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INCOME TAX APPELLATE TRIBUNAL (HYDERABAD BENCH)
Shri Vijay Pal Rao, VP, Shri Madhusudan Sawdia, AM
Assessee – Appellant
Versus
CIT (A) NFAC Delhi – Respondent
| Table of Content |
|---|
| 1. arguments on retrospective application of taxation provisions. (Para 3 , 8) |
| 2. claim of net loss against gross income disputed. (Para 4 , 5 , 6) |
| 3. assessment principles articulated. (Para 7 , 9) |
| 4. court's position on retrospective vs prospective taxation. (Para 10 , 11) |
| 5. final order of dismissal. (Para 12) |
आदेश/ORDER
Per Vijay Pal Rao, Vice President This appeal by the assessee is directed against the order dated 06/09/2024 of the learned CIT (A)-NFAC Delhi, for the A.Y.2022-23.
2. The assessee has raised the following grounds of appeal:
3. The assessee has also filed a petition for admission of additional ground which reads as under:
“Without prejudice to the grounds, the learned CIT (A) is not justified in confirming the addition of Rs.1,86,60,850/- made by learned Assessing Officer being gross receipts from gaming activity u/s 115BB, ignoring the fact that the amendment made vide insertion of section 115BBJ w.e.f. 01/04/2023 is clarificatory in nature and Hence, the net receipts only can be brought to tax”.
4. The assessee is a private sector salaried employee stated to have an annual income less than five lakh rupees and no other income than salary. The assessee f
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