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21 results for “reassessment”+ Section 6(1)(c)clear

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Delhi4,117 Mumbai3,715 Chennai1,288 Bangalore1,154 Kolkata959 Ahmedabad653 Jaipur631 Hyderabad415 Chandigarh291 Pune276 Surat202 Rajkot197 Raipur192 Amritsar188 Indore184 Karnataka125 Cuttack122 Cochin118 Visakhapatnam110 Nagpur100 Lucknow99 Patna90 Guwahati83 Telangana71 Dehradun65 Jodhpur56 Ranchi54 Agra49 SC40 Allahabad38 Panaji21 Calcutta18 Jabalpur17 Kerala16 Orissa13 Varanasi10 Rajasthan7 A.K. SIKRI ROHINTON FALI NARIMAN3 Punjab & Haryana2 Madhya Pradesh1 J&K1 Gauhati1 K.S. RADHAKRISHNAN A.K. SIKRI1 Uttarakhand1

Key Topics

Section 24940 Section 14431 Section 246A25 Section 25017 Section 143(3)16 Section 14714 Section 14811 Addition to Income11 Section 253(1)10 Penalty

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, BELAGAVI, BELAGAVI vs. M/S POTDAR BROTHERS, BELAGAVI

Appeals of the Revenue are PARTLY ALLOWED for statistical purposes in aforestated terms

ITA 177/PAN/2025[2020-21]Status: DisposedITAT Panaji18 Nov 2025AY 2020-21

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

For Appellant: Mr Pramod Vaidya [‘Ld. AR’]For Respondent: Mr M Satish [‘Ld. DR’]

Section 132Section 133ASection 138Section 143(1)Section 143(3)Section 147Section 148Section 246ASection 250Section 253(2)

Showing 1–20 of 21 · Page 1 of 2

10

Limitation/Time-bar10

Condonation of Delay10

reassessment by issue of notice u/s 148 and consequential assessment u/s 147 of the Act completed wherein a solitary addition of 30% of total payments made to karigars (artisan labours) during the year was made. 3.3 Aggrieved assessee filed an appeal u/s 246A of the Act before first appellate authority which was allowed vide para 4.9 to 4.12 which reads

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, BELAGAVI, BELAGAVI vs. M/S POTDAR BROTHERS, BELAGAVI

Appeals of the Revenue are PARTLY ALLOWED for statistical purposes in aforestated terms

ITA 180/PAN/2025[2022-23]Status: DisposedITAT Panaji18 Nov 2025AY 2022-23

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

For Appellant: Mr Pramod Vaidya [‘Ld. AR’]For Respondent: Mr M Satish [‘Ld. DR’]

Section 132Section 133ASection 138Section 143(1)Section 143(3)Section 147Section 148Section 246ASection 250Section 253(2)

reassessment by issue of notice u/s 148 and consequential assessment u/s 147 of the Act completed wherein a solitary addition of 30% of total payments made to karigars (artisan labours) during the year was made. 3.3 Aggrieved assessee filed an appeal u/s 246A of the Act before first appellate authority which was allowed vide para 4.9 to 4.12 which reads

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, BELAGAVI, BELAGAVI vs. M/S POTDAR BROTHERS, BELAGAVI

Appeals of the Revenue are PARTLY ALLOWED for statistical purposes in aforestated terms

ITA 175/PAN/2025[2018-19]Status: DisposedITAT Panaji18 Nov 2025AY 2018-19

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

For Appellant: Mr Pramod Vaidya [‘Ld. AR’]For Respondent: Mr M Satish [‘Ld. DR’]

Section 132Section 133ASection 138Section 143(1)Section 143(3)Section 147Section 148Section 246ASection 250Section 253(2)

reassessment by issue of notice u/s 148 and consequential assessment u/s 147 of the Act completed wherein a solitary addition of 30% of total payments made to karigars (artisan labours) during the year was made. 3.3 Aggrieved assessee filed an appeal u/s 246A of the Act before first appellate authority which was allowed vide para 4.9 to 4.12 which reads

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, BELAGAVI vs. M/S POTDAR BROTHERS, BELAGAVI

Appeals of the Revenue are PARTLY ALLOWED for statistical purposes in aforestated terms

ITA 176/PAN/2025[2019-20]Status: DisposedITAT Panaji18 Nov 2025AY 2019-20

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

For Appellant: Mr Pramod Vaidya [‘Ld. AR’]For Respondent: Mr M Satish [‘Ld. DR’]

