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101 results for “house property”+ Section 153Aclear

Sorted by relevance

Delhi1,128Mumbai756Bangalore398Jaipur292Chennai235Hyderabad225Cochin146Chandigarh107Indore104Visakhapatnam101Pune101Amritsar81Ahmedabad71Rajkot48Kolkata41Agra33Guwahati29Nagpur29Patna27Lucknow24Karnataka21Jodhpur20Raipur20Surat20Dehradun18Cuttack14Allahabad14Kerala7Telangana6Varanasi4SC2Ranchi1Rajasthan1Jabalpur1

Key Topics

Section 153A88Section 143(3)83Addition to Income83Section 13272Section 271(1)(c)59Search & Seizure45Section 80I43Section 14842Section 143(2)34Section 147

DCIT CIRCLE 1 NASHIK, NASHIK vs. SHREE SAI PROPERTIES, NASHIK

In the result, appeal of the Revenue is dismissed

ITA 987/PUN/2025[2014-15]Status: DisposedITAT Pune27 Jan 2026AY 2014-15

Bench: Dr. Manish Borad & Shri Vinay Bhamore

For Appellant: Shri Subodh Ratnaparkhi, CAFor Respondent: Shri Amit Bobde, CIT
Section 132Section 143(2)Section 143(3)Section 147Section 148Section 250

153A read with Section 153C by incorporating the "non-obstante" clause, in these provisions, which carves out an exception to any normal/regular action being resarted under Section 147. 24. In this view of the matter, we are of the clear opinion that the impugned notice under Section 147 of the I.T. Act and all actions consequent thereto are required

Showing 1–20 of 101 · Page 1 of 6

32
Reopening of Assessment28
Disallowance19

DCIT, CC-2(1), PUNE, PUNE vs. VINOD RAMCHANDRA JADHAV, PUNE

In the result, the appeal filed by the Revenue is dismissed and the appeal filed by the assessee is partly allowed

ITA 1307/PUN/2024[2010-11]Status: DisposedITAT Pune21 Apr 2025AY 2010-11

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2010-11 Dcit, Vinod Ramchandra Jadhav Central Circle 2(1), Vs. Plot No.42-44, Green Park Society, Pune Viman Nagar, Pune – 411014 Pan: Aanpj0592P (Appellant) (Respondent) Assessment Year : 2010-11 Vinod Ramchandra Jadhav Dcit, Plot No.42-44, Green Park Society, Vs. Central Circle 2(1), Pune Viman Nagar, Pune – 411014 Pan: Aanpj0592P (Appellant) (Respondent) Assessee By : Shri Kishor B Phadke Department By : Shri Ajay Kumar Keshari – Cit & Shri Arvind Desai, Addl Cit-Dr Date Of Hearing : 23-01-2025 Date Of Pronouncement : 21-04-2025 O R D E R

For Appellant: Shri Kishor B PhadkeFor Respondent: Shri Ajay Kumar Keshari – CIT and Shri Arvind Desai, Addl CIT-DR
Section 132Section 139(1)Section 153ASection 245C(1)Section 245DSection 245D(4)Section 245HSection 271(1)(c)

house property in respect of Talegaon flat of Rs.31,920/- and Rs.42,000/- from Lunkad Collonade Viman Nagar property is concerned, it is the submission of the Ld. Counsel for the assessee that due to some arithmetical error, there was shortfall in disclosing that rental income but rental income from the above two properties was disclosed. We find some force

VINOD RAMCHANDRA JADHAV,PUNE vs. DCIT, CC-2(1), PUNE, PUNE

In the result, the appeal filed by the Revenue is dismissed and the appeal filed by the assessee is partly allowed

ITA 2144/PUN/2024[AY 2010-11]Status: DisposedITAT Pune21 Apr 2025

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2010-11 Dcit, Vinod Ramchandra Jadhav Central Circle 2(1), Vs. Plot No.42-44, Green Park Society, Pune Viman Nagar, Pune – 411014 Pan: Aanpj0592P (Appellant) (Respondent) Assessment Year : 2010-11 Vinod Ramchandra Jadhav Dcit, Plot No.42-44, Green Park Society, Vs. Central Circle 2(1), Pune Viman Nagar, Pune – 411014 Pan: Aanpj0592P (Appellant) (Respondent) Assessee By : Shri Kishor B Phadke Department By : Shri Ajay Kumar Keshari – Cit & Shri Arvind Desai, Addl Cit-Dr Date Of Hearing : 23-01-2025 Date Of Pronouncement : 21-04-2025 O R D E R

