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TMI Blog2022 (2) TMI 1027X X X X Extracts X X X X X X X X Extracts X X X X ..... mmon order [ 2021 (11) TMI 1024 - ITAT MUMBAI] . Therefore, we are of the view that it would be in the interest of justice that the issue before us pertaining to the utilization of accumulated also remanded to the file of AO who would be at liberty to examine the same in terms of Section 11(3)(c) of the Act and the grant relief to the Assessee, if any, as per the applicable law. Accordingly, the i ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ment year 2011-12, whereby the Ld. CIT(A) had partly allowed the appeal filed by the Assessee against the rectification order, dated 29.03.2018, passed under section 154 of the Act. 2. Brief facts of the case relevant to the issue before us are that the Appellant is a company stated to have been formed, inter alia, for the purpose of promoting and protecting the trade commerce and manufacturers ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nt order, dated 13.01.2014, was dismissed vide order, dated 19.12.2014. The Appellant, therefore, took the matter in appeal before the Tribunal. 4. Meanwhile, vide order, dated 29.03.2018, passed Section 154 of the Act, the assessment order, dated 13.01.2014, was rectified by the Assessing Officer and an addition of INR 1,36,26,000/- was made by invoking the provisions of section 11(3)(c) of th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... be required to grant benefit of exemption under Section 11 of the Act to the Appellant and quantify the same, the Ld. Counsel for the Assessee submitted that the issue in the present appeal pertaining to unutilized accumulated amount of INR.1,36,26,000/- may also sent back to the AO. While the Ld. Departmental Representative confirms that the Tribunal has granted the aforesaid relief to the Appell ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... on order, dated 10.11.2021. Therefore, we are of the view that it would be in the interest of justice that the issue before us pertaining to the utilization of accumulated amount of INR 1,36,26,000/- is also remanded to the file of Assessing Officer who would be at liberty to examine the same in terms of Section 11(3)(c) of the Act and the grant relief to the Assessee, if any, as per the applicabl ..... X X X X Extracts X X X X X X X X Extracts X X X X
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