Section 132Section 133ASection 138Section 143(1)Section 143(3)Section 147Section 148Section 246ASection 250Section 253(2)

reassessment by issue of notice u/s 148 and consequential assessment u/s 147 of the Act completed wherein a solitary addition of 30% of total payments made to karigars (artisan labours) during the year was made. 3.3 Aggrieved assessee filed an appeal u/s 246A of the Act before first appellate authority which was allowed vide para 4.9 to 4.12 which reads

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, BELAGAVI, BELAGAVI vs. M/S POTDAR BROTHERS, BELAGAVI

Appeals of the Revenue are PARTLY ALLOWED for statistical purposes in aforestated terms

ITA 179/PAN/2025[2021-22]Status: DisposedITAT Panaji18 Nov 2025AY 2021-22

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

For Appellant: Mr Pramod Vaidya [‘Ld. AR’]For Respondent: Mr M Satish [‘Ld. DR’]

Section 132Section 133ASection 138Section 143(1)Section 143(3)Section 147Section 148Section 246ASection 250Section 253(2)

reassessment by issue of notice u/s 148 and consequential assessment u/s 147 of the Act completed wherein a solitary addition of 30% of total payments made to karigars (artisan labours) during the year was made. 3.3 Aggrieved assessee filed an appeal u/s 246A of the Act before first appellate authority which was allowed vide para 4.9 to 4.12 which reads

M/S CHOWGULE AND COMPANY (SALT) PVT. LTD,MORMUGAO vs. THE ACIT, CIRCLE - 2, MARGAO

The appeal of the assessee is partly allowed in terms of aforesaid observation

ITA 390/PAN/2017[2012-13]Status: DisposedITAT Panaji29 Apr 2022AY 2012-13

Bench: Shri Ravish Sood & Shri Jamlappa D. Battullआयकर अपील सं. / Ita No. : 390/Pan/2017 करधििाारण वर्ा / Assessment Year : 2012-2013 M/S Chowgule & Company (Salt) Pvt Ltd., Chowgule House, Mormugao Harbour, Goa – 403803. Pan: Aabcc 5595 J . . . . . . . अपीलार्थी / Appellant बिाम / V/S Asstt. Commissioner Of Income Tax, Circle-2, Margao, Goa. . . . . . . . प्रत्यर्थी / Respondent द्वारा / Appearances Assessee By : Ms Hiral Sejpal Revenue By : Shri Sourabh Nayak सुनवाई की तारीख / Date Of Conclusive Hearing : 24/02/2022 घोषणा की तारीख / Date Of Pronouncement : 29/04/2022 आदेश / Order Per Jamlappa D Battull Am; The Present Appeal Filed By The Appellant Assessee Is Directed Against The Order Of Commissioner Of Income Tax- Appeals, Panaji-1 [For Short “Cit(A)”] Dt. 09/10/2017 Passed U/S 250 Of The Income-Tax Act, 1961 [For Short “The Act”], Which In Turn Tousled Out Of Order Of Assessment Of Assistant Commissioner Of Income Tax-Circle-2, Margoa [For Short “Ao”] Dt. 27/07/2014 Passed U/S 143(3) Of The Act, For The Assessment Year [For Short “Ay”] 2012-2013. Itat-Panaji Page 1 Of 23

For Appellant: Ms Hiral SejpalFor Respondent: Shri Sourabh Nayak

Section 10(35)Section 115JSection 143(3)Section 14ASection 14A(1)Section 250

reassess under section 147 or pass an order enhancing the assessment or reducing a refund already made or otherwise increasing the liability of the assessee under section 154, ITAT-Panaji Page 13 of 23 M/s Chowgule and Company (Salt) Pvt Ltd ITA No.: 390/PAN/2017, AY : 2012-2013, AABCC5595J for any assessment year beginning on or before

GUALA CLOSURES (INDIA) PVT. LTD.,PANAJI vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX, PANAJI., SELECT CITY

Appeal is dismissed in above terms

ITA 205/PAN/2019[2012-13]Status: DisposedITAT Panaji13 Oct 2023AY 2012-13

Bench: Shri Satbeer Singh Godara & Dr. Dipak Ripote

For Appellant: Shri Ketan VedFor Respondent: Shri P.S. Shivshankar, CIT-DR

Section 143(3)Section 144(3)Section 144CSection 253Section 263Section 4

6) The Dispute Resolution Panel shall issue the directions referred to in sub-section (5), after considering the following, namely:- (a) draft order; (b) objections filed by the assessee; (c) evidence furnished by the assessee; (d) report, if any, of the Assessing Officer, Valuation Officer or Transfer Pricing Officer or any other authority; (e) records relating to the draft order