For Appellant: Shri Kishor B PhadkeFor Respondent: Shri Ajay Kumar Keshari – CIT and Shri Arvind Desai, Addl CIT-DR
Section 132Section 139(1)Section 153ASection 245C(1)Section 245DSection 245D(4)Section 245HSection 271(1)(c)

house property in respect of Talegaon flat of Rs.31,920/- and Rs.42,000/- from Lunkad Collonade Viman Nagar property is concerned, it is the submission of the Ld. Counsel for the assessee that due to some arithmetical error, there was shortfall in disclosing that rental income but rental income from the above two properties was disclosed. We find some force

MRS. VASUNDHARA SHAILESH JOSHI,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

In the result, appeals in the case of Mrs

ITA 96/PUN/2016[2010-11]Status: DisposedITAT Pune27 Mar 2018AY 2010-11

Bench: Ms. Sushma Chowla, Jm & Shri D. Karunakara Rao, Am आयकर अपीऱ सं. / Ita Nos.95 & 96/Pun/2016 यििाारण वषा / Assessment Years : 2009-10 & 2010-11

For Appellant: S/Shri Nikhil Pathak /For Respondent: Shri Hitendra Ninawe
Section 250Section 271(1)(c)

Housing Ltd. Vs. ITO (2014) 45 taxmann.com 144 (Kar), wherein it has been held that Chpter XIV-B does not preclude the Assessing Officer to proceed against the assessee by issuing notice under section 148 of the Act. He thus, stressed that after search proceedings carried out in the case of another person, it was open to the Assessing Officer

MRS. VASUNDHARA SHAILESH JOSHI,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

In the result, appeals in the case of Mrs

ITA 95/PUN/2016[2009-10]Status: DisposedITAT Pune27 Mar 2018AY 2009-10

Bench: Ms. Sushma Chowla, Jm & Shri D. Karunakara Rao, Am आयकर अपीऱ सं. / Ita Nos.95 & 96/Pun/2016 यििाारण वषा / Assessment Years : 2009-10 & 2010-11

For Appellant: S/Shri Nikhil Pathak /For Respondent: Shri Hitendra Ninawe
Section 250Section 271(1)(c)

Housing Ltd. Vs. ITO (2014) 45 taxmann.com 144 (Kar), wherein it has been held that Chpter XIV-B does not preclude the Assessing Officer to proceed against the assessee by issuing notice under section 148 of the Act. He thus, stressed that after search proceedings carried out in the case of another person, it was open to the Assessing Officer

JOSHI WADEWALE SHEWALWADI,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

In the result, appeals in the case of Mrs

ITA 100/PUN/2016[2010-11]Status: DisposedITAT Pune27 Mar 2018AY 2010-11

Bench: Ms. Sushma Chowla, Jm & Shri D. Karunakara Rao, Am आयकर अपीऱ सं. / Ita Nos.95 & 96/Pun/2016 यििाारण वषा / Assessment Years : 2009-10 & 2010-11

For Appellant: S/Shri Nikhil Pathak /For Respondent: Shri Hitendra Ninawe
Section 250Section 271(1)(c)

Housing Ltd. Vs. ITO (2014) 45 taxmann.com 144 (Kar), wherein it has been held that Chpter XIV-B does not preclude the Assessing Officer to proceed against the assessee by issuing notice under section 148 of the Act. He thus, stressed that after search proceedings carried out in the case of another person, it was open to the Assessing Officer

JOSHI WADEWALE SHEWALWADI,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

In the result, appeals in the case of Mrs

ITA 99/PUN/2016[2009-10]Status: DisposedITAT Pune27 Mar 2018AY 2009-10

Bench: Ms. Sushma Chowla, Jm & Shri D. Karunakara Rao, Am आयकर अपीऱ सं. / Ita Nos.95 & 96/Pun/2016 यििाारण वषा / Assessment Years : 2009-10 & 2010-11

