Allowing the appeal of the revenue the Court held that , even in affirming the findings of the authorities below, the burden was heavier for the higher appellate authority when it decided to reverse the findings of the authorities below. The findings of the Tribunal were perverse and required interference of the court under appeal . Additions confirmed . Order of the AO and CIT (A) is up held ( BP .1-4-1996 to 4-6-2002)
CIT v. Dr. K. Kannagi (2020) 424 ITR 470/ 194 DTR 145 / 316 CTR 695 (Mad) (HC) CIT v. Dr. N. Rajkumar (2020) 424 ITR 470/ 194 DTR 145 / 316 CTR 695 (Mad) (HC)
S.254(1) : Appellate Tribunal- Duties- Tribunal bound to give reasons for reversing findings rendered by lower authorities — Deletion of addition is held to be not justified .[ S.132(4) , 158BA, 158BC]