Re: Two additions both deleted by CIT(A). In Deptt appeal ITAT restored 1 addition to AO and confirmed 2nd deletion
In AY 11-12 and 12-13 two additions were made by AO u/s 43(5) Rs. 3Cr and u/s 40(a)(ia) -Rs.50L. Both additions deleted by CIT(A). In Deptt. appeal the Tribunal vide order dated 18.01.2020 restored the issue to AO on 1st issue i.e. 43(5) and on 2nd issue confirmed the deletion u/s 40(a)(ia) of Rs.50L.
Deptt. has option to file appeal on 2nd issue but it is below tax effect.
What is the status of 2nd Issue
(a) VsV on 1st issue 100% of tax.
(b) on 2nd issue –
(1) No tax as issue already settled?
(2) 50% as Deptt has appeal option open?
(3) 100% as the entire addition is to be considered?
Thanks
With regard to the 2nd issue, since time limit is available with the Department to file the appeal, 50% to be paid if opted for VSV Scheme.
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