Chapter VIA deduction cannot be added twice when already accounted for in assessed income

A Chapter VIA deduction cannot be added again as an excess deduction where the same amount has already been excluded in computing assessed income. In the recorded computation, the eligible deduction was already restricted and reflected in the assessed total income, so any further addition would amount to double counting. The only further step required was verification of the computation. On that basis, the proposed addition was held unsustainable and was deleted, granting relief to the assessee.

---

---

Issues: Whether the addition of Rs. 92,028 on account of alleged excess deduction under Chapter VIA was sustainable when the deduction had already been restricted while computing the assessed income.

Analysis: The assessment was completed ex parte under section 144. In appellate proceedings, the deduction eligible under Chapter VIA was determined at Rs. 44,282. The record showed that this figure had already been taken into account while computing total income, and the further addition of Rs. 92,028 would amount to a repeated addition of the same amount. The correction required only verification of the computation.

Conclusion: The addition of Rs. 92,028 was not sustainable and was directed to be deleted after necessary verification, giving relief to the assessee.

Ratio Decidendi: A sum cannot be added again as excess deduction if it has already been excluded in the computation of assessed income.

---