2024 (4) TMI 1299

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....R PC:- 1. The following four substantial questions of law are proposed : "1. Whether on the facts and circumstances of the case and in law the Hon'ble ITAT erred in accepting and allowing new grounds of appeal without appreciating the facts that in the same order, ITAT has upheld the order of Ld. CIT (A) ? 2. Whether on the facts and circumstances of the case and in law the Hon'ble ITAT e....

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.... Income Tax, Central-1, Mumbai v/s. Pruthvi Brokers and Shareholders [(2012) 349 ITR 336], this Court has held that "an Assessee is entitled to raise before the Appellate Authorities additional grounds in terms of additional claims not made in return filed by it". Therefore, it will not be a substantial question of law. 3. As regards the second substantial question of law proposed, the Income Tax....

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....stion of law proposed, this Court has in Assessee's own case being Income Tax Appeal No. 1126 of 2018, on 6th December 2023 admitted the appeal and framed the following substantial question of law : "Whether on the facts and circumstances of the case and in law the Hon'ble ITAT erred in holding that strategic investments should not be considered for making disallowance under Section 14 read....