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38 results for “section 68”+ Section 246Aclear

Sorted by relevance

Indore158Delhi112Chennai53Mumbai38Jaipur31Kolkata24Chandigarh24Hyderabad15Bangalore13Pune9Panaji7Jodhpur7Raipur6Ahmedabad6Rajkot5Calcutta4SC3Lucknow3Patna2Karnataka2Nagpur2Allahabad2Visakhapatnam1Amritsar1Guwahati1Jabalpur1Surat1Telangana1Uttarakhand1Agra1

Key Topics

Section 14827Section 143(3)26Section 3526Disallowance25Addition to Income24Section 218Deduction17Section 92C14Section 25014Section 143(2)

BARCLAYS BANK PLC,MUMBAI vs. CIT (INTERNATIONAL TAXATION)-RANGE-1, MUMBAI

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

ITA 827/MUM/2021[2013-14]Status: DisposedITAT Mumbai03 Jan 2022AY 2013-14

Bench: Shri Shamim Yahya (Am) & Shri Amarjit Singh (Jm)

Section 143(3)Section 144C(13)Section 263Section 37

68 held that the Tribunal held that the sale was a slump sale if it was a sale of a going concern, even if some of the assets were retained by the transferor and sections 50 and 50A of the Act were not applicable. In this case, the assessee has transferred a business asset and the business asset

TATA AIA LIFE INSURANCE CO.LTD,MUMBAI vs. ASST CIT (TDS) CIR 3(1), MUMBAI

In the result, appeal is allowed for statistical purposes

Showing 1–20 of 38 · Page 1 of 2

12
Section 143(1)12
Limitation/Time-bar10
ITA 1400/MUM/2014[2011-12]Status: Disposed
ITAT Mumbai
16 Mar 2016
AY 2011-12

Bench: Shri Saktijit Dey & Shri Ramit Kochar

For Appellant: Shri Dhanesh BafnaFor Respondent: Shri Ritesh Misra
Section 200ASection 200A(1)Section 246Section 246A

68,29,450. Against the intimation issued under section 200A, assessee preferred appeal before the learned Commissioner (Appeals). 3. The learned Commissioner (Appeals), however, dismissed the appeal of the assessee by holding that the intimation issued under section 200A, is not appealable under section 246A

U S ROOFS LTD.,,NAVI MUMBAI vs. ADDL/JT/DY/ACIT/ITO, NFE-ASS C, DELHI DELHI, DELHI

ITA 2112/MUM/2023[2006-07]Status: DisposedITAT Mumbai27 Sept 2023AY 2006-07

Bench: Shri Kuldip Singh & Shri Amarjit Singh

For Appellant: Shri Fenil Bhat, ARFor Respondent: Shri Ankush Kapoor, CIT-DR
Section 143(2)Section 144Section 145(3)Section 148Section 250

68 of the Act be deleted. ITA Nos.2102-2105 & 2112 /Mum/2023 :: 5 :: 14.3. Without prejudice to the above, the Appellant prays that the Ld. AO, at best, could have added only Rs.3,32,369 as cash credits received from Udani Traders being net of receipts of Rs.8,60,000 as reduced by payments of Rs.5,27,631. 15.1. Without prejudice

U S ROOFS LTD.,,NAVI MUMBAI vs. ADDL/JT/DY/ACIT/ITO, NFE-ASS C, DELHI DELHI, DELHI

ITA 2104/MUM/2023[2011-12]Status: DisposedITAT Mumbai27 Sept 2023AY 2011-12

Bench: Shri Kuldip Singh & Shri Amarjit Singh

For Appellant: Shri Fenil Bhat, ARFor Respondent: Shri Ankush Kapoor, CIT-DR
Section 143(2)Section 144Section 145(3)Section 148Section 250

68 of the Act be deleted. ITA Nos.2102-2105 & 2112 /Mum/2023 :: 5 :: 14.3. Without prejudice to the above, the Appellant prays that the Ld. AO, at best, could have added only Rs.3,32,369 as cash credits received from Udani Traders being net of receipts of Rs.8,60,000 as reduced by payments of Rs.5,27,631. 15.1. Without prejudice

