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ITAT allowed appeal against CIT(A)'s dismissal of rectification petition under s.154 concerning deduction claim under s.80P(2)(d). CIT(A) erroneously held s.154 orders non-appealable, contradicting express provisions of s.246A(c) which permits such appeals. Assessee's interest income from cooperative banks remained undisputed by revenue authorities. Appeal rejection was purely on legal grounds rather than factual merits. Tribunal set aside impugned order, noting clear statutory right of appeal against rectification orders. Addition deleted based on established judicial precedents and interpretation of s.246A(c). Assessee's appeal sustained with favorable outcome on both procedural and substantive grounds.
ITAT allowed appeal against CIT(A)'s dismissal of rectification petition under s.154 concerning deduction claim under s.80P(2)(d). CIT(A) erroneously held s.154 orders non-appealable, contradicting express provisions of s.246A(c) which permits such appeals. Assessee's interest income from cooperative banks remained undisputed by revenue authorities. Appeal rejection was purely on legal grounds rather than factual merits. Tribunal set aside impugned order, noting clear statutory right of appeal against rectification orders. Addition deleted based on established judicial precedents and interpretation of s.246A(c). Assessee's appeal sustained with favorable outcome on both procedural and substantive grounds.
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