2026 (4) TMI 913

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.... SUCHITRA KAMBLE - JUDICIAL MEMBER: The appeal filed by the Revenue is against the order passed by the Ld. Commissioner of Income Tax (Appeals)-4, (in short "Ld. CIT(A)"), Surat on 12.127.2024 for A.Y. 2018-19. 2. The Revenue has raised the following grounds of appeal: "a) On the facts and in the circumstances of the case and in law the Ld. CIT(A) erred in deleting the addition of d....

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....on of the Assessee and holding that the bid not successful is itself a business activity thereby totally ignoring that the Assessee has not shown any income from business or profession m any of the assessment years after the A.Y. 2015-16. d) On the facts and in the circumstances of the case and in law the Ld. CIT(A) erred in being ignorant about the investment of the Assessee for which th....

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....the assessee. 5. The Ld. DR relied upon the assessment order and submitted that the Kolkata Port Trust is an artificial Juridical body as per the PAN data base and not a Government entity as claimed by the assessee and hence the provision of Section 43B of the Act shall not apply in assessee's case. 6. The Ld. AR relied upon the order of the CIT(A). 7. We have heard both the parties and p....