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2020 (12) TMI 333 - AT - Income TaxRectification u/s 254 - only contention raised by learned AR of the assessee that the Tribunal is not correct in saying that no argument was advanced regarding ground No.4 of the original grounds of appeal - HELD THAT:- No evidence could be brought on record by learned AR of the assessee in this regard to establish that arguments were in fact advanced by learned AR of the assessee in respect of ground No.4 of the original grounds of appeal filed by the assessee. CIT (A) has decided the issue about R & D Segment as per para 7 to 7.9.7.1 of his order running from pages 9 to 25 of the order of CIT (A) and as per our log Book, no reference was made by the learned AR of the assessee to para 7 to 7.9.7.1 of the order of CIT (A) where he decided the issue about R & D Segment by way of detailed discussion in 16 – 17 pages hence, the order about this issue is not cryptic and in ground No. 4 of the Original grounds raised before the tribunal, the issue raised is about R & D segment and hence, we find no apparent mistake in this finding of the tribunal that no argument was made by the learned AR of the assessee about R & D Segment and hence, there is no apparent mistake in the tribunal order regarding the inference that Ground No. 4 is also not pressed. Hence, we hold that there is no merit in the MP filed by the assessee.
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