapur Railway Station Complex-400614. Tan No. Mums 63193 E Appellant Respondent Assessee By : Mr. Anand Desai & Mr. Sachin Lopes, Ar Revenue By : Mr. Paresh Deshpande, Dr

For Appellant: Mr. Anand Desai &For Respondent: Mr. Paresh Deshpande, DR

condonation of delay in filing of appeal of 249 days to the Appellant delay in filing of appeal of 249 days to the Appellant delay in filing of appeal of 249 days to the Appellant without appreciating without appreciating the facts of the case the facts of the case the facts of the case. the case. Opportunity of being heard

STATE BANK OF INDIA,MUM vs. ACIT-TDS-2(2), MUM

In the result, all the appeals of the assessee are allowed for In the result, all the appeals of the assessee are allowed for In the result, all the appeals of the assessee are allowed for statisti...

ITA 3088/MUM/2022[2016-17]Status: DisposedITAT Mumbai27 Apr 2023AY 2016-17

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Ita Nos. 3111& 3112/Mum/2022 Assessment Years: 2012-13& 2013-14 State Bank Of India Hrms Acit (Tds) Rg-2(2), Department, Peddar Road, Vs. 4Th Floor, Cidco Tower No. 7, Mumbai-400014. Belapur Railway Station Complex-400614. Tan No. Mums 63193 E Appellant Respondent Assessee By : Mr. Anand Desai & Mr. Sachin Lopes, Ar Revenue By : Mr. Paresh Deshpande, Dr

For Appellant: Mr. Anand Desai &For Respondent: Mr. Paresh Deshpande, DR

condonation of delay in filing of appeal of 249 days to the Appellant delay in filing of appeal of 249 days to the Appellant delay in filing of appeal of 249 days to the Appellant without appreciating without appreciating the facts of the case the facts of the case the facts of the case. the case. Opportunity of being heard

STATE BANK OF INDIA HRMS DEPARTMENT,MUMBAI vs. ASSTT. COMMISSIONER OF INCOME TAX (TDS)RANGE-2(2), MUMBAI

In the result, all the appeals of the assessee are allowed for In the result, all the appeals of the assessee are allowed for In the result, all the appeals of the assessee are allowed for statisti...

ITA 3112/MUM/2022[2013-2014]Status: DisposedITAT Mumbai27 Apr 2023AY 2013-2014

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Ita Nos. 3111& 3112/Mum/2022 Assessment Years: 2012-13& 2013-14 State Bank Of India Hrms Acit (Tds) Rg-2(2), Department, Peddar Road, Vs. 4Th Floor, Cidco Tower No. 7, Mumbai-400014. Belapur Railway Station Complex-400614. Tan No. Mums 63193 E Appellant Respondent Assessee By : Mr. Anand Desai & Mr. Sachin Lopes, Ar Revenue By : Mr. Paresh Deshpande, Dr

For Appellant: Mr. Anand Desai &For Respondent: Mr. Paresh Deshpande, DR

condonation of delay in filing of appeal of 249 days to the Appellant delay in filing of appeal of 249 days to the Appellant delay in filing of appeal of 249 days to the Appellant without appreciating without appreciating the facts of the case the facts of the case the facts of the case. the case. Opportunity of being heard

STATE BANK OF INDIA,MUM vs. ACIT-TDS-2(2), MUM

In the result, all the appeals of the assessee are allowed for In the result, all the appeals of the assessee are allowed for In the result, all the appeals of the assessee are allowed for statisti...

ITA 3087/MUM/2022[2015-16]Status: DisposedITAT Mumbai27 Apr 2023AY 2015-16

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Ita Nos. 3111& 3112/Mum/2022 Assessment Years: 2012-13& 2013-14 State Bank Of India Hrms Acit (Tds) Rg-2(2), Department, Peddar Road, Vs. 4Th Floor, Cidco Tower No. 7, Mumbai-400014. Belapur Railway Station Complex-400614. Tan No. Mums 63193 E Appellant Respondent Assessee By : Mr. Anand Desai & Mr. Sachin Lopes, Ar Revenue By : Mr. Paresh Deshpande, Dr

For Appellant: Mr. Anand Desai &For Respondent: Mr. Paresh Deshpande, DR

condonation of delay in filing of appeal of 249 days to the Appellant delay in filing of appeal of 249 days to the Appellant delay in filing of appeal of 249 days to the Appellant without appreciating without appreciating the facts of the case the facts of the case the facts of the case. the case. Opportunity of being heard

STATE BANK OF INDIA-RBO II THANE WESTERN BRANCH,MUMBAI vs. ACIT-TDS-2(2), MUMBAI

In the result, all the appeals of the assessee are allowed for In the result, all the appeals of the assessee are allowed for In the result, all the appeals of the assessee are allowed for statisti...