For Appellant: S/Shri Nikhil Pathak /For Respondent: Shri Hitendra Ninawe
Section 250Section 271(1)(c)

Housing Ltd. Vs. ITO (2014) 45 taxmann.com 144 (Kar), wherein it has been held that Chpter XIV-B does not preclude the Assessing Officer to proceed against the assessee by issuing notice under section 148 of the Act. He thus, stressed that after search proceedings carried out in the case of another person, it was open to the Assessing Officer

JOSHI WADEWALE HADAPSAR,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

In the result, appeals in the case of Mrs

ITA 105/PUN/2016[2010-11]Status: DisposedITAT Pune27 Mar 2018AY 2010-11

Bench: Ms. Sushma Chowla, Jm & Shri D. Karunakara Rao, Am आयकर अपीऱ सं. / Ita Nos.95 & 96/Pun/2016 यििाारण वषा / Assessment Years : 2009-10 & 2010-11

For Appellant: S/Shri Nikhil Pathak /For Respondent: Shri Hitendra Ninawe
Section 250Section 271(1)(c)

Housing Ltd. Vs. ITO (2014) 45 taxmann.com 144 (Kar), wherein it has been held that Chpter XIV-B does not preclude the Assessing Officer to proceed against the assessee by issuing notice under section 148 of the Act. He thus, stressed that after search proceedings carried out in the case of another person, it was open to the Assessing Officer

JOSHI WADEWALE PRABHAT CINEMA,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

In the result, appeals in the case of Mrs

ITA 102/PUN/2016[2010-11]Status: DisposedITAT Pune27 Mar 2018AY 2010-11

Bench: Ms. Sushma Chowla, Jm & Shri D. Karunakara Rao, Am आयकर अपीऱ सं. / Ita Nos.95 & 96/Pun/2016 यििाारण वषा / Assessment Years : 2009-10 & 2010-11

For Appellant: S/Shri Nikhil Pathak /For Respondent: Shri Hitendra Ninawe
Section 250Section 271(1)(c)

Housing Ltd. Vs. ITO (2014) 45 taxmann.com 144 (Kar), wherein it has been held that Chpter XIV-B does not preclude the Assessing Officer to proceed against the assessee by issuing notice under section 148 of the Act. He thus, stressed that after search proceedings carried out in the case of another person, it was open to the Assessing Officer

RAJDEEP BUILDCON PRIVAT LIMITED, AHMEDNAGAR,AHMEDNAGAR vs. DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 1(2), PUNE, PUNE

In the result, the appeal filed by the assessee in ITA

ITA 468/PUN/2022[2012-13]Status: DisposedITAT Pune18 Sept 2024AY 2012-13

Bench: SHRI R. K. PANDA (Vice President), SHRI VINAY BHAMORE (Judicial Member)

For Appellant: Smt. Deepa KhareFor Respondent: Shri Ajay Kumar Keshari
Section 132Section 139Section 143(3)Section 14ASection 153A

House, Near Bhide Hospital, Savedi, Ahmednagar- 414003. PAN : AAACR8605D Appellant Respondent Assessee by : Smt. Deepa Khare Revenue by : Shri Ajay Kumar Keshari Date of hearing : 25.06.2024 Date of pronouncement : 18.09.2024 आदेश / ORDER PER VINAY BHAMORE, JM: The above captioned three appeals filed by the assessee are directed against the separate orders dated 27.04.2022 passed by ld. CIT(A)-11, Pune

RAJDEEP BUILDCON PVT LTD, AHMEDNAGAR,AHMEDNAGAR vs. DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 1(2), PUNE, PUNE

In the result, the appeal filed by the assessee in ITA

ITA 469/PUN/2022[2013-14]Status: DisposedITAT Pune18 Sept 2024AY 2013-14

Bench: SHRI R. K. PANDA (Vice President), SHRI VINAY BHAMORE (Judicial Member)

