admission

unless an allowance or deduction has been made as per Income Tax Act and records, the same will not come under the sweep of Section 41(1). A return treated as non est and `invalid' can by no stretch of imagination be treated as allowance or deduction as per Income Tax Act and records. Full Article

All these appeals have been preferred under Section 260A (2) of the Income Tax Act, 1961 (hereinafter referred to as the ''Act 1961') by the Revenue as well as by the Assessee. It provides for filing of an appeal in the form of a memorandum of appeal within 120 days from the date on which the order appealed against is received by the Assessee or the Chief Commissioner or the Commissioner. It is an admitted position that all these appeals have been preferred beyond the pe.. Full Article