2022 (6) TMI 262

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....R : KULDIP SINGH, JUDICIAL MEMBER: The appellant, M/s. PRIA CETP (India) Ltd. (hereinafter referred to as 'the assessee') by filing the present appeal, sought to set aside the impugned order dated 27.03.2018 passed by Commissioner of Income Tax (Appeals)-48, Mumbai [hereinafter referred to as the CIT(A)] qua the assessment year 2012-13 on the grounds inter alia that :- "1. On the facts....

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....,293/- under section 80IA of the Income Tax Act, 1961 (for short 'the Act'). Declining the contentions raised by the assessee the AO proceeded to disallow the deduction claimed by the assessee under section 80IA(3) of the Act and thereby framed the assessment at the total income of Rs.37807114/- under section 143(3) of the Act. 3. Assessee carried the matter before the Ld. CIT(A) by way of fili....

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.... assessee's claim qua deduction under section 80IA of the Act for preceding years i.e. A.Y. 2006-07 to 2011-12 has not been entertained and as such the only inference can be drawn that present claim of the assessee for deduction under section 80IA of the Act has become the first year. 7. In the backdrop of the aforesaid facts and circumstances of the case we have perused the impugned order pass....