2026 (9) TMI 27

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....iv Sapra, FCA For the Department : Ms. Beenu, Sr. DR ORDER PER MANISH AGARWAL, AM: This appeal is filed by the Revenue against the order of the Ld. Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi ['Ld. CIT(A)' in short], in Appeal No. CIT(A), Delhi-2/10297/2019-20 dated 07.01.2026 passed u/s 250 of the Income Tax Act, 1961 ('the Act' in short) for As....

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....ng the addition made w/s 68 ignoring the facts discussed by AO in para 2.3 of this assessment order and law position as discussed in para 2.4 of the assessment order passed u/s 143(3) dated 27/11/2019. 4. Whether Ld. CIT(A) has erred in law and facts in admitting additional evidence violation of Rule 46A of Income Tax Rules, 1962. 5. The appellant craves leave to add, alter or am....

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..... AO has computed the same at Rs. 1,39,80,640/- by applying tax rate of 60%, surcharges @ 25% and Cess @3% as provided u/s 115BBE of the Act. However, we find no merit in the above computation, once Hon'ble Madras High Court in the case of SMILE Microfinance Ltd. v. ACIT in WP(MD) No. 2078 of 2020 & 1742 of 2020 dated 19.11.2024 (Mad.) has already settled the issue that Section 115BBE applies on t....