ITA 2765/MUM/2022[2013-14]Status: DisposedITAT Mumbai27 Apr 2023AY 2013-14

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Ita Nos. 3111& 3112/Mum/2022 Assessment Years: 2012-13& 2013-14 State Bank Of India Hrms Acit (Tds) Rg-2(2), Department, Peddar Road, Vs. 4Th Floor, Cidco Tower No. 7, Mumbai-400014. Belapur Railway Station Complex-400614. Tan No. Mums 63193 E Appellant Respondent Assessee By : Mr. Anand Desai & Mr. Sachin Lopes, Ar Revenue By : Mr. Paresh Deshpande, Dr

For Appellant: Mr. Anand Desai &For Respondent: Mr. Paresh Deshpande, DR

condonation of delay in filing of appeal of 249 days to the Appellant delay in filing of appeal of 249 days to the Appellant delay in filing of appeal of 249 days to the Appellant without appreciating without appreciating the facts of the case the facts of the case the facts of the case. the case. Opportunity of being heard

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

In the result, all the appeals of the assessee are allowed for In the result, all the appeals of the assessee are allowed for In the result, all the appeals of the assessee are allowed for statisti...

ITA 2764/MUM/2022[2012-13]Status: DisposedITAT Mumbai27 Apr 2023AY 2012-13

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Ita Nos. 3111& 3112/Mum/2022 Assessment Years: 2012-13& 2013-14 State Bank Of India Hrms Acit (Tds) Rg-2(2), Department, Peddar Road, Vs. 4Th Floor, Cidco Tower No. 7, Mumbai-400014. Belapur Railway Station Complex-400614. Tan No. Mums 63193 E Appellant Respondent Assessee By : Mr. Anand Desai & Mr. Sachin Lopes, Ar Revenue By : Mr. Paresh Deshpande, Dr

For Appellant: Mr. Anand Desai &For Respondent: Mr. Paresh Deshpande, DR

condonation of delay in filing of appeal of 249 days to the Appellant delay in filing of appeal of 249 days to the Appellant delay in filing of appeal of 249 days to the Appellant without appreciating without appreciating the facts of the case the facts of the case the facts of the case. the case. Opportunity of being heard

STATE BANK OF INDIA-ISB BRANCH,MUMBAI vs. DCIT-TDS-2(2), MUMBAI

In the result, all the appeals of the assessee are allowed for In the result, all the appeals of the assessee are allowed for In the result, all the appeals of the assessee are allowed for statisti...

ITA 355/MUM/2023[2011-2012]Status: DisposedITAT Mumbai27 Apr 2023AY 2011-2012

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Ita Nos. 3111& 3112/Mum/2022 Assessment Years: 2012-13& 2013-14 State Bank Of India Hrms Acit (Tds) Rg-2(2), Department, Peddar Road, Vs. 4Th Floor, Cidco Tower No. 7, Mumbai-400014. Belapur Railway Station Complex-400614. Tan No. Mums 63193 E Appellant Respondent Assessee By : Mr. Anand Desai & Mr. Sachin Lopes, Ar Revenue By : Mr. Paresh Deshpande, Dr

For Appellant: Mr. Anand Desai &For Respondent: Mr. Paresh Deshpande, DR

condonation of delay in filing of appeal of 249 days to the Appellant delay in filing of appeal of 249 days to the Appellant delay in filing of appeal of 249 days to the Appellant without appreciating without appreciating the facts of the case the facts of the case the facts of the case. the case. Opportunity of being heard

STATE BANK OF INDIA,MUM vs. ACIT-TDS-2(2), MUM

In the result, all the appeals of the assessee are allowed for In the result, all the appeals of the assessee are allowed for In the result, all the appeals of the assessee are allowed for statisti...

