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3. Both the appeals were accordingly taken up for hearing together and are being disposed of by a common consolidated order for the sake of convenience.

We shall be dealing with the facts in the case of the assessee Shri Rajeshkumar Mohanlal Shah(the son) in the Department's appeal in paripassu the other appeal also.

4. Grounds raised by the Revenue in ITA No. 575/Ahd/2020 reads as under:

ITA No.575/Ahd/2020 & 10/Ahd/2021
ITO vs. Shri Rajeshkumar Mohanlal Shah & Late Shri Mohanlal B Shah L/h. Shri Rajeshkumar M Shah Asst.Year -2007-08 "(1) The Ld. CIT (A) has erred in law and on facts in deleting the addition of Rs.