U S ROOFS LTD.,,NAVI MUMBAI vs. ADDL/JT/DY/ACIT/ITO, NFE-ASS C, DELHI DELHI, DELHI

ITA 2102/MUM/2023[2007-08]Status: DisposedITAT Mumbai27 Sept 2023AY 2007-08

Bench: Shri Kuldip Singh & Shri Amarjit Singh

For Appellant: Shri Fenil Bhat, ARFor Respondent: Shri Ankush Kapoor, CIT-DR
Section 143(2)Section 144Section 145(3)Section 148Section 250

68 of the Act be deleted. ITA Nos.2102-2105 & 2112 /Mum/2023 :: 5 :: 14.3. Without prejudice to the above, the Appellant prays that the Ld. AO, at best, could have added only Rs.3,32,369 as cash credits received from Udani Traders being net of receipts of Rs.8,60,000 as reduced by payments of Rs.5,27,631. 15.1. Without prejudice

U S ROOFS LTD.,,NAVI MUMBAI vs. ADDL/JT/DY/ACIT/ITO, NFE-ASS C, DELHI DELHI, DELHI

ITA 2103/MUM/2023[2008-09]Status: DisposedITAT Mumbai27 Sept 2023AY 2008-09

Bench: Shri Kuldip Singh & Shri Amarjit Singh

For Appellant: Shri Fenil Bhat, ARFor Respondent: Shri Ankush Kapoor, CIT-DR
Section 143(2)Section 144Section 145(3)Section 148Section 250

68 of the Act be deleted. ITA Nos.2102-2105 & 2112 /Mum/2023 :: 5 :: 14.3. Without prejudice to the above, the Appellant prays that the Ld. AO, at best, could have added only Rs.3,32,369 as cash credits received from Udani Traders being net of receipts of Rs.8,60,000 as reduced by payments of Rs.5,27,631. 15.1. Without prejudice

U S ROOFS LTD.,,NAVI MUMBAI vs. ADDL/JT/DY/ACIT/ITO, NFE-ASS C, DELHI DELHI, DELHI

ITA 2105/MUM/2023[2012-13]Status: DisposedITAT Mumbai27 Sept 2023AY 2012-13

Bench: Shri Kuldip Singh & Shri Amarjit Singh

For Appellant: Shri Fenil Bhat, ARFor Respondent: Shri Ankush Kapoor, CIT-DR
Section 143(2)Section 144Section 145(3)Section 148Section 250

68 of the Act be deleted. ITA Nos.2102-2105 & 2112 /Mum/2023 :: 5 :: 14.3. Without prejudice to the above, the Appellant prays that the Ld. AO, at best, could have added only Rs.3,32,369 as cash credits received from Udani Traders being net of receipts of Rs.8,60,000 as reduced by payments of Rs.5,27,631. 15.1. Without prejudice

CABLE AND WIRELESS (INDIA) LTD,MUMBAI vs. DCIT (IT) CIR 2(1)(1), MUMBAI

In the result, appeal stands dismissed

ITA 3199/MUM/2017[2011-12]Status: DisposedITAT Mumbai16 Dec 2019AY 2011-12

Bench: Shri Pramod Kumar & Shri Saktijit Dey

For Appellant: Shri Vishal KarlaFor Respondent: Shri V. Sreekar
Section 115JSection 143(3)Section 144C(1)Section 144C(13)Section 253Section 254

68,24,622, under the normal provisions and computed the total income of ` 1,04,30,850. Since, the tax computed on the book profit was more than tax computed on the income assessed under the normal provisions, the Assessing Officer assessed the tax under section 115JB of the Act. Against the aforesaid order passed by the Assessing Officer

MORYA HOUSE MAKERS,NAVI MUMBAI vs. DCIT CEN CIR 39, MUMBAI

In the result, this appeal is allowed for statistical purposes

ITA 5264/MUM/2013[2008-09]Status: DisposedITAT Mumbai13 Aug 2021AY 2008-09
Section 40Section 68

68 of the I.T. Act. Before learned CIT(A) the AR of the assessee submitted that it was booking amount received from Shri Sahul Hameed and photocopy of confirmation and PAN was submitted. But, learned CIT(A) 7 Shri Morya House Makers rejected the same as no reason was given for not submitting the details before the AO when

