2023 (12) TMI 652

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....itioner Through: Mr Kamal Sawheny with Mr Nikhil Agarwal, Mr Nishank and Ms Harshita Agrawal, Advs. For the Respondent Through: Mr Zoheb Hossain, Sr Standing Counsel with Mr Sanjeev Menon, Standing Counsel. RAJIV SHAKDHER, J.: (ORAL) 1. The substantive relief sought by the petitioner in the writ petition reads as follows: "(a) Issue a writ of CERTIORARIFIED MANDAMUS or any other ....

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....ng to Rs. 2,06,29,647/-. 3. The disallowance was ordered by the Assessing Officer (AO) under Section 40(a)(i) of the Income-tax Act, 1961 [in short, "Act"], while framing the assessment order, under Section 143(3) of the Act, on 27.12.2016. 4. The record shows [and something which is not disputed by the respondent/revenue] that the aforementioned addition, amounting to Rs. 2,06,29,647/-, had....

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....emonstrates that expertise available with the AEs was 'made available' to the petitioner/assessee. Finally, it was also observed that this issue had been decided by the CIT(A) in favour of the petitioner/assessee in matters concerning AYs 2010-11 and 2014-15, decisions that were not challenged before the Tribunal. 6. Mr Zoheb Hossain, learned senior standing counsel, who appears on behalf of th....