2025 (11) TMI 1172

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....r the Respondent: Mr. Madhur Agarwal, a/w Mr. Punit Shah, Sameer G. Dalal,. P.C.:- 1. Heard Ms. Gokhale, learned counsel for the appellant and Mr. Madhur Agarwal, learned counsel for the respondent. 2. The tax effect in this case is only Rs. 10 Lakhs. However, Ms. Gokhale submits that this case falls within the exceptions carved out by the CBDT Circular No. 3 of 2018 dated 11 July 2018. ....

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....urn filed under Section 153A as well. Even the books of account clearly reflected the acquisition of these assets. 6. Mr. Agarwal submitted that the return under Section 153 A disclosing the acquisition of these assets was filed even before any notice for penalty could be issued. He therefore submitted that the assessee's case was covered by the decision of this Court in the case of Principal C....

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....unt produced from time to time clearly reflected the acquisition of this asset. 10. In the case of JSW Steel Limited (supra), a coordinate Bench of this Court has taken the view that the return filed under Section 153A is also a return for the purposes of Section 139(1) of the Income Tax Act. The Commissioner (Appeals)-I and Income Tax Appellate Tribunal have relied upon this decision to hold t....