DEEPAK NOVOCHEM TECHNOLOGIES LTD,MUMBAI vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-8(1), MUMBAI

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

ITA 2562/MUM/2023[2018-2019]Status: DisposedITAT Mumbai28 Nov 2023AY 2018-2019

Bench: Shri Om Prakash Kant () & Shri Rahul Chaudhary () Ita Nos. 2558 To 2562/Mum/2023 Assessment Years: 2014-15 To 2018-19 Deepak Novochem The Acit, Cc-8(1), Technologies Ltd., Aayakar Bhavan, Room No. Vs. 515, 5Th Floor, Citi Point, Boat 656, 6Th Floor, M.K. Road, Club Road, Pune City, Mumbai-400020. Pune-411 001. Pan No. Aaccd 5796 K Appellant Respondent Assessee By : Mr. H.P. Mahajani Revenue By : Mrs. Sanyogita Nagpal, Cit-Dr : Date Of Hearing 16/11/2023 Date Of Pronouncement : 28/11/2023

For Appellant: Mr. H.P. MahajaniFor Respondent: Mrs. Sanyogita Nagpal, CIT-DR
Section 35

68,51,063), AY 2014-15 (Rs. 1,09,789) and AY 15 (Rs. 1,09,789) and AY 2015-16 (Rs. 18,54,948), to the taxable income of the Appellant. 16 (Rs. 18,54,948), to the taxable income of the Appellant. 16 (Rs. 18,54,948), to the taxable income of the Appellant. Initiation of penalty proceedings

DEEPAK NOVOCHEM TECHNOLOGIES LTD,MUMBAI vs. THE ASSISTANT COMMISSIONER OF INCOME TAX-CENTRAL CIRCLE-8(1), MUMBAI

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

ITA 2559/MUM/2023[2015-16]Status: DisposedITAT Mumbai28 Nov 2023AY 2015-16

Bench: Shri Om Prakash Kant () & Shri Rahul Chaudhary () Ita Nos. 2558 To 2562/Mum/2023 Assessment Years: 2014-15 To 2018-19 Deepak Novochem The Acit, Cc-8(1), Technologies Ltd., Aayakar Bhavan, Room No. Vs. 515, 5Th Floor, Citi Point, Boat 656, 6Th Floor, M.K. Road, Club Road, Pune City, Mumbai-400020. Pune-411 001. Pan No. Aaccd 5796 K Appellant Respondent Assessee By : Mr. H.P. Mahajani Revenue By : Mrs. Sanyogita Nagpal, Cit-Dr : Date Of Hearing 16/11/2023 Date Of Pronouncement : 28/11/2023

For Appellant: Mr. H.P. MahajaniFor Respondent: Mrs. Sanyogita Nagpal, CIT-DR
Section 35

68,51,063), AY 2014-15 (Rs. 1,09,789) and AY 15 (Rs. 1,09,789) and AY 2015-16 (Rs. 18,54,948), to the taxable income of the Appellant. 16 (Rs. 18,54,948), to the taxable income of the Appellant. 16 (Rs. 18,54,948), to the taxable income of the Appellant. Initiation of penalty proceedings

DEEPAK NOVOCHEM TECHNOLOGIES LTD,MUMBAI vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-8(1), MUMBAI

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

ITA 2558/MUM/2023[2014-2015]Status: DisposedITAT Mumbai28 Nov 2023AY 2014-2015

Bench: Shri Om Prakash Kant () & Shri Rahul Chaudhary () Ita Nos. 2558 To 2562/Mum/2023 Assessment Years: 2014-15 To 2018-19 Deepak Novochem The Acit, Cc-8(1), Technologies Ltd., Aayakar Bhavan, Room No. Vs. 515, 5Th Floor, Citi Point, Boat 656, 6Th Floor, M.K. Road, Club Road, Pune City, Mumbai-400020. Pune-411 001. Pan No. Aaccd 5796 K Appellant Respondent Assessee By : Mr. H.P. Mahajani Revenue By : Mrs. Sanyogita Nagpal, Cit-Dr : Date Of Hearing 16/11/2023 Date Of Pronouncement : 28/11/2023

