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2019 (8) TMI 110

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.... JUDGMENT (PER : HONOURABLE MR.JUSTICE J.B.PARDIWALA) This Tax Appeal under Section 260A of the Income Tax Act, 1961, is at the instance of the Revenue and is directed against the order passed by the Income Tax Appellate Tribunal, Ahmedabad dated 25/09/2018 in the ITA No.3446/Ahd/2014/SRT for the A.Y.2007-08 . 2. The Revenue has proposed the following two substantial questions of law for ....

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....000/- under section 40(a) (ia) of the Act to the returned income. From the copy of the reasons recorded available at page 52 of the assessee's paper book, it is vivid that the reasons were recorded on 19.8.2011, wherein first two paras the AO recorded the history of earlier ass proceedings and in subsequent para 3 noted the essence of the provisions of section 40A(3) of the Act and thereafter ....