For Appellant: Smt. Deepa KhareFor Respondent: Shri Ajay Kumar Keshari
Section 132Section 139Section 143(3)Section 14ASection 153A

House, Near Bhide Hospital, Savedi, Ahmednagar- 414003. PAN : AAACR8605D Appellant Respondent Assessee by : Smt. Deepa Khare Revenue by : Shri Ajay Kumar Keshari Date of hearing : 25.06.2024 Date of pronouncement : 18.09.2024 आदेश / ORDER PER VINAY BHAMORE, JM: The above captioned three appeals filed by the assessee are directed against the separate orders dated 27.04.2022 passed by ld. CIT(A)-11, Pune

RAJDEEP BUILDCOM PRIVATE LIMITED,AHMEDNAGAR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE - 1(2), PUNE, PUNE

In the result, the appeal filed by the assessee in ITA

ITA 467/PUN/2022[2011-12]Status: DisposedITAT Pune18 Sept 2024AY 2011-12

Bench: SHRI R. K. PANDA (Vice President), SHRI VINAY BHAMORE (Judicial Member)

For Appellant: Smt. Deepa KhareFor Respondent: Shri Ajay Kumar Keshari
Section 132Section 139Section 143(3)Section 14ASection 153A

House, Near Bhide Hospital, Savedi, Ahmednagar- 414003. PAN : AAACR8605D Appellant Respondent Assessee by : Smt. Deepa Khare Revenue by : Shri Ajay Kumar Keshari Date of hearing : 25.06.2024 Date of pronouncement : 18.09.2024 आदेश / ORDER PER VINAY BHAMORE, JM: The above captioned three appeals filed by the assessee are directed against the separate orders dated 27.04.2022 passed by ld. CIT(A)-11, Pune

ALNESH AKIL SOMJI,PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX, PUNE

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

ITA 35/PUN/2025[2019-20]Status: DisposedITAT Pune27 Jun 2025AY 2019-20

Bench: Shri R. K. Panda & Ms Astha Chandra

For Appellant: Shri Nitin RanderFor Respondent: Shri Amol Khairnar CIT-DR
Section 132Section 139(1)Section 143(2)Section 153ASection 24

153A of the Act which was not made in the return filed u/s 139(1) of the Act. Further, the assessee in his reply filed on 21.04.2021 has submitted that in the revised computation of income the assessee has not claimed the set off and the loss has been carried forward to the succeeding years. In view of this

SHAMKANT KESHAV KOTKAR (PROP. NANDAN BUILDERS),PUNE vs. PR. COMMISSIONER OF INCOME TAX (CENTRAL), PUNE

In the result, appeal of the assessee is allowed

ITA 1358/PUN/2025[2017-18]Status: DisposedITAT Pune31 Dec 2025AY 2017-18

Bench: SHRI VINAY BHAMORE (Judicial Member)

Section 132Section 142(1)Section 143(3)Section 153Section 153ASection 153CSection 26Section 263Section 40

153A. The AO has not verified the issue of Cash Loan; hence the Assessment Order is erroneous and prejudicial to the interest of revenue. As per Explanation-2 of the Section 263, Assessment Order will be deemed to be erroneous and prejudicial if Pr.CIT is of the opinion that Assessment Order(AO) is passed without making any Inquiry or verification

PRASAD RAMCHANDRA PATIL,URAN, PANVEL vs. ITO WARD 3, PANVEL, PANVEL

Accordingly, the grounds raised by the assessee are allowed for statistical purposes

ITA 2340/PUN/2024[2017-18]Status: DisposedITAT Pune18 Feb 2026AY 2017-18

Bench: Shri R.K. Panda & Ms. Astha Chandra

For Appellant: Shri Prakash PanditFor Respondent: Shri Amit Bobde
Section 132ASection 144Section 153ASection 69A

House No. 1275, Vindhare Village Post Digode, Tal Uran Panvel, Vs. Dist. Raigad-401206 PAN : ASJPP8541J अपीलार्थी / Appellant प्रत्यर्थी / Respondent Assessee by : Shri Prakash Pandit Department by : Shri Amit Bobde Date of hearing : 02-02-2026 Date of 18-02-2026 Pronouncement : आदेश / ORDER PER ASTHA CHANDRA, JM : The above three appeals filed by the assessee are directed against

