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46 results for “TDS”+ Section 142clear

Sorted by relevance

Mumbai1,217Delhi1,111Bangalore469Kolkata311Hyderabad292Chennai255Jaipur202Chandigarh169Ahmedabad153Pune151Indore123Cochin115Visakhapatnam102Karnataka102Rajkot70Raipur60Surat46Patna44Nagpur42Dehradun40Lucknow35Guwahati28Cuttack27Jodhpur26Agra26Allahabad16Amritsar13Ranchi13Panaji11Jabalpur9Varanasi6Telangana5SC4Calcutta4Bombay1

Key Topics

Section 26347Section 143(3)47Addition to Income38Section 6823TDS21Section 142(1)17Disallowance15Section 14414Section 254(1)13Section 148

SANSKRUTI MEGA STRUCTURE PVT. LIMITED,SURAT vs. DCIT, CENTRAL CIRCLE-2(1)(2), SURAT

In the result the grounds of appeal raised by the assessee are allowed

ITA 28/SRT/2018[2014-15]Status: DisposedITAT Surat19 May 2021AY 2014-15

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini(Hearing In Virtual Court) Sanskruti Mega Structure Pvt. The Deputy Ltd., Commissioner Of Income Vs 203, Mnirman Bhavan, Tax, Central Circle- Majura Gate, Surat. 2(1)(2), Surat. Pan : Aamcs 5055 Q Applicant Respondent

Section 142(1)Section 143(3)Section 254(1)Section 271(1)(b)

section 142(1) of the Act on 11.08.2016 along with certain questionnaires. The AO noted that the assessee has debited an amount of Sanskruti Mega Structure Pvt. Ltd., (AY 2014-15) Rs. 73,388/- on account of interest on TDS

HARMONY YARNS PVT. LTD.,SURAT vs. PR. COMMISSIONER OF INCOME TAX -1, SURAT

In the result, the appeal filed by the assessee is partly allowed in above terms

Showing 1–20 of 46 · Page 1 of 3

11
Section 143(2)11
Deduction11
ITA 348/SRT/2023[2018-19]Status: DisposedITAT Surat23 Nov 2023AY 2018-19

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.348/Srt/2023 Assessment Year: (2018-19) (Physical Hearing) Harmony Yarns Private Vs. The Pcit-1, Limited, Surat Plot-65, 1St Floor Subhash Nagar Society, Ghod Dod Road, Nr. Ram Chowk, Surat – 395001. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaach5895F (Appellant) (Respondent) Appellant By Shri Rasesh Shah, Ca Respondent By Shri Airiju Jaikaran, Cit(Dr) Date Of Hearing 12/10/2023 23/11/2023 Date Of Pronouncement

Section 143(3)Section 263Section 36(1)(va)Section 68

Section 263 of the Income Tax Act and is required to be revised u/s 263 of the Act, 1961. Accordingly, ld. PCIT issued show cause notice bearing DIN No. ITBA/COM/F/17/2022- 23/1050992059(l) dated 20.03.2023 and was duly served upon the assessee, through e-proceedings and the assessee -company was provided an opportunity of being heard and to offer explanation

M/S SEVEN EAGLE PRODUCTION,SURAT vs. THE ASSISTANT COMMISSIONER INCOME TAX, CIRCLE-3(2), SURAT

In the result, appeal of the assessee is allowed for statistical purpose

ITA 24/SRT/2019[2009-10]Status: DisposedITAT Surat09 Sept 2021AY 2009-10

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini(Hearing In Virtual Court) Seven Eagle Production, The Assistant 5/6, Paras Shopping Centre, Commissioner Of Income Vs. Near.Gajera Circle, Katargam, Tax, Circle-3(2), Surat. Email:Srshethtax@Gmail.Com Surat – 395004. Pan: Abffs 0860 C Applicant Respondent

Section 143(2)Section 143(3)Section 147Section 148Section 254(1)Section 40

section 143(2) and 142(1) and supplying reasons recorded, proceeded for re- assessment. During the assessment the assessee was asked to submits the details of tax deducted at sources on the payments of various expenses of Rs. 4.37 Crore, as mentioned in para 6.1 of the assessment order. The assessee filed its reply as recorded in para

