The Court : This appeal filed by the revenue under Section 260A of the Income
Tax Act, 1961 (the Act) is directed against the order dated April 10, 2024 passed by the
Income Tax Appellate Tribunal, ‘SMC’ Bench, Kolkata (the Tribunal) in
ITA/172/Kol/20 for the assessment year 2012-13.
The revenue has raised the following substantial questions of law for
consideration :
“i) Whether on the facts and in the circumstances of the case, the Learned Tribunal was justified
in law to delete the addition of Rs.27,93,150/- made by the Assessing Officer on account of bogus
loss on client code modification, ignoring the fact that the respondent assessee failed to prove the
genuineness of the transactions relating to bogus loss on client code modification?