2022 (7) TMI 531

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.... pressed. Accordingly, ground No. 2 is dismissed as not pressed. 3. Ground Nos. 1 and 3 are interlinked which can be discussed collectively. In ground No. 1, the assessee challenged the action of CIT(A) in confirming the addition made by invoking the provisions u/s. 40(a)(ia) of the Act. In ground No. 3, the assessee challenged the action of CIT(A) for not considering the second proviso to section 40(a)(ia) of the Act, which in our opinion is a legal ground concerning invocation of provisions u/s. 40(a)(ia) of the Act. In view of the same, we shall discuss the facts of the case concerning the invocation of section 40(a)(ia) of the Act. 4. Heard both the parties and perused the material available on record. We note that the assessee is....

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....er : Assessed Income as per Order dtd. 01.12.2011   5,09,44,738/- Less : Relief Granted by CIT(A) vide order dated 10.01.2013   2,43,02,993/- Income as per order giving effect to the CIT(A)'s order dtd. 10.01.2013   2,66,41,745/- Less : Relief Granted by ITAT by restoring the issue of adjudicating afresh the addition of Rs.4,01,08,595/- instead of amount of Rs.2,22,62,872/- that was confirmed by the CIT(A) Net Relief out of addn. of Rs.4,01,08,595/- 2,22,62,872/- Add : Addition confirmed by ITAT 63,43,270/-   Assessed Income   1,07,22,143/- Rounded off to   1,07,22,100/- Agricultural Income   78,620/- 8. On perusal of the above, we ....