SHIVAM RESIDENTIAL CONSTRUCTION (INDIA) PVT. LTD.,VALSAD vs. PRINCIPAL COMMISSIONER OF INCOME TAX, VALSAD

In the result, appeal of the assessee is dismissed

ITA 396/SRT/2018[2013-14]Status: DisposedITAT Surat10 Feb 2023AY 2013-14

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.396/Srt/2018 ("नधा"रणवष" / Assessment Year: (2013-14) (Virtual Court Hearing) Shivam Residential Construction Principal Commissioner Of (India) Pvt. Ltd., New Civil Income-Tax-Valsad, Palak Vs. Hospital Road, Nanakwada, Valsad Arcade, Pali Hill, Santinagar, Tithal Road, Valsad-396001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aapcs 3137 G (Appellant) (Respondent) िनधा"रती की ओर से /Assessee By : Shri Milin Mehta, C.A राज"व क" ओर से /Respondent By: Shri Ashish Pophare, Cit-D.R

For Appellant: Shri Milin Mehta, C.AFor Respondent: Shri Ashish Pophare, CIT-D.R
Section 143(3)Section 263Section 68

142(1) of the Act, it is vivid that Assessing Officer has never asked the question/issues raised by ld PCIT. We note that ld PCIT has raised four issues in his revision order under section 263 of the Act, as noted by us above, however, none of the issue has been examined by the assessing officer. It is a case

HASUMATIBEN JAGDISHBHAI PATEL, ,SURAT vs. PRINCIPAL COMMISSIONER OF INCOME TAX, VALSAD

In the result, appeal of assessee is allowed

ITA 322/SRT/2023[2018-19]Status: DisposedITAT Surat22 Nov 2023AY 2018-19

Bench: Shri Pawan Singh & Dr Arjun Lal Sainiआ.अ.सं./Ita No.322/Srt/2023 (Ay 2018-19) (Hearing In Physical Court) Hasumatiben Jagdishbhai Principal Commissioner Of Patel Income-Tax, Valsad, 301, Vs 80 Shree Ram Estate, Opp. 3Rd Floor, Income Tax Pandesara Petrol Pump Office, Palak Arcade, Shanti Bhedwad, Surat-394220 Nagar, Tithal Road, Pan : Aaopp 1698 K Valsad-396001 अपीलाथ"/Appellant ""यथ" /Respondent

Section 142(1)Section 143(2)Section 143(3)Section 254(1)Section 263

TDS or that such issues were not verified. The Ld. PCIT gave his observation / findings without giving any opportunity of such additional issue. The Ld. AR for the assessee submits that without giving any opportunity on the issue which was not subject-matter of show cause, the order passed by Ld.PCIT under section 263 to that extent is absolutely illegal

SHANKAR ZETHABHAI PATEL,SURAT vs. PR. COMMISSIONER OF INCOME TAX CENTRAL, SURAT

In the result, appeal of the assessee is allowed

ITA 124/SRT/2022[2018-19]Status: DisposedITAT Surat28 Aug 2023AY 2018-19

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.124/Srt/2022 "नधा"रण वष"/Assessment Year: (2018-19) (Physical Hearing) Shankar Zethabhai Patel, Vs. The Pcit(Central), 505, Sraynik Park Appartment, Rander Surat. Road, Surat – 395009. (Appellant) (Respondent) "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Cfepp7235M Appellant By Shri Rasesh Shah, Ca Respondent By Shri Ashok B. Koli, Cit(Dr) 15/06/2023 Date Of Hearing Date Of Pronouncement 28/08/2023

Section 132Section 143(3)Section 263

TDS out of Rs. 70 lacs. The amount actually paid is evident from the bank statement as explained herein above. 3. Your honour has raised another issue that assessee has shown the turnover of Rs.31,35,000/- for the purpose of section 44AD whereas the credit entries appearing in bank accounts is Rs.1,20,44,870/- including cash deposit

ITO, WARD 2(3)(8), SURAT vs. MUKESH MAHAVIRPRASAD SEN, SURAT

In the result the ground No

ITA 15/SRT/2020[2008-09]Status: DisposedITAT Surat13 Jan 2023AY 2008-09

Bench: Shri Pawan Singh, Hon'Ble & Dr. A. L. Saini, Hon'Ble Accountnat Member (Physical Court Hearing) Sl.

