2023 (11) TMI 1238

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....enior Standing Counsel with Mr. Rishabh Nigam, Ms. Anuja Pethia and Ms. Dacchita Shahi, Advocates. For the Respondent : Mr. Weeraj Jain and Mr. Aditya Vohra, Advocates. ORDER [Physical Hearing/Hybrid Hearing (as per request)] 1. This appeal concerns Assessment Year (AY) 2008-09. 2. Via the instant appeal, the appellant/revenue seeks to assail the order dated 25.06.2020 passed by the....

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....it of Rs. 2,20,61,0271- by admitting the additional ground without giving any opportunity to the department? D. Whether on facts and circumstances of the case and also on prevailing law, the Hon'ble ITAT was justified in not appreciating that the claim was not made in the ITR and never raised before the AO and CIT(A)? E. Whether on facts and circumstances of the case and also....

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.... proposed questions, i.e., "C", "D", and "E", it is evident that "D" and "E" are linked to the proposed question "C". According to the learned counsel for the respondent/assessee, the proposed questions "C," "D", and "E" are covered by the following judgments of the Karnataka High Court: (i) Wipro Ltd vs DCIT: (2015) SCC OnLine Kar 9196. (ii) PCIT vs Infosys Ltd: (2023) 147 taxma....