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TMI Blog2025 (4) TMI 1478X X X X Extracts X X X X X X X X Extracts X X X X ..... ORDER PER RAKESH MISHRA, ACCOUNTANT MEMBER: Both these appeals filed by the assessee are against separate orders of the Addl/JCIT(A)-Prayagraj [hereinafter referred to as Ld. 'CIT(A)'] passed u/s 250 of the Income Tax Act, 1961 (hereinafter referred to as 'the Act') for AY 2022-23 & AY 2023-24 dated 23.10.2024 & 14.11.2024, which have been passed against the intimation orders u/s 143(1) ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... t. 5. That the appellate craves leave to add, modify or amend the ground of appeal and to adduce additional evidence in support of ground of appeal at the time of hearing of the case." AY 2023-24 "1. The Id. CIT(A), NFAC erred in law and on facts to affirm the order of the Assessing Officer, NFAC. 2. The Ld. CIT(A), NFAC erred in law to affirm the order of the Assessing Officer, NFAC in wh ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... m amount which was not chargeable to tax and the tax rate for the assessee was 30%. The assessee had total income of Rs. 24,78,407/- including dividend income, interest income from the bank and interest income from fixed deposit. The CPC calculated the surcharge at Rs. 2,75,102/- instead of 'NIL' in computing the tax liability. The CPC also charged consequential cess in excess by Rs. 11,004/- and ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... f the assessee has capital gains, therefore, even otherwise the surcharge was to be limited to 15%. Since the beneficiaries are known and the shares are mentioned in the trust deed, therefore, the provisions of section 167B or section 164(1) of the Act are not applicable. The Ld. DR relies upon the order of the Ld. CIT(A). 5. We have considered the submissions made and find that the surcharge @ 1 ..... X X X X Extracts X X X X X X X X Extracts X X X X
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