For Appellant: Shri Rohit Vijayvargiya, CAFor Respondent: Shri Ashok B. Koli, CIT(DR) with Shri Vinod Kumar
Section 132(4)Section 144

Section 142(3). This requirement is emphasized by the various decisions quoted by AR in this submission (supra). 7.1.3 Requirement of giving materials proposed to be relied by the ld. AO t0 the appellant is a statutory requirement , failure to do it is fatal to the assessment as held in many judicial pronouncements such as; (Gangaram

ITO, WARD-2(3)(7), SURAT vs. ANSHUMAN RAMDAYALJI KUMAWAT, SURAT

In the result the ground No

ITA 22/SRT/2020[2009-10]Status: DisposedITAT Surat13 Jan 2023AY 2009-10

Bench: Shri Pawan Singh, Hon'Ble & Dr. A. L. Saini, Hon'Ble Accountnat Member (Physical Court Hearing) Sl.

For Appellant: Shri Rohit Vijayvargiya, CAFor Respondent: Shri Ashok B. Koli, CIT(DR) with Shri Vinod Kumar
Section 132(4)Section 144

Section 142(3). This requirement is emphasized by the various decisions quoted by AR in this submission (supra). 7.1.3 Requirement of giving materials proposed to be relied by the ld. AO t0 the appellant is a statutory requirement , failure to do it is fatal to the assessment as held in many judicial pronouncements such as; (Gangaram

ITO, WARD-2(3)(7), SURAT vs. ANSHUMAN RAMDAYALJI KUMAWAT, SURAT

In the result the ground No

ITA 21/SRT/2020[2008-09]Status: DisposedITAT Surat13 Jan 2023AY 2008-09

Bench: Shri Pawan Singh, Hon'Ble & Dr. A. L. Saini, Hon'Ble Accountnat Member (Physical Court Hearing) Sl.

For Appellant: Shri Rohit Vijayvargiya, CAFor Respondent: Shri Ashok B. Koli, CIT(DR) with Shri Vinod Kumar
Section 132(4)Section 144

Section 142(3). This requirement is emphasized by the various decisions quoted by AR in this submission (supra). 7.1.3 Requirement of giving materials proposed to be relied by the ld. AO t0 the appellant is a statutory requirement , failure to do it is fatal to the assessment as held in many judicial pronouncements such as; (Gangaram

ITO, WARD 2(3)(8), SURAT vs. MUKESH MAHAVIRPRASAD SEN, SURAT

In the result the ground No

ITA 16/SRT/2020[2009-10]Status: DisposedITAT Surat13 Jan 2023AY 2009-10

Bench: Shri Pawan Singh, Hon'Ble & Dr. A. L. Saini, Hon'Ble Accountnat Member (Physical Court Hearing) Sl.

For Appellant: Shri Rohit Vijayvargiya, CAFor Respondent: Shri Ashok B. Koli, CIT(DR) with Shri Vinod Kumar
Section 132(4)Section 144

Section 142(3). This requirement is emphasized by the various decisions quoted by AR in this submission (supra). 7.1.3 Requirement of giving materials proposed to be relied by the ld. AO t0 the appellant is a statutory requirement , failure to do it is fatal to the assessment as held in many judicial pronouncements such as; (Gangaram

INCOME TAX OFFICER, WARD 2(3)(8), SURAT vs. SHRI RAJESH KUMAR PAMECHA, AJMER

In the result the ground No

ITA 87/SRT/2017[2007-08]Status: DisposedITAT Surat13 Jan 2023AY 2007-08

Bench: Shri Pawan Singh, Hon'Ble & Dr. A. L. Saini, Hon'Ble Accountnat Member (Physical Court Hearing) Sl.