For Appellant: Mr. H.P. MahajaniFor Respondent: Mrs. Sanyogita Nagpal, CIT-DR
Section 35

68,51,063), AY 2014-15 (Rs. 1,09,789) and AY 15 (Rs. 1,09,789) and AY 2015-16 (Rs. 18,54,948), to the taxable income of the Appellant. 16 (Rs. 18,54,948), to the taxable income of the Appellant. 16 (Rs. 18,54,948), to the taxable income of the Appellant. Initiation of penalty proceedings

DEEPAK NOVOCHEM TECHNOLOGIES LTD,MUMBAI vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-8(1), MUMBAI

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

ITA 2560/MUM/2023[2016-2017]Status: DisposedITAT Mumbai28 Nov 2023AY 2016-2017

Bench: Shri Om Prakash Kant () & Shri Rahul Chaudhary () Ita Nos. 2558 To 2562/Mum/2023 Assessment Years: 2014-15 To 2018-19 Deepak Novochem The Acit, Cc-8(1), Technologies Ltd., Aayakar Bhavan, Room No. Vs. 515, 5Th Floor, Citi Point, Boat 656, 6Th Floor, M.K. Road, Club Road, Pune City, Mumbai-400020. Pune-411 001. Pan No. Aaccd 5796 K Appellant Respondent Assessee By : Mr. H.P. Mahajani Revenue By : Mrs. Sanyogita Nagpal, Cit-Dr : Date Of Hearing 16/11/2023 Date Of Pronouncement : 28/11/2023

For Appellant: Mr. H.P. MahajaniFor Respondent: Mrs. Sanyogita Nagpal, CIT-DR
Section 35

68,51,063), AY 2014-15 (Rs. 1,09,789) and AY 15 (Rs. 1,09,789) and AY 2015-16 (Rs. 18,54,948), to the taxable income of the Appellant. 16 (Rs. 18,54,948), to the taxable income of the Appellant. 16 (Rs. 18,54,948), to the taxable income of the Appellant. Initiation of penalty proceedings

DEEPAK NOVOCHEM TECHNOLOGIES LTD,MUMBAI vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-8(1), MUMBAI

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

ITA 2561/MUM/2023[2017-2018]Status: DisposedITAT Mumbai28 Nov 2023AY 2017-2018

Bench: Shri Om Prakash Kant () & Shri Rahul Chaudhary () Ita Nos. 2558 To 2562/Mum/2023 Assessment Years: 2014-15 To 2018-19 Deepak Novochem The Acit, Cc-8(1), Technologies Ltd., Aayakar Bhavan, Room No. Vs. 515, 5Th Floor, Citi Point, Boat 656, 6Th Floor, M.K. Road, Club Road, Pune City, Mumbai-400020. Pune-411 001. Pan No. Aaccd 5796 K Appellant Respondent Assessee By : Mr. H.P. Mahajani Revenue By : Mrs. Sanyogita Nagpal, Cit-Dr : Date Of Hearing 16/11/2023 Date Of Pronouncement : 28/11/2023

For Appellant: Mr. H.P. MahajaniFor Respondent: Mrs. Sanyogita Nagpal, CIT-DR
Section 35

68,51,063), AY 2014-15 (Rs. 1,09,789) and AY 15 (Rs. 1,09,789) and AY 2015-16 (Rs. 18,54,948), to the taxable income of the Appellant. 16 (Rs. 18,54,948), to the taxable income of the Appellant. 16 (Rs. 18,54,948), to the taxable income of the Appellant. Initiation of penalty proceedings

RAVINDRA PRATAPRAI DOSHI,MUMBAI vs. INCOME TAX OFFICER 29(3)(1), MUMBAI

The appeal of the assessee is allowed for statistical purposes in terms of our aforesaid observations

ITA 52/MUM/2018[2007-08]Status: DisposedITAT Mumbai28 Jun 2019AY 2007-08

Bench: Shri Shamim Yahya & Shri Ravish Soodravindra Prataprai Doshi The Income Tax Officer, Room No. 6, A Wing, Ward 29(3)(1), Premrose, Chs, 305, C-10, Pratyaksh Kar Bhavan, Dadasaheb Gaikwad Road, Vs. Bandra Kurla Complex Tambe Nagar, Mulund (E) Bandra (East), Mumbai- 400080 Mumbai -400051

