Answers On Topic: cross objection
Can an assessee raise the question of Law which was not raised before the lower Authorities , for the first time before the Tribunal , in an appeal filed by the revenue .?
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1.Assessment was completed u/s 143(3)/147 making additions on account of discrepancies found in survey on account of Cash in hand and Stock in trade etc. 2.On appeal the additions made by A.O. were confirmed by CIT(A) vide order dated 06/02/2020 and ITAT order dated 08/07/2016. 3.Penalty u/s 271(1)(c) of Rs.4,60,000 was levied vide order dated 26/04/2017. 4.On appeal CIT(A) deleted the Penalty on the sole ground taken regarding limitation stating that - "order of the ITAT was passed on 08/07/2016 , therefore the penalty order must have been passed by the A.O. upto 31/03/2017. However the A.O. has passed the…
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