ITA 3089/MUM/2022[2017-18]Status: DisposedITAT Mumbai27 Apr 2023AY 2017-18

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Ita Nos. 3111& 3112/Mum/2022 Assessment Years: 2012-13& 2013-14 State Bank Of India Hrms Acit (Tds) Rg-2(2), Department, Peddar Road, Vs. 4Th Floor, Cidco Tower No. 7, Mumbai-400014. Belapur Railway Station Complex-400614. Tan No. Mums 63193 E Appellant Respondent Assessee By : Mr. Anand Desai & Mr. Sachin Lopes, Ar Revenue By : Mr. Paresh Deshpande, Dr

For Appellant: Mr. Anand Desai &For Respondent: Mr. Paresh Deshpande, DR

condonation of delay in filing of appeal of 249 days to the Appellant delay in filing of appeal of 249 days to the Appellant delay in filing of appeal of 249 days to the Appellant without appreciating without appreciating the facts of the case the facts of the case the facts of the case. the case. Opportunity of being heard

STATE BANK OF INDIA- NRI BRANCH,MUMBAI vs. ACIT-TDS-2(2), MUMBAI

In the result, all the appeals of the assessee are allowed for In the result, all the appeals of the assessee are allowed for In the result, all the appeals of the assessee are allowed for statisti...

ITA 2744/MUM/2022[2012-13]Status: DisposedITAT Mumbai27 Apr 2023AY 2012-13

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Ita Nos. 3111& 3112/Mum/2022 Assessment Years: 2012-13& 2013-14 State Bank Of India Hrms Acit (Tds) Rg-2(2), Department, Peddar Road, Vs. 4Th Floor, Cidco Tower No. 7, Mumbai-400014. Belapur Railway Station Complex-400614. Tan No. Mums 63193 E Appellant Respondent Assessee By : Mr. Anand Desai & Mr. Sachin Lopes, Ar Revenue By : Mr. Paresh Deshpande, Dr

For Appellant: Mr. Anand Desai &For Respondent: Mr. Paresh Deshpande, DR

condonation of delay in filing of appeal of 249 days to the Appellant delay in filing of appeal of 249 days to the Appellant delay in filing of appeal of 249 days to the Appellant without appreciating without appreciating the facts of the case the facts of the case the facts of the case. the case. Opportunity of being heard

ACIT, CIRCLE-3, THANE, ASHAR, IT PARK, THANE vs. MAGIC KRAFT PRIVATE LIMITED, VASAI EAST

ITA 4327/MUM/2025[2023-24]Status: DisposedITAT Mumbai13 Oct 2025AY 2023-24

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

Section 115BSection 143(1)Section 1ISection 250

23- 10-2023 7. [2025] 176 taxmann.com 742 INCOME TAX : Where assessee- (Gujarat) company inadvertently failed to CO. 242/Mum/2025. HIGH COURT OF GUJARAT electronically file Form 10-IC within due date and filed belated Camino Herbal Remedies (P.) Form and made an application Ltd. under section 119(2)(b) to v. condone delay

ACIT, CIRCLE-3, THANE, ASHAR IT PARK THANE vs. MAGIC KRAFT PRIVATE LIMITED, VASAI EAST

ITA 4338/MUM/2025[2023-24]Status: DisposedITAT Mumbai13 Oct 2025AY 2023-24

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

Section 115BSection 143(1)Section 1ISection 250

23- 10-2023 7. [2025] 176 taxmann.com 742 INCOME TAX : Where assessee- (Gujarat) company inadvertently failed to CO. 242/Mum/2025. HIGH COURT OF GUJARAT electronically file Form 10-IC within due date and filed belated Camino Herbal Remedies (P.) Form and made an application Ltd. under section 119(2)(b) to v. condone delay

UMMEED FOUNDATION,AL SHAKREEN APT vs. COMMISSIONER OF INCOME TAX (EXEMPTION), PUNE, PMT BUILDING COMMERCIAL COMPLEX

In the result, the grounds of the assessee are allowed for In the result, the grounds of the assessee are allowed for In the result, the grounds of the assessee are allowed for statistical purposes

