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ITAT held that for AY 2018-19 the appellate authority (CIT(A)) lacked power under s.251(1) to set aside the assessment to the AO for de novo computation because the proviso empowering such reference took effect from 01.10.2024; accordingly the CIT(A)'s direction to verify expenditure and remit computation to the AO was unauthorized and was quashed, with instruction that CIT(A) exercise only statutory powers to confirm, reduce, enhance or annul the assessment. On claim of parity between ss.12A and 10(23C), ITAT concluded no legislative intent to extend the proviso's benefit to s.10(23C); consequently the CIT(A)'s disallowance of s.10(23C) relief for AY 2018-19 was upheld and the assessee's cross-objection dismissed.
ITAT held that for AY 2018-19 the appellate authority (CIT(A)) lacked power under s.251(1) to set aside the assessment to the AO for de novo computation because the proviso empowering such reference took effect from 01.10.2024; accordingly the CIT(A)'s direction to verify expenditure and remit computation to the AO was unauthorized and was quashed, with instruction that CIT(A) exercise only statutory powers to confirm, reduce, enhance or annul the assessment. On claim of parity between ss.12A and 10(23C), ITAT concluded no legislative intent to extend the proviso's benefit to s.10(23C); consequently the CIT(A)'s disallowance of s.10(23C) relief for AY 2018-19 was upheld and the assessee's cross-objection dismissed.
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