For Appellant: NoneFor Respondent: Shri D.G.Pansari, Sr. D.R
Section 131Section 133ASection 144Section 147Section 148Section 250Section 251Section 68

68 in respect of the alleged unaccounted cash credits in his bank accounts. As is discernible from the order of the CIT(A), we find, that the latter after culling out the facts of the case, had dismissed the appeal of the assessee for the reason that he had failed to put up an appearance before him. In our considered

MULTI DIMENSIONAL ASSET & WEALTH CREATION LLP ( EARILER MULTI-DIMENSIONAL ASSET & WEALTH CREATION PRIVATE LIMITED),MUMBAI vs. ITO WARD- 10(2)(4), MUMBAI

In the result, the appeal filed by the assessee is allowed as indicated above

ITA 4349/MUM/2023[2011-12]Status: DisposedITAT Mumbai31 May 2024AY 2011-12

Bench: Shri Prashant Maharishi, Am & Shri Sunil Kumar Singh, Jm Multi Dimensional Asset & Wealth Creation Llp ( Earlier Ito Multi Dimensional Asset & Ward 10(2)(4) Wealth Creation Private Room No.213, 2Nd Floor, Vs. Limited) Aaykar Bhavan, C/408, Shirin Sohrab Palace, Mumbai-400 020 Nariman Point East, Mumbai-400 057 (Appellant) (Respondent) Pan No. Aagcm7603Q

For Appellant: Mr. Vishal D. Shah, ARFor Respondent: Smt. Mahita Nair, DR
Section 143(3)Section 147Section 148Section 246ASection 250Section 68

section 147 of the Income-tax Act, 1961 (the Act) dated 16th December, 2016, passed by the Asst. Commissioner of Income Tax, Range 10(2)(4), Mumbai. Assessee has raised following grounds of appeal:- 02. “1. On the facts and under the circumstances of the case and in law, the Ld. CIT(A) erred in passing the order

ASST CIT 19(3), MUMBAI vs. RAJESH M SHAH(HUF), MUMBAI

ITA 7105/MUM/2016[2012-13]Status: DisposedITAT Mumbai30 Aug 2018AY 2012-13

Bench: Hon’Ble Sh. R. C. Sharma, Am & Hon’Ble Sh. Sandeep Gosain, Jm आयकरअपीलसं./ I.T.A. No. 7105/Mum/2016 (िनधा"रणवष" / Assessment Year: 2012-13)

For Appellant: Shri ChaitanyaFor Respondent: Shri Suchek Anchaliya
Section 142(1)Section 143(2)Section 143(3)

section 68 of the Act are applicable. 6.3.28 In the case before me, the record also shows that to prove the genuineness of the impugned loan entries from the 6 creditors, the appellant has 8 I.T.A. No. 7105/Mum/2016 Rajesh M Shah (HUF) furnished to the Assessing Officer the following details copies of which were also furnished in the present

DOW AGROSCIENCES INDIA P.LTD,MUMBAI vs. ACIT 3(1)(1), MUMBAI

The appeal of the assessee is allowed in terms of our aforesaid observations

ITA 6618/MUM/2018[2014-15]Status: DisposedITAT Mumbai15 Feb 2021AY 2014-15

Bench: Shri S. Rifaur Rahman & Shri Ravish Sooddow Agrosciences India Private Asst. Commissioner Of Limited, 1St Floor, Block B, Income Tax-3(1)(1) Godrej It Park, [Income-Tax Officer-14(1)(3)] Room No. 458, Vs. Pirojshanagar, Vikhroli (W) Aayakar Bhavan, M.K. Road, Mumbai – 400 079 Mumbai – 400 020

For Appellant: Shri Nishant Thakkar, A.RFor Respondent: Shri Sunil Deshpande, D.R
Section 143(3)Section 144C(13)Section 92C

