2021 (6) TMI 1142

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....S.S. GODARA, J.M. This assessee's appeal for A.Y. 2018-19 arises against the Commissioner of Income Tax (Appeals) "[CIT(A)]"-3, Hyderabad's order dated 26.02.2020 passed in case no. 19799/2019-20 in proceedings u/s 143(1) of the Income Tax Act, 1961 [in short 'the Act']. Heard both the parties. Case file perused. Assessee has raised the following substantive grounds in its appeal. "The order ....

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....33,033/-] 4. The Ld. CIT (A) ought to have appreciated the fact that the provisions of section 43B permits allowance of payments made up to the due date of filing the return of income and the section 36(1)(va) of the 1.T act should be read along with section 43B of the 1. T act. [tax effect: Rs. 13,33,033/-] 5. The Ld. CIT (A) ought to have fairly appreciated the fact that the appellant compan....

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....nd ESI before the due date of filing of return f income, as held by the hon'ble ITAT Hyderabad and other Courts of law I number of cases 8. The assessee may add alter, or modify or substitute any other points to the grounds of appeal at any time before and or at the time of hearing of the appeal." 2. Coming to the sole substantive issue of ESI/PF disallowance of Rs. 13,33,033/-, the assessee's ....