$ 16. * IN HIGH COURT OF DELHI AT NEW DELHI + ITA 328/2015 PR. CIT-17 Appellant Through: Mr.Duleep Shivpuri, Sr.Standing Counsel with Mr.Sanjay Kumar, Advocate Versus SH. KRISHNA BANSAL Respondent Through: None. CORAM: JUSTICE S.MURALIDHAR JUSTICE CHANDER SHEKHAR ORDER % 02.05.2017 1. For last two years, Revenue has tried to unsuccessfully serve Assessee. It has come to point now where Revenue is seeking to serve Assessee through substituted service. Although application is not on record, it is handed over in Court. 2. It is seen that tax effect in present case is only marginally above that set by Department for its appeals. 3. question sought to be urged concerns deletion addition made by AO under Section 40(ia) read with Section 194C of Income Tax Act, 1961. Both Commissioner of Income Tax (Appeals) as well as Income Tax Appellate Tribunal have concurrently held against Revenue. ITA 328/2015 Page 1 of 2 finding is factual and is not shown to be perverse. In circumstances, question urged is left open for consideration in appropriate case. 4. appeal is dismissed. S.MURALIDHAR, J CHANDER SHEKHAR, J MAY 02, 2017 anb ITA 328/2015 Page 2 of 2 Pr. CIT-17 v. Krishna Bansal