PRASAD RAMCHANDRA PATIL,URAN, PANVEL vs. ITO WARD 3, PANVEL, PANVEL

Accordingly, the grounds raised by the assessee are allowed for statistical purposes

ITA 2338/PUN/2024[2014-15]Status: DisposedITAT Pune18 Feb 2026AY 2014-15

Bench: Shri R.K. Panda & Ms. Astha Chandra

For Appellant: Shri Prakash PanditFor Respondent: Shri Amit Bobde
Section 132ASection 144Section 153ASection 69A

House No. 1275, Vindhare Village Post Digode, Tal Uran Panvel, Vs. Dist. Raigad-401206 PAN : ASJPP8541J अपीलार्थी / Appellant प्रत्यर्थी / Respondent Assessee by : Shri Prakash Pandit Department by : Shri Amit Bobde Date of hearing : 02-02-2026 Date of 18-02-2026 Pronouncement : आदेश / ORDER PER ASTHA CHANDRA, JM : The above three appeals filed by the assessee are directed against

PRASAD RAMCHANDRA PATIL,URAN, PANVEL vs. ITO - WARD 3, PANVEL, PANVEL

Accordingly, the grounds raised by the assessee are allowed for statistical purposes

ITA 2339/PUN/2024[2015-16]Status: DisposedITAT Pune18 Feb 2026AY 2015-16

Bench: Shri R.K. Panda & Ms. Astha Chandra

For Appellant: Shri Prakash PanditFor Respondent: Shri Amit Bobde
Section 132ASection 144Section 153ASection 69A

House No. 1275, Vindhare Village Post Digode, Tal Uran Panvel, Vs. Dist. Raigad-401206 PAN : ASJPP8541J अपीलार्थी / Appellant प्रत्यर्थी / Respondent Assessee by : Shri Prakash Pandit Department by : Shri Amit Bobde Date of hearing : 02-02-2026 Date of 18-02-2026 Pronouncement : आदेश / ORDER PER ASTHA CHANDRA, JM : The above three appeals filed by the assessee are directed against

M/S. VIKRAM DEVELOPERS & PROMOTERS,,PUNE vs. DEPUTY COMMISSIONER OF INCOME TAX,,

In the result, the appeal of the assessee in ITA No

ITA 2795/PUN/2016[2012-13]Status: DisposedITAT Pune14 Nov 2019AY 2012-13

Bench: Shri D. Karunakara Rao, Am & Shri Partha Sarathi Chaudhury, Jm आयकर अपील सं. / Ita Nos.2795 & 2796/Pun/2016 िनधा"रण वष" / Assessment Years : 2012-13 & 2013-14 M/S. Vikram Developers & Promoters, 19, Shrikrishna Heights, Ganeshkhind Road, Shivaji Nagar, Pune-411005. .......अपीलाथ" / Appellant Pan : Aagfv4298R बनाम / V/S. Dcit, Central Circle-2(1), ……""यथ" / Respondent Pune. Assessee By : Shri Kishor Phadke Revenue By : Shri Milind Chahure सुनवाई क" तारीख / Date Of Hearing : 17.10.2019 घोषणा क" तारीख / Date Of Pronouncement : 14.11.2019 आदेश / Order Per D. Karunakara Rao, Am: There Are Two Appeals Under Consideration Filed By The Assessee Against The Common Orders Of The Cit(A)-12, Pune Dated 08.09.2016 For The Assessment Years 2012-13 & 2013-14 Respectively. Preliminary Issue - Condonation Of Delay – Both Appeals 2. Before Us, At The Outset, Ld. Counsel For The Assessee Submitted That The Both The Appeals Could Not Be Filed In Time & The Said Appeals Were Filed With The Delay Of 01 Day. In This Regard, Ld. Counsel For The Assessee Submitted That The Delay Is Unintentional & Prayed For Condoning The Same. 3. After Hearing Both The Sides & Considering The Smallness Of Delay In Filing Of Both The Appeals, We Condone The Delay & Proceed To Adjudicate The Appeals Of The Assessee In The Following Paragraphs. 4. The Facts & Grounds Are Common In Both The Appeals, Therefore, Both The Appeals Were Heard Together & Are Being Disposed Of By This Composite Order. Accordingly, The Appeal-Wise Adjudication Is Taken Up In The Following Paragraphs.

