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    <title>2024 (2) TMI 152 - ITAT KOLKATA</title>
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    <description>A prima facie disallowance of deduction under section 80P could not be made under section 143(1)(a)(v) for an assessment year before the amendment effective from 01.04.2021, because the CPC had no authority to reject the claim merely on the ground of late filing; the disallowance was therefore unsustainable and was set aside. Penalty under section 272A(1)(d) was also deleted because the record did not show service of the demand notice, the assessment had been completed under section 143(3), and reasonable cause for the default was disclosed.</description>
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      <title>2024 (2) TMI 152 - ITAT KOLKATA</title>
      <link>https://www.taxtmi.com/caselaws?id=449001</link>
      <description>A prima facie disallowance of deduction under section 80P could not be made under section 143(1)(a)(v) for an assessment year before the amendment effective from 01.04.2021, because the CPC had no authority to reject the claim merely on the ground of late filing; the disallowance was therefore unsustainable and was set aside. Penalty under section 272A(1)(d) was also deleted because the record did not show service of the demand notice, the assessment had been completed under section 143(3), and reasonable cause for the default was disclosed.</description>
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