For Appellant: Shri Rohit Vijayvargiya, CAFor Respondent: Shri Ashok B. Koli, CIT(DR) with Shri Vinod Kumar
Section 132(4)Section 144

Section 142(3). This requirement is emphasized by the various decisions quoted by AR in this submission (supra). 7.1.3 Requirement of giving materials proposed to be relied by the ld. AO t0 the appellant is a statutory requirement , failure to do it is fatal to the assessment as held in many judicial pronouncements such as; (Gangaram

N R CORPORATION,SURAT vs. PCIT-1, SURAT

In the result, the appeal of the assessee is allowed

ITA 526/SRT/2024[2018-19]Status: DisposedITAT Surat28 May 2025AY 2018-19

Bench: Shri Pawan Singh & Shri Bijayananda Prusethआयकर अपील सं./Ita No.526/Srt/2024 Assessment Year: 2018-19 (Physical Hearing) N. R. Corporation, Vs. The Pcit - 1, B-202, Capital Status, Opp – Hariom Surat Nagar, Near Atman Park, L. P. Savani Road, Adajan, Surat - 395009 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aamfn9368A (Appellant) (Respondent) Appellant By Shri Suresh K. Kabra, Ca Respondent By Shri Ritesh Mishra, Cit-Dr Date Of Hearing 13/03/2025 Date Of Pronouncement 28/05/2025

Section 143Section 143(2)Section 143(3)Section 194CSection 263Section 40

142(1) of the Act. After receiving the reply through e-filing portal, the AO passed the assessment order u/s 143(3) of the Act accepting the returned income. Subsequently, the ld. PCIT called for the records and noted that the case was selected for complete scrutiny on the issue of income from real estate. On verification of the return

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIR.-3, SURAT vs. SH. HARESHBHAI MOHANBHAI SAKARIYA, SURAT

In the result, Revenue’s appeal is dismissed

ITA 48/SRT/2021[2017-18]Status: DisposedITAT Surat25 May 2022AY 2017-18

Bench: Shri Pawan Singh & Dr. Arjun Lal Sainiit(Ss)A No.01/Srt/2021 (Ay 2010-11) It(Ss)A No.09/Srt/2020 (Ay 2014-15) (Hearing In Physical Court) Deputy Commissioner Of Shri Dineshchandra D Income-Tax, Central Circle- Koradia, 3Room No.507, 5Th Floor, 9/10, Dayanand Society, Aayakar Bhawan, Majura B/H.Navyug College, Gate, Surat-395001 Rander Road, Surat Pan No: Acupk 3696 A Assistant Commissioner Of Vs Income-Tax, Central Circle-3, Room No.507, 5Th Floor, Aayakar Bhawan, Majura Gate, Surat-395001 Appellant / Revenue Respondent /Assessee

Section 132Section 132(1)Section 143(3)Section 14ASection 153ASection 153CSection 158BSection 254(1)

142(1) of the Act proceeded for assessment. The Assessing Officer during the assessment recorded that on verification of return of income, it is seen that the assessee has received unsecured loan from various parties who have poor credentials. The assessee availed loan from AYs 10-11, 14-15, 15-16 & 17-18 Dineshchandra D Koradia, Nagjibhai M Sakariya

SHRI GIRISHBHAI R PATEL,MUMBAI vs. ITO, INTERNATIONAL TAXATION, SURAT, SURAT

In the result, appeal of the assessee is allowed for statistical purpose

ITA 758/SRT/2018[2010-11]Status: DisposedITAT Surat03 Sept 2021AY 2010-11

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini(Hearing In Virtual Court) Shri Girishbhai R Patel, The Income Tax Officer, A-93, Pl-A, Pranek Garden, International Taxation, Vs. Panchasheel Encl. Anavil Business Centre, Dahanukarwadi Off. M.G. Road, Adajan, Surat. Mumbai Pan : Axnpp 4064 B Applicant Respondent

Section 142(1)Section 144Section 147Section 148Section 254(1)Section 69

TDS amounting to Rs.41,121/- from total tax demand. 6) It is therefore prayed that above addition made by assessing officer and confirmed by Commissioner of Income-tax (Appeals) may please be deleted” 2. Brief facts of the case are that assessee is non-resident Indian. The case of the assessee was reopened under section 147. The case was reopened

