9911796707
TMI Blog2023 (5) TMI 549X X X X Extracts X X X X X X X X Extracts X X X X ..... al, Advocate. RAJIV SHAKDHER, J.: (ORAL) CM APPL. 17995/2023 1. Allowed, subject to just exceptions. CM APPL.17996/2023[Application filed on behalf of the appellant/revenue for condonation of delay of 240 days in filing the appeal] 2. This is an application filed on behalf of the appellant/revenue seeking condonation of delay in filing the appeal. 2.1 According to the appellant/revenue, ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... confirmed the findings of fact returned by the Commissioner of Income Tax (Appeals) [in short, "CIT(A)"]. 9. The relevant paragraphs of the impugned order dated 14.10.2021, for the sake of convenience, are extracted hereafter: "10. We have heard the rival submissions and perused the materials available on record. The issue in the present ground is with respect to the deleting the addition of R ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... (A) for the reasons stated in the order has deleted the addition. Before us, Revenue has not pointed any fallacy in the findings of CIT(A). In such a situation, we find no reason to interfere with the order of CIT(A) and thus the ground of Revenue is dismissed. xxx xxx xxx 12. As far as ITA No. 2988/Del/2018 for A.Y. 2014-15 is concerned, before us, both the parties have submitted that the is ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he goose is sauce for the gander. The approach of the AO bordered on whimsicality. 10.2 Furthermore, while we are conscious that the principle of res judicata has no place in the Income Tax regime, the principle of consistency, which is equally weighty, has been applied by the court where circumstances are pari materia with the facts obtaining in the period in issue. 11. Accordingly, we find no ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
