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2020 (8) TMI 662 - AT - Income TaxRectification u/s. 154 - disallowance u/s. 36(1)(viia) - AR submits that the disallowances u/s. 36(1)(viia) is a subject matter of litigation and the same cannot be matter of rectification u/s. 154 - debatable issue - HELD THAT:- We find that the contentions made before us by the ld. AR were not raised before the AO and fairly conceded that if this Tribunal remand the matter to the file of AO the assessee will take the same contentions before this Tribunal. Taking into consideration the facts and circumstances of the case and submissions of ld. AR and ld. DR, we deem it proper to remand the issue to the file of AO for its fresh consideration. The assessee is liberty to file evidences if any in support of its claim. Thus, only issue raised by the assessee is allowed for statistical purpose.
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