D V PROPERTIES PVT. LTD.,SURAT vs. PR. COMMISSIONER OF INCOME TAX - 1, SURAT

In the result, appeal filed by the assessee is partly allowed to the extent indicated above

ITA 121/SRT/2023[2018-19]Status: DisposedITAT Surat29 Aug 2023AY 2018-19

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.121/Srt/2023 Assessment Year: (2018-19) (Physical Hearing) D. V. Properties Pvt. Ltd., Vs. The Pcit - 1, 748-749, Golden Plaza Market, Surat. Ring Road, Surat – 395002. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaacd8392B (Appellant) (Respondent) Ms Chaitali Shah, Ca Appellant By Shri Ashok B. Koli, Cit(Dr) Respondent By Date Of Hearing 19/07/2023 Date Of Pronouncement 29/08/2023

Section 143(3)Section 263Section 37(1)Section 43B

section 37(1) of the Act, only such expenditure which are incurred in connection with business and offence for an illegal act or breach of law or prohibition of law are alone not allowable and in other cases and more particularly in this case, the interest in respect of TDS was only in the nature of compensation of revenue

ENGINEERING PROFESSIONAL CO. PVT LTD,SURAT vs. PCIT-1, SURAT

In the result, appeal of the assessee is partly allowed

ITA 541/SRT/2024[2018-19]Status: DisposedITAT Surat19 Feb 2025AY 2018-19

Bench: Shri Pawan Singh & Shri Bijayananda Prusethआयकर अपील सं./Ita No.541/Srt/2024 Assessment Year: (2018-19) (Physical Hearing) Engineering Professional Co. Pvt. Ltd., Vs. The Pcit -1, 444, Royal Arcade, Opp. Sarthana Zoo, Surat Varachha Road, Near Sarthana Jakatnaka, Surat – 395006, Gujarat "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aabce0313Q (Appellant) (Respondent) Appellant By Shri P. M. Jagasheth, Ca Respondent By Shri Ravi Kant Gupta, Cit(Dr) Date Of Hearing 13/02/2025 Date Of Pronouncement 19/02/2025

Section 142(1)Section 143(2)Section 143(3)Section 194CSection 263

section 263 of the Income-tax Act, 1961 (in short, ‘the Act’) dated 13.03.2024 by the Principal Commissioner of Income Tax (Central), Surat [in short, ‘PCIT’] for the assessment year (AY) 2020-21. 2. The grounds of appeal raised by the assessee are as under: “1. On the facts and in the circumstances of the case as well

CHIRAGBHAI S. GADHIYA,SURAT vs. I.T.O., WARD-3(2)(6),, SURAT

In the result, this appeal of assessee is allowed

ITA 240/SRT/2021[2016-17]Status: DisposedITAT Surat28 Jul 2023AY 2016-17

Bench: Shri Pawan Singh(Physical Hearing) Chiragbhai S. Gadhiya, I.T.O., 79, Mani Nagar Society, Nana Ward-3(2)(6), Vs. Varachha, Nr. Sarthana Jakat Naka, Surat. Surat-395006. Pan No. Ajypg 7927 K Appellant/ Assessee Respondent/ Revenue

Section 133(6)Section 143(3)Section 254(1)Section 68

142(1) was issued for seeking various information. The assessee furnished reply by way of e-reply alongwith covering letter and by furnishing evidence of bank book and statement of all banks, Income tax return, computation of income, trading account, Profit & Loss Account, balance sheet and audit report for A.Y. 2015-16 and 2016-17 with cash book. The Assessing

VITRAG PRINTS,SURAT vs. NFAC, DELHI

In the result, appeal filed by the assessee is allowed for statistical purposes in above terms