M/S KAMAT REAL ESTATE DEVELOPERS,,PANAJI vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1), PANAJI., PANAJI

In the result, appeal of the Assessee is allowed

ITA 336/PAN/2018[2005-06]Status: DisposedITAT Panaji17 Aug 2022AY 2005-06

Bench: Shri Chandra Mohan Garg & Shri Girish Agrawal

For Appellant: Sh Sandip Bhandare, C.AFor Respondent: Sh Mayur Kamble, Sr. D.R

Section 142(1)Section 143(1)Section 143(3)Section 147Section 148

reassessment proceedings initiated u/s 147 of I.T. Act by the Assessing Officer were valid, although nothing had been recorded by the Assessing Officer in the reasons about any failure on the part of the Appellant Firm to disclose fully and truly all material facts necessary for the completion of 5 ITA.No.336/PAN./2018 M/s. Kamat Real Estate Developers, Panaji

SMT NEHA PRASANNA GHOTAGE,BELAGAVI vs. INCOME TAX OFFICER, WARD - 1, KARWAR

Appeals are DISMISSED

ITA 268/PAN/2025[2010-11]Status: DisposedITAT Panaji11 Feb 2026AY 2010-11

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

For Appellant: Mr Pramod Vaidya [‘Ld. AR’]For Respondent: Mr Azhar Zain [‘Ld. DR’]

Section 144Section 246ASection 249Section 250Section 253(1)Section 271(1)(c)

section 249 of the Act. ITAT-Panaji Page 6 of 22 Neha Prasanna Ghotage Vs ACIT, Belgaum ITA No. 259 to 268/PAN/2025 AY: 2006-07 to 2010-11 10. Alike in former cases, opportunities provided to showcase ‘sufficient cause’ behind such belated filings in these cases also went futile as no evidence and explanations were filed. In the event

SMT NEHA PRASANNA GHOTAGE,BELAGAVI vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE - 2, BELAGAVI

Appeals are DISMISSED

ITA 263/PAN/2025[2010-11]Status: DisposedITAT Panaji11 Feb 2026AY 2010-11

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

For Appellant: Mr Pramod Vaidya [‘Ld. AR’]For Respondent: Mr Azhar Zain [‘Ld. DR’]

Section 144Section 246ASection 249Section 250Section 253(1)Section 271(1)(c)

section 249 of the Act. ITAT-Panaji Page 6 of 22 Neha Prasanna Ghotage Vs ACIT, Belgaum ITA No. 259 to 268/PAN/2025 AY: 2006-07 to 2010-11 10. Alike in former cases, opportunities provided to showcase ‘sufficient cause’ behind such belated filings in these cases also went futile as no evidence and explanations were filed. In the event

SMT NEHA PRASANNA GHOTAGE,BELAGAVI vs. INCOME TAX OFFICER, WARD - 1, KARWAR

Appeals are DISMISSED

ITA 267/PAN/2025[2009-10]Status: DisposedITAT Panaji11 Feb 2026AY 2009-10

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

For Appellant: Mr Pramod Vaidya [‘Ld. AR’]For Respondent: Mr Azhar Zain [‘Ld. DR’]

Section 144Section 246ASection 249Section 250Section 253(1)Section 271(1)(c)

section 249 of the Act. ITAT-Panaji Page 6 of 22 Neha Prasanna Ghotage Vs ACIT, Belgaum ITA No. 259 to 268/PAN/2025 AY: 2006-07 to 2010-11 10. Alike in former cases, opportunities provided to showcase ‘sufficient cause’ behind such belated filings in these cases also went futile as no evidence and explanations were filed. In the event

SMT NEHA PRASANNA GHOTAGE,BELAGAVI vs. INCOME TAX OFFICER, WARD - 1, KARWAR

Appeals are DISMISSED

ITA 266/PAN/2025[2008-09]Status: DisposedITAT Panaji11 Feb 2026AY 2008-09

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

For Appellant: Mr Pramod Vaidya [‘Ld. AR’]For Respondent: Mr Azhar Zain [‘Ld. DR’]

Section 144Section 246ASection 249Section 250Section 253(1)Section 271(1)(c)

section 249 of the Act. ITAT-Panaji Page 6 of 22 Neha Prasanna Ghotage Vs ACIT, Belgaum ITA No. 259 to 268/PAN/2025 AY: 2006-07 to 2010-11 10. Alike in former cases, opportunities provided to showcase ‘sufficient cause’ behind such belated filings in these cases also went futile as no evidence and explanations were filed. In the event

SMT NEHA PRASANNA GHOTAGE,BELAGAVI vs. INCOME TAX OFFICER, WARD - 1, KARWAR

Appeals are DISMISSED

ITA 264/PAN/2025[2006-07]Status: DisposedITAT Panaji11 Feb 2026AY 2006-07

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

For Appellant: Mr Pramod Vaidya [‘Ld. AR’]For Respondent: Mr Azhar Zain [‘Ld. DR’]

