2021 (2) TMI 1205

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....h. Atique Ahmed, Sr. DR. For the Assessee : Sh. K.V.S. R. Krishna, Adv. (Through Video Conferencing) PER ANADEE NATH MISSHRA, A.M. : (A) This appeal by the revenue is filed against the order of Learned Commissioner of Income Tax (Appeals)-40, New Delhi, [Ld. CIT(A)", for short], dated 22/06/2017 for Assessment Year 2013-14. Grounds taken in this appeal of Revenue are as under: 1. "O....

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....e Act. 4. On the basis of facts and circumstances of the case and in law, the Ld. CIT(A) has erred in treating the assessee not involved in any trade, commerce or business and mischief of proviso of section 2(15) of the Act is not applicable to the assessee. 5. The appellant craves leave to add, to alter or amend any ground of appeal raised above at the time of hearing." (B) The only issu....

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....ng Officer ("AO", for short). Neither side has brought any material to distinguish the facts and circumstances of the case for AY 2013-14 (to which this appeal pertains) from facts and circumstances of A.Y. 2011-12 and A.Y. 2012-13 to which respectively the aforesaid orders dated 03.09.2019 and 08.12.2020 pertain. Neither side has brought any material for our consideration to persuade us to take a....