For Appellant: Shri Kishor PhadkeFor Respondent: Shri Milind Chahure
Section 132Section 68Section 80I

property i.e. builders. The housing project undertaken by the assessee was approved by the competent authority and accordingly, assessee claimed deduction under section 80IB of the Act of 100% of the profit from the housing project. We noted that Chapter XII BA i.e. special provisions relating to certain persons other than a company was introduced by the Finance

VIKRAM DEVELOPERS & PROMOTERS,,PUNE vs. DEPUTY COMMISSIONER OF INCOME TAX,,

In the result, the appeal of the assessee in ITA No

ITA 2796/PUN/2016[2013-14]Status: DisposedITAT Pune14 Nov 2019AY 2013-14

Bench: Shri D. Karunakara Rao, Am & Shri Partha Sarathi Chaudhury, Jm आयकर अपील सं. / Ita Nos.2795 & 2796/Pun/2016 िनधा"रण वष" / Assessment Years : 2012-13 & 2013-14 M/S. Vikram Developers & Promoters, 19, Shrikrishna Heights, Ganeshkhind Road, Shivaji Nagar, Pune-411005. .......अपीलाथ" / Appellant Pan : Aagfv4298R बनाम / V/S. Dcit, Central Circle-2(1), ……""यथ" / Respondent Pune. Assessee By : Shri Kishor Phadke Revenue By : Shri Milind Chahure सुनवाई क" तारीख / Date Of Hearing : 17.10.2019 घोषणा क" तारीख / Date Of Pronouncement : 14.11.2019 आदेश / Order Per D. Karunakara Rao, Am: There Are Two Appeals Under Consideration Filed By The Assessee Against The Common Orders Of The Cit(A)-12, Pune Dated 08.09.2016 For The Assessment Years 2012-13 & 2013-14 Respectively. Preliminary Issue - Condonation Of Delay – Both Appeals 2. Before Us, At The Outset, Ld. Counsel For The Assessee Submitted That The Both The Appeals Could Not Be Filed In Time & The Said Appeals Were Filed With The Delay Of 01 Day. In This Regard, Ld. Counsel For The Assessee Submitted That The Delay Is Unintentional & Prayed For Condoning The Same. 3. After Hearing Both The Sides & Considering The Smallness Of Delay In Filing Of Both The Appeals, We Condone The Delay & Proceed To Adjudicate The Appeals Of The Assessee In The Following Paragraphs. 4. The Facts & Grounds Are Common In Both The Appeals, Therefore, Both The Appeals Were Heard Together & Are Being Disposed Of By This Composite Order. Accordingly, The Appeal-Wise Adjudication Is Taken Up In The Following Paragraphs.

For Appellant: Shri Kishor PhadkeFor Respondent: Shri Milind Chahure
Section 132Section 68Section 80I

property i.e. builders. The housing project undertaken by the assessee was approved by the competent authority and accordingly, assessee claimed deduction under section 80IB of the Act of 100% of the profit from the housing project. We noted that Chapter XII BA i.e. special provisions relating to certain persons other than a company was introduced by the Finance

ALNESH MOHAMADAKIL SOMJI,PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX, PUNE

ITA 34/PUN/2025[2018-19]Status: DisposedITAT Pune27 Jun 2025AY 2018-19

Bench: Shri R. K. Panda & Ms Astha Chandra

For Appellant: Shri Nitin RanderFor Respondent: Shri Amol Khairnar CIT-DR
Section 132Section 139(1)Section 143(2)Section 14ASection 153ASection 24

153A of the Act which was not made in the return filed u/s 139(1) of the Act. Further, the assessee in his reply filed on 21.04.2021 has submitted that in the revised computation of income the assessee has not claimed the set off and the loss has been carried forward to the succeeding years. In view of this