2025 (9) TMI 1666

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.... Sh. Dhiraj Kumar Jain, Sr. DR ORDER PER SATBEER SINGH GODARA, JUDICIAL MEMBER: This assessee's appeal for Assessment Year 2009-10, arises against the CIT(A)-IX, New Delhi's case No. 100/11-12 dated 07.06.2013, in proceedings u/s 143(3) of the Income Tax Act, 1961 (in short "the Act"). 2. Heard both the parties at length. Case file perused. 3. It emerges during the course of hearing....

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....s well as payable expenditure items during the relevant previous year. We thus reject the assessee's instant first and foremost substantive ground in very terms. 4. Our attention is next invited to the assessee's revised/additional ground(s) wherein it pleads that an expenditure of Rs. 4,06,950/- never required to be subjected to any TDS deduction. Both the parties vehemently reiterate their re....

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.... to this effect is restored back to the learned assessing authority subject to a rider that the taxpayer shall plead and prove all the relevant facts, in consequential proceedings, within three effective opportunities at it's own risk and responsibility. This third/additional revised ground is accordingly accepted for statistical purposes. 6. Learned counsel's last argument during the course of....