2023 (11) TMI 1445

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....see : Ms. Swati Talwar, Advocate. For the Department : Sh. S.L. Anuragi, Sr. DR. ORDER PER SAKTIJIT DEY, V.P. Captioned appeals by the assessee arise out of three separate orders dated 31.10.2022 passed by National Faceless Appeals Centre (NFAC), pertaining to assessment years 2018-19, 2019-20 and 2020-21. 2. The only common issue arising in all these appeals relates to disallowance....

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....4)(x) of the Act. 4. Though, the assessee contested the aforesaid disallowances by filing appeals before the first appellate authority, however, it failed in its attempt, as, the first appellate authority relying upon a decision of the Hon'ble Supreme Court in case of Checkmate Services P. Ltd. Vs. CIT in Civil Appeal No. 2833 of 2016 [TS-791- SC-2022] upheld the disallowance. 5. Before....

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....as provided under section 36(1)(va) of the Act should be construed from the date on which salary was actually disbursed to the employees and not the date on which salary was due. In our view, the aforesaid contention of the assessee merits consideration. 7. We have further observed, while considering similar pleadings made by the assessee, the Coordinate Benches have restored the issue to the A....