Section 144Section 246ASection 249Section 250Section 253(1)Section 271(1)(c)

section 249 of the Act. ITAT-Panaji Page 6 of 22 Neha Prasanna Ghotage Vs ACIT, Belgaum ITA No. 259 to 268/PAN/2025 AY: 2006-07 to 2010-11 10. Alike in former cases, opportunities provided to showcase ‘sufficient cause’ behind such belated filings in these cases also went futile as no evidence and explanations were filed. In the event

SMT NEHA PRASANNA GHOTAGE,BELAGAVI vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE - 2, BELAGAVI

Appeals are DISMISSED

ITA 262/PAN/2025[2009-10]Status: DisposedITAT Panaji11 Feb 2026AY 2009-10

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

For Appellant: Mr Pramod Vaidya [‘Ld. AR’]For Respondent: Mr Azhar Zain [‘Ld. DR’]

Section 144Section 246ASection 249Section 250Section 253(1)Section 271(1)(c)

section 249 of the Act. ITAT-Panaji Page 6 of 22 Neha Prasanna Ghotage Vs ACIT, Belgaum ITA No. 259 to 268/PAN/2025 AY: 2006-07 to 2010-11 10. Alike in former cases, opportunities provided to showcase ‘sufficient cause’ behind such belated filings in these cases also went futile as no evidence and explanations were filed. In the event

SMT NEHA PRASANNA GHOTAGE,BELAGAVI vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE - 2, BELAGAVI

Appeals are DISMISSED

ITA 261/PAN/2025[2008-09]Status: DisposedITAT Panaji11 Feb 2026AY 2008-09

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

For Appellant: Mr Pramod Vaidya [‘Ld. AR’]For Respondent: Mr Azhar Zain [‘Ld. DR’]

Section 144Section 246ASection 249Section 250Section 253(1)Section 271(1)(c)

section 249 of the Act. ITAT-Panaji Page 6 of 22 Neha Prasanna Ghotage Vs ACIT, Belgaum ITA No. 259 to 268/PAN/2025 AY: 2006-07 to 2010-11 10. Alike in former cases, opportunities provided to showcase ‘sufficient cause’ behind such belated filings in these cases also went futile as no evidence and explanations were filed. In the event

SMT NEHA PRASANNA GHOTAGE,BELAGAVI vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE - 2, BELAGAVI

Appeals are DISMISSED

ITA 260/PAN/2025[2007-08]Status: DisposedITAT Panaji11 Feb 2026AY 2007-08

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

For Appellant: Mr Pramod Vaidya [‘Ld. AR’]For Respondent: Mr Azhar Zain [‘Ld. DR’]

Section 144Section 246ASection 249Section 250Section 253(1)Section 271(1)(c)

section 249 of the Act. ITAT-Panaji Page 6 of 22 Neha Prasanna Ghotage Vs ACIT, Belgaum ITA No. 259 to 268/PAN/2025 AY: 2006-07 to 2010-11 10. Alike in former cases, opportunities provided to showcase ‘sufficient cause’ behind such belated filings in these cases also went futile as no evidence and explanations were filed. In the event

SMT NEHA PRASANNA GHOTAGE,BELAGAVI vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, 2, BELAGAVI

Appeals are DISMISSED

ITA 259/PAN/2025[2006-07]Status: DisposedITAT Panaji11 Feb 2026AY 2006-07

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

For Appellant: Mr Pramod Vaidya [‘Ld. AR’]For Respondent: Mr Azhar Zain [‘Ld. DR’]

Section 144Section 246ASection 249Section 250Section 253(1)Section 271(1)(c)

section 249 of the Act. ITAT-Panaji Page 6 of 22 Neha Prasanna Ghotage Vs ACIT, Belgaum ITA No. 259 to 268/PAN/2025 AY: 2006-07 to 2010-11 10. Alike in former cases, opportunities provided to showcase ‘sufficient cause’ behind such belated filings in these cases also went futile as no evidence and explanations were filed. In the event

SMT NEHA PRASANNA GHOTAGE,BELAGAVI vs. INCOME TAX OFFICER, WARD - 1, KARWAR

Appeals are DISMISSED

ITA 265/PAN/2025[2007-08]Status: DisposedITAT Panaji11 Feb 2026AY 2007-08

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

For Appellant: Mr Pramod Vaidya [‘Ld. AR’]For Respondent: Mr Azhar Zain [‘Ld. DR’]

