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INCOME TAX APPELLATE TRIBUNAL (DELHI BENCH)
AVDHESH KUMAR MISHRA, AM
M/s. National Housing Bank – Appellant
Versus
Assistant Commissioner of Income Tax – Respondent
| Table of Content |
|---|
| 1. overview of appeals and background. (Para 1 , 2) |
| 2. grounds of appeal concerning loss claims. (Para 3) |
| 3. details of the loss and its implications. (Para 4) |
| 4. arguments presented by the appellant. (Para 5) |
| 5. defense by the respondent. (Para 6 , 7) |
| 6. court's analysis and observations. (Para 8 , 11) |
| 7. ratio decidendi regarding loss allowance. (Para 12) |
| 8. final conclusion and order. (Para 13 , 14) |
ORDER
PER AVDHESH KUMAR MISHRA, AM
Common facts arise in the above captioned appeals of the assessee;therefore, these appeals were heard together and are being disposed off by this common order. At the outset, it is worth mentioning that this is third round of appeal before the Tribunal. On earlier two occasions, the Tribunal remanded the matter back (both quantum and penalty appeals) to the AO with certain directions. The issues in disputes in both appeals remain same every time.
2. The appeal ITA No. 1717. Del.2019 for Assessment Year (AY) 2003-04 filed by the assessee is directed against order dated 31.12.2018 of the Commissioner of Income Tax (Appeals)-06, New Delhi and second appeal ITA No.1158/Del/2023 for AY 2003-04 filed by the assessee is directed against order dated 2
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