One cannot read provision of section 249(4)(a) into section 253(1)(b)
-
Once section 249(4)(a) is treated as a mandatory condition for filing an appeal before CIT (Appeals) and once that condition stood satisfied at the time of his filing an appeal to CIT (Appeals), then, there was no necessity for the assessee to once again pay the admitted tax due as a condition precedent to his filing the appeal before the Appellate Tribunal under section 253(1)(b)
SUPREME COURT OF INDIA
CIT
v.
Pawan Kumar Laddha
Civil Appeal Nos. 8914-8922 of 2003
April 6, 2010
