2019 (12) TMI 41

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....ndent P.C. :- These two Petitions under Article 226 of the Constitution of India challenge a common order dated 29 March 2019 passed by the Income Tax Appellate Tribunal (Tribunal) under Section 254(2) of the Income Tax Act, 1961 (Act). The common impugned order dated 29 March 2019 rejected the Petitioner's application for rectification of an order dated 9 July 2018 passed under Section 254(....

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....18 urging that the Tribunal failed to note that Assessing Officer had recorded his dissatisfaction while rejecting the suo motu disallowance under Section 14A of the Act r/w. 8D of the Rules. 4. The Tribunal by the impugned order dated 29 March 2019 dismissed the Revenue's rectification application by pointing out that in its order dated 9 July 2018 it had come to the conclusion on perusal of t....

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....9 July 2018 had dealt with the Petitioner's contentions extensively while upholding the order of the Commissioner of Income Tax(Appeals). The view taken by the Tribunal in its order dated 9 July 2018 in both the Assessment Years was on the basis of the record available before it and its understanding/appreciation of the evidence on record for the two Assessment Years. This is not a case of an erro....