Section 144Section 246ASection 249Section 250Section 253(1)Section 271(1)(c)

section 249 of the Act. ITAT-Panaji Page 6 of 22 Neha Prasanna Ghotage Vs ACIT, Belgaum ITA No. 259 to 268/PAN/2025 AY: 2006-07 to 2010-11 10. Alike in former cases, opportunities provided to showcase ‘sufficient cause’ behind such belated filings in these cases also went futile as no evidence and explanations were filed. In the event

MARIA ESTIBEIRO,PANAJI vs. DCIT, CIRCLE - 1(1), PANAJI

The appeal stands ALLOWED

ITA 34/PAN/2024[2012-13]Status: DisposedITAT Panaji24 Apr 2025AY 2012-13

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshaliassessment Year : 2012-13 Maria Estibeiro L/H Of Jacintodas Estibeiro 781, St. Marys Colony, Miramar, Goa. Pan:Aabpe2798N . . . . . . . Appellant V/S Dy. Commissioner Of Income Tax, Panaji, Goa. . . . . . . . Respondent Appearances Assessee By : Mr D E Robinson [‘Ld. Ar’] Revenue By : Mr Vimalraj Periyagounden [‘Ld. Dr’] Date Of Conclusive Hearing : 25/03/2025 Date Of Pronouncement : 24/04/2025 Order Per G. D. Padmahshali, Am; By This Appeal Captioned Appellant Impugns Din & Order No. 1060336601(1) Dt. 31/01/2024 Passed U/S 250 Of The Income-Tax Act, 1961 [‘The Act’] By The National Faceless Appeal Centre, Delhi [‘Nfac’] Which In Turn Arisen Out Of Order Of Assessment Passed U/S 147 R.W.S. 144 Of The Act For Assessment Year 2012- 13 [‘Ay’].

For Appellant: Mr D E Robinson [‘Ld. AR’]For Respondent: Mr Vimalraj Periyagounden [‘Ld. DR’]

Section 142(1)Section 144Section 147Section 148Section 250Section 56(2)

c) maturity proceeds of deposits of ₹9,10,547/- [BOI]. To verify nature & source of all such credits, various notices u/s 142(1) of the Act were issued. There was no compliance to any of such notices nor was there any submission by the appellant. In absence of evidences and in the event no response forthcoming from the appellant

NANU RESORTS PVT. LTD.,MARGAO vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE- 1., MARGAO

In the result, both the appeals of the assessee are allowed

ITA 394/PAN/2018[2005-06]Status: DisposedITAT Panaji30 Aug 2022AY 2005-06

Bench: Shri Chandra Mohan Garg & Shri Girish Agrawalita Nos.393 & 394/Pan/2018 Assessment Years: 2004-05 & 2005-06 Nanu Resorts Pvt. Acit, Circle-1, Ltd. Margao Nanu House, Varde Vs. Valaulikar Road, Margao- Goa Pan: Aaacn 7114 P (Appellant) (Respondent) Present For: Appellant By : None Respondent By : Shri Mayur Kamble, Sr. Dr Date Of Hearing : 15.06.2022 Date Of Pronouncement : 30.08.2022 O R D E R Per Girish Agrawal: These Two Appeals By The Assessee Arising Out Of The Order Of Ld. Cit(A), Panaji-1, Panaji In Ita Nos.305 & 306/Mrg/2014-15 Dated 02.07.2018 Against The Assessment Order Passed By Dcit, Circle-1, Margao-Goa U/S 143(3) Of The Income-Tax Act, 1961 (Hereinafter Referred To As The ‘Act’) Dated 25.10.2011 For Both A.Y. 2004-05 & A.Y. 2005-06. 2. The Issue Involved In Both These Appeals Are Common Which Relates To Treatment Of Expenditure Incurred By The Assessee For Replacement Of Assets & Renovation As Revenue Or Capital In Nature. For Ay 2004-05, The Quantum Of Expenditure In Dispute Is Of Rs. 10,81,672/- & For Ay 2005-06 It Is Rs. 2,06,379/-. A.Ys. 2004-05 & 2005-06 3. Before Us, None Appeared On Behalf Of The Assessee & Shri Mayur Kamble, Sr. Dr Represented The Department.

For Appellant: NoneFor Respondent: Shri Mayur Kamble, Sr. DR

Section 143(3)Section 147Section 148

Section 148 of the Act, for which notice u/s 148 of the Act was issued and served on the assessee on 22.03.2011. In the course of reassessment, inter-alia, Ld. A.O made a disallowance of expenses towards repairs and maintenance by treating it as capital expenditure for an amount of Rs. 20,76,892/-, for which the assessee went