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In the result, appeal of the revenue is partly allowed for statistical purposes in terms of our aforesaid observations
Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अपील सं./Ita No.88/Rpr/2020 ("नधा"रण वष" / Assessment Year: 2014-15)
Section 23 68 of the Act which are applicable for the relevant A.Y.2014-15. We, therefore, set-aside the order of the CIT(A) and restore the issue to the file of the A.O for adjudicating the same afresh. Needless to say, the AO shall grant reasonable opportunity of being heard to the assessee in the set-aside proceedings. Thus