ITAT allowed the assessee's appeal on two key grounds: (1) No...

ITAT allowed the assessee's appeal on two key grounds: (1) No disallowance under Section 40(a)(ia) was warranted since the payee offered the interest income to tax in their return, consistent with Supreme Court precedent; (2) Deduction under Section 80IB/80IA was permissible despite not being initially claimed in the original return, with the appellate authority empowered to consider such claims. The tribunal set aside the lower authority's order and directed the Assessing Officer to delete the addition and allow the deduction, effectively providing relief to the assessee on both disputed issues.