I.T.O. vs. M/S KUMAR CONSTRUCLTION,
In the result, the appeal of the Revenue is partly allowed
ITA 10/PAT/2015[2009-10]Status: DisposedITAT Patna17 Oct 2023AY 2009-10
Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Rajesh Kumar
Section 142(1)Section 143(2)Section 271(1)(b)Section 40A(3)
182 the AAC on an appeal preferred by the assessee had jurisdiction to invoke, for the first time provisions of rule 33 of the Indian Income-tax Rules, 1922, for the purpose of computing the income of a nonresident even if the ITO had not done so in the assessment proceedings.
In CIT v. Kanpur Coal Syndicate