And that brand new Tribunal kept you to definitely Company had didn’t establish you to definitely the new Assessee had paid one into the-currency in addition to said thought of the sale deed in order to the latest manufacturers of the home and you will led so you’re able to remove the whole introduction produced.
The newest CIT(A) overlooked the lands elevated because of the Assessee with the validity of reopening out-of assessment and you can assumption of legislation of the AO
S. 143(3) : Research – Disallowance brand new share gotten off group to the ESI and you will EPF – Federal Faceless Focus Middle (NFAC) based in Delhi, regardless of if centralised, is limited because of the precedents laid down because of the HC workouts territorial jurisdiction along side Assessee’s AO.
ITAT retains you to National Faceless Appeal Center (NFAC) situated in Delhi, even though centralised, is bound by precedents placed off from the HC exercise territorial legislation (here, Allahabad HC) along side Assessee’s AO. Opines you to definitely an attraction facing an order passed by NFAC lies before the ITAT counter with legislation over Assessee’s AO and you may “For this reason attention resistant to the tribunal (Agra in present case) will sit to your Hon’ble Allahabad Large Courtroom so the choice made by Hon’ble High courtroom is not only joining to your the fresh Tribunal and also with the NFAC, (even though seated within the Delhi) that’s deciding this new lis pertaining to Agra ITAT Jurisdiction (Allahabad HC Jurisdiction).(ITA Zero.41 & 42/Agr/2021, dt fourteen-06-2021) ( AY. 2018 -19, 2019-20)