ITA 338/SRT/2023[2015-16]Status: DisposedITAT Surat14 Dec 2023AY 2015-16

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.338/Srt/2023 Assessment Year: (2015-16) (Physical Hearing) Vitrag Prints, Vs. The Acit (Osd), K-2619 To 2622, Millenium Ward -1(2)(5), Textile Market Ring Road, Surat. Surat - 395002 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aalfv5612L (Appellant) (Respondent) Appellant By Shri Jaykishan Goel, Ca Shri Vinod Kumar, Sr. Dr Respondent By 22/09/2023 Date Of Hearing Date Of Pronouncement 14/12/2023

Section 133(6)Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 145(3)Section 40A(2)(b)

142(1) calling for details and information. The AO rejected the books of accounts and resorted to disallow a portion of expenses. The AO observed in the assessment order that: “In response to the above notice, the assessee vide its letter dated 19/12/2017 his reply stating that assessee has submitted all bills for which expenses were debited in its books

ASSISTANT COMMISSIONER OF INCOME TAX, CIR - 1(3), SURAT vs. RAJGREEN INFRALINK LLP, SURAT

In the result, the ground No

ITA 375/SRT/2023[2018-19]Status: DisposedITAT Surat26 Oct 2023AY 2018-19

Bench: Shri Pawan Singh & Dr Arjun Lal Sainiआ.अ.सं./Ita No.257 & 375/Srt/2023 (Ay 2018-19) (Hearing In Physical Court) Rajgreen Infralink Llp Deputy Commissioner Of 29-30, Sai Baba Shraddha Nagar, Income Tax, Circle-1(3) Nr. Choksi Wadi, New Rander Road, Surat, Aaykar Bhavan, Adajan, Surat-395009 Majura Gate, Surat-395001 Pan No. Aavfr 8064 N Assistant Commissioner Of Income- Rajgreen Infralink Llp Vs Tax, Circle-1(3), Surat, Room No. 29-30, Sai Baba Shraddha 301, 3Rd Floor, Anavil Business Nagar, Nr. Choksi Wadi, Centre, Hazira Road, Adajan, New Rander Road, Adajan, Surat-395009 Surat-395009 Pan No. Aavfr 8064 N अपीलाथ"/Appellant ""थ" /Respondent

Section 143(3)Section 254(1)Section 68

section 142(1) vide notice dated 16.02.2020, 04.01.2021 and 31.03.2021 were issued to the assessee. The assessee failed to submit proper reply with respect to issue raised by assessing officer. The assessee in its reply submitted that due to second wave of Covid-19 pandemic, the assessee could not collect the requisite contra- confirmation and sought short adjournment upto

RAJGREEN INFRALINK LLP,SURAT vs. DY. COMMISSIONER OF INCOME TAX, CIRCLE - 1(3), SURAT

In the result, the ground No

ITA 257/SRT/2023[2018-19]Status: DisposedITAT Surat26 Oct 2023AY 2018-19

Bench: Shri Pawan Singh & Dr Arjun Lal Sainiआ.अ.सं./Ita No.257 & 375/Srt/2023 (Ay 2018-19) (Hearing In Physical Court) Rajgreen Infralink Llp Deputy Commissioner Of 29-30, Sai Baba Shraddha Nagar, Income Tax, Circle-1(3) Nr. Choksi Wadi, New Rander Road, Surat, Aaykar Bhavan, Adajan, Surat-395009 Majura Gate, Surat-395001 Pan No. Aavfr 8064 N Assistant Commissioner Of Income- Rajgreen Infralink Llp Vs Tax, Circle-1(3), Surat, Room No. 29-30, Sai Baba Shraddha 301, 3Rd Floor, Anavil Business Nagar, Nr. Choksi Wadi, Centre, Hazira Road, Adajan, New Rander Road, Adajan, Surat-395009 Surat-395009 Pan No. Aavfr 8064 N अपीलाथ"/Appellant ""थ" /Respondent

Section 143(3)Section 254(1)Section 68

section 142(1) vide notice dated 16.02.2020, 04.01.2021 and 31.03.2021 were issued to the assessee. The assessee failed to submit proper reply with respect to issue raised by assessing officer. The assessee in its reply submitted that due to second wave of Covid-19 pandemic, the assessee could not collect the requisite contra- confirmation and sought short adjournment upto