ITA 1876/MUM/2024[2023-24]Status: DisposedITAT Mumbai24 Jul 2024AY 2023-24

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2023-24 Ummeed Foundation, Cit(E), Pune, Room No. 204, A1 Shakreen Apt, 322, 3Rd Floor, Income Tax Vs. Waf Acomplex Chs, H-104, Office, Pmt Building Sharifa Road, Amrut Nagar, City Commercial Complex, Shankar Convent High School, Thane, Sheth Road, Swargate, Kausa B.O., Maharashtra-400612. Pune-411037. Pan No. Aaatu 4914 H Appellant Respondent

For Appellant: Mr. Ankush Kapoor, CIT-DRFor Respondent: Mr. Rohan Dedhia
Section 12ASection 12A(1)(ac)Section 80GSection 80G(5)Section 80G(5)(iv)

condone the delay in filing Form No. 10A/10AB, as the same , as the same could not be filed in such cases wit could not be filed in such cases within the last extended date, i.e hin the last extended date, i.e., 30.09 .2023. 3. On consideration of the matter, with a view to avoid and mitigate 3. On consideration

GETINGE MEDICAL INDIA PRIVATE LIMITED ,MUMBAI vs. DCIT 2(2)(1), MUMBAI MAHARASHTRA

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

ITA 4872/MUM/2024[2020-21]Status: DisposedITAT Mumbai13 Mar 2026AY 2020-21

Bench: Smt. Beena Pillai () & Shri Girish Agrawal ()

Section 115Section 115BSection 142(1)Section 143(2)Section 156Section 234ASection 270ASection 37Section 41Section 41(1)(a)

10-B in respect of an educational trust, Hon'ble Court dealt with section 119(2)(b) and a circular vide which powers to condone delay were delegated to CITs. In para 18,19 and 20 Hon'ble Court noted provisions of Section 119(2)(b), the circular vide which CBDT delegated the authority to condone delay to jurisdictional CITs

CHETANA ,MUMBAI vs. CIT(EXEMPTION) , MUMBAI

In the result, the appeal filed by the assessee is allowed for In the result, the appeal filed by the assessee is allowed for In the result, the appeal filed by the assessee is allowed for statisti...

ITA 1812/MUM/2025[N.A ]Status: DisposedITAT Mumbai10 Jul 2025

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan () Chetana, Cit (Exemptions), Survey No. 341, Chetana College, 601, 6Th Floor, Cumballa Hill Vs. Government Colony, Bandra East, Mtnl Te Building, Pedder Road, Mumbai-400051. Gopalrao Deshmukh Marg, Cumballa Hill, Mumbai-400026. Pan No. Aaatc 3012 A Appellant Respondent

For Appellant: Mr. Ashish A. ThakurdesaiFor Respondent: 10/06/2025
Section 10

23 to 2024–25. In terms of clause (iii) of the first 25. In terms of clause (iii) of the first proviso to sub-section (5) of Section 10(23C) of the Act, the assessee section (5) of Section 10(23C) of the Act, the assessee section (5) of Section 10(23C) of the Act, the assessee was required

SHA HURGOWAN ANANDJI DESAI CHARITIES ,MUMBAI vs. DEPUTY DIRECTOR OF INCOME TAX, CPC , BENGULURU

In the result, the appeal of the assessee

ITA 2807/MUM/2024[2022-23]Status: DisposedITAT Mumbai30 Aug 2024AY 2022-23

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail () Assessment Year: 2022-23 Sha Hurgowan Anandji Desai Dy. Director Of Income-Tax, Cpc Charities, Bengaluru, 18, Bhaskar Lane, Bhuleshwar, Vs. Income Tax Officer Exemption Mumbai-400002. Ward 2(3), 6Th Floor, Mtnl Te Building Pedder Road, Mumbai-400026. Pan No. Aaats 0405 R Appellant Respondent

For Respondent: Ms. Vasanti Patel, &
Section 11

10-B cannot be fatal in cannot be fatal in as much as the benefits of Section 11 cannot be denied on this as much as the benefits of Section 11 cannot be denied on this as much as the benefits of Section 11 cannot be denied on this solitary ground. The learned CIT(Appeals) failed to appreciate the solitary

