2022 (3) TMI 959

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.... the ITO, Corporate Ward 1, Coimbatore for assessment year 2014-15 u/s.143(3) of the Act, vide order dated 26.12.2016. 2. The only issue in this appeal of assessee is against the order of PCIT assuming jurisdiction u/s.263 of the Act consequently passing the revision order in setting aside the completed scrutiny assessment framed u/s.143(3) of the Act allowing the claim of deduction u/s.80IA after considering the issue and after examining the issue. For this assessee has raised various grounds which we need not to reproduce. 3. Brief facts are that the assessment was completed u/s.143(3) of the Act for the relevant assessment year 2014-15 and allowed the claim of deduction u/s.80IA of the Act by relying on the decision of Hyderabad Be....

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....es of the case. We have perused the case records. Before us, the ld.counsel for the assessee Shri S. Sridhar, stated that the original assessment framed allowing deduction u/s.80IA of the Act was based on the decision of Co-ordinate Bench of ITAT, Hyderabad in the case of S. Venkatiah, supra. The ld.counsel for the assessee carried us through para 6.1 of the assessment order which reads as under:- 6.1 Deduction u/s 80-IA 6.1.1. As per the provisions of Section 80AC deduction is admissible under section 80-IA only if the assessee furnishes a return of income on or before the due date specified under sub-section (1) of section 139. 6.1.2 In this case, the assessee filed their return of income only on 31.03.2015 i.e.....