9911796707
TMI Blog2022 (9) TMI 1370X X X X Extracts X X X X X X X X Extracts X X X X ..... his appeal of the assessee. - ITA No. 71/Ahd/2019 - - - Dated:- 28-9-2022 - Shri P.M. Jagtap, Vice-President And Shri T.R. Senthil Kumar, Judicial Member For the Assessee : Shri M.J. Shah, AR For the Revenue : Shri Shramdeep Sinha, Sr. DR ORDER PER P.M. JAGTAP, VICE-PRESIDENT : This appeal filed by the assessee is directed against the order of learned Commissioner of Income-tax (Appeals)-4, Ahmedabad [ CIT(A) in short] dated 03.01.2019 and the grounds raised by the assessee therein read as under:- 1. The learned C.I.T. (Appeals) is not justified in not allowing the full credit of TDS of Rs.32,28,248/- as claimed by the appellant in its return of income. 2. The learned C.I.T. (Appeals) while not granti ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the Assessing Officer (CPC) dated 17.03.2017 under Section 154 of the Act, an appeal was filed by the assessee before the learned CIT(A) and after considering the submissions made by the assessee as well as the material available on record, the learned CIT(A) decided the issue relating to assessee s claim for credit of TDS vide his impugned order dated 03.01.2019 as under:- The fact remains that the first appellate authority also doesn't have much of evidences and even if filed have limited mandate to which verification could be done as the preliminary examination of such evidences has not been done by the assessing officer having natural jurisdiction over the case. It is also noted that there is very limited sphere of power with t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... It is my conscious decision not to accede to the demand of appellant for allowing TDS credit pertaining to A.Y. 2010-11, A.Y. 2011-12, A.Y. 2012-13, AY. 2013-14, A.Y. 2014-15 A.Y. 2015-16. The ground No.1 is accordingly dispose off with the direction to AO to issue revised demand notice. 4. Aggrieved by the order of the learned CIT(A), the assessee has preferred this appeal before the Tribunal. 5. We have heard the arguments of both the sides and also perused the relevant material available on record. The learned Counsel for the assessee has submitted that another application for rectification under Section 154 was filed by the assessee before the Assessing Officer and while disposing of the same vide an order dated 28.06.2019 pas ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