68 taxmann. Com 370)(Delhi) (iii) DCIT Vs. Air Liquide Engineering India P. Ltd. (2014) 43 taxmann.com 299 (Hyd). (iv). Daksh Business Process Services P. Ltd. Vs. DCIT (2016) 72 txamann.com 44 (Delhi) In the backdrop of our aforesaid deliberations, we are of the considered view that Dow Agrosciences India (P) Ltd. Vs. ACIT-3(1)(1), Mumbai

SHRI MOHAN THAKUR,MUMBAI vs. A.C.I.T. CENT. CIR. 8(4), MUMBAI

In the result, the appeal of the assessee is hereby ordered to be allowed

ITA 7413/MUM/2017[2008-09]Status: DisposedITAT Mumbai09 Jan 2020AY 2008-09

Bench: Shri Shamim Yahya, Am & Shri Amarjit Singh, Jm आयकर अपील सं/ I.T.A. No.7413 /Mum/2017 (ननधधारण वर्ा / Assessment Years: 2008-09) बनधम/ Shri Mohan Thakur Acit, Central Circle-8(4) 6Th Floor Aayakar Bhavan, 4, Flora Vila, 35, St. Vs. M.K. Road, Mumbai- Andrews Road, Bandra 400020. (W), Mumbai-400050. स्थधयी लेखध सं./जीआइआर सं./Pan/Gir No. :Aaapt2966N (अपीलाथी /Appellant) (प्रत्यथी / Respondent) .. Revenue By: Shri Durga Dutt/ Akhtar H. Ansari (Dr) Assessee By: Dr. K. Shivaram सुनवाई की तारीख / Date Of Hearing: 15/11.2019 घोषणा की तारीख /Date Of Pronouncement: 09/01/2020 आदेश / O R D E R Per Amarjit Singh, Jm: The Assessee Has Filed The Present Appeal Against The Order Dated 30.10.2017 Passed By The Commissioner Of Income Tax (Appeals)-50, Mumbai [Hereinafter Referred To As The “Cit(A)”] Relevant To The A.Y.2008- 09. 2. The Assessee Has Raised The Following Grounds Of Appeal: - “The Learned Cit(A) Erred In Upholding The Validity Of Notice U/S 148 Where The Proceedings U/S 153C Had Already Been Initiated Which Were Dropped & Immediately The Reassessment Proceedings Had Been Initiated Without Any Fresh Material On Record & Hence Reopening Is Void- Ab - Initio Merit : Addition Of Rs.237.00.000/- Based On Entries In Diary Of Third Person: 2. No Addition Can Be Made Based On Entries Found In The Books In Third Party'S Premises Since No Search U/S 132 Had Taken Place On The Assessee & Hence S.132(4A) Would Not Be Applicable To The Present Facts Of The Case. In View Of The Same The Entire Addition May Be Deleted.

For Appellant: Dr. K. ShivaramFor Respondent: Shri Durga Dutt/ Akhtar H
Section 132Section 143(2)Section 143(3)Section 148Section 153C

68,079 Emirates Rupani 09 Total A 6,44,879 Funds given by Mohan Thakur to Desiree Ann Thakur 20.03.2008 43,407 Ireland Hugo Merry 2008-09 37.5367 16,29,355 Stud Farm 18.03.2008 10,713 Unknown Callbrated 2008-09 37.7547 4,04,466 colur 07.11.2007 1,30,659 Hong Kong Golden 2008-09 36.3154 47,44,933 Dragon

RAVISHANKAR,MUMBAI vs. CIT-12, MUMBAI

In the result, assessee’s appeal is dismissed

ITA 7034/MUM/2014[2009-10]Status: DisposedITAT Mumbai23 Sept 2016AY 2009-10

Bench: Shri Saktijit Dey & Shri N.K. Pradhan

For Appellant: Shri RavishankarFor Respondent: Shri A.S. Srivastava
Section 143(1)Section 154Section 246ASection 264

68,318 declared by the assessee. It was further 3 Shri Ravishankar submitted by the assessee that the Assessing Officer failed to set–off carry forward loss of the preceding year. After considering the submissions of the assessee and on the basis of facts and materials placed before him, the Commissioner being prima–facie satisfied with the fact that assessee