SHREE PUSHKAR FOUNDATION,MUMBAI vs. INCOME TAX OFFICER (EXEMPTION)-WARD 2(30, MUMBAI

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

ITA 2714/MUM/2024[2021-22]Status: DisposedITAT Mumbai30 Aug 2024AY 2021-22

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail () Assessment Year: 2021-22 Shree Pushkar Foundation, Ito (Exemption) – Ward 2(3), 301/302, 3Rd Floor, Cumbala Hill Tele Exchange Atlanta Centre, Vs. (Mtnl), Peddar Rd, Tardeo, Near Udyog Bhavan, Mumbai-400026. Sonawala Road, Goregaon East, Mumbai-400063. Pan No. Aawts 2303 N Appellant Respondent

For Appellant: Mr. Sandip S. Nagar, &For Respondent: 24/07/2024
Section 11Section 11(2)Section 139(1)Section 143(1)Section 143(1)(a)

23-12- Shree Pushkar Foundation Shree Pu 7 2002 and filed a declaration under section 10B (8) which admittedly 2002 and filed a declaration under section 10B (8) which admittedly 2002 and filed a declaration under section 10B (8) which admittedly was after the due date of filing of the original return under section was after the due date

TATA EDUCATION TRUST ,MUMBAI vs. ASSISTANT COMMISSIIONER OF INCOME TAX CIRCLE 17(3), MUMBAI

In the result, Revenue’s appeal is dismissed

ITA 4727/MUM/2024[2016-17]Status: DisposedITAT Mumbai10 Oct 2025AY 2016-17

Bench: Shri Saktijit Dey & Shri Narendra Kumar Billaiya

For Appellant: Shri P.J. Pardiwala a/w ShriFor Respondent: Shri Ritesh Mishra, CIT DR
Section 10(34)Section 10(35)Section 11Section 11(5)Section 12ASection 13(1)(d)Section 13(2)(h)Section 143(3)Section 234B

condone the delay and admit the appeal for adjudication. 22. We have heard the parties and perused the materials on record. After carefully going through the order of learned First Appellate Authority, we are of the view that the grounds raised by the Department are thoroughly misconceived as no relief with regard to assessee’s claim of exemption either Section

TATA EDUCATION TRUST ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX (EXEMPTION)-CIRCLE 2(1), MUMBAI

In the result, Revenue’s appeal is dismissed

ITA 4282/MUM/2024[2014-15]Status: DisposedITAT Mumbai10 Oct 2025AY 2014-15

Bench: Shri Saktijit Dey & Shri Narendra Kumar Billaiya

For Appellant: Shri P.J. Pardiwala a/w ShriFor Respondent: Shri Ritesh Mishra, CIT DR
Section 10(34)Section 10(35)Section 11Section 11(5)Section 12ASection 13(1)(d)Section 13(2)(h)Section 143(3)Section 234B

condone the delay and admit the appeal for adjudication. 22. We have heard the parties and perused the materials on record. After carefully going through the order of learned First Appellate Authority, we are of the view that the grounds raised by the Department are thoroughly misconceived as no relief with regard to assessee’s claim of exemption either Section

ASSISTANT COMMISSIONER OF INCOME TAX, KAUTILYA BHAVAN, BKC, MUMBAI vs. TATA EDUCATION TRUST, MUMBAI

In the result, Revenue’s appeal is dismissed

ITA 4852/MUM/2024[2013-14]Status: DisposedITAT Mumbai10 Oct 2025AY 2013-14

Bench: Shri Saktijit Dey & Shri Narendra Kumar Billaiya

For Appellant: Shri P.J. Pardiwala a/w ShriFor Respondent: Shri Ritesh Mishra, CIT DR
Section 10(34)Section 10(35)Section 11Section 11(5)Section 12ASection 13(1)(d)Section 13(2)(h)Section 143(3)Section 234B

condone the delay and admit the appeal for adjudication. 22. We have heard the parties and perused the materials on record. After carefully going through the order of learned First Appellate Authority, we are of the view that the grounds raised by the Department are thoroughly misconceived as no relief with regard to assessee’s claim of exemption either Section