2023 (9) TMI 679

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.... : Shri I.P. BansalAdv.; And Shri Vivek Bansal, Adv. For the Department : Shri T. James Singson, CIT (DR) ORDER PER ANUBHAV SHARMA, JM: The assessee has come in appeal challenging the orders dated 11.03.2022 for A.Y. 2017-18 and 23.01.2023 for A.Y. 2018-19 passed by the Principal Commissioner of Income Tax, Delhi-12, New Delhi u/s 263 of the Income-tax Act, 1961 (hereinafter referred a....

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.... of filing the return was 7.11.2017 and 30.10.2018 respectively. He submitted that form 56 was submitted to the AO during the course of assessment proceedings, for A.Y. 2017-18 it was submitted online on 8.12.2019 while for A.Y. 2018-19 it was filed on 3.10.2018. The assessments were completed for A.Y. 2017-18 on 30.12.2019 and for A.Y. 2018-19 on 26.2.2021. He submitted that in any case before th....

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....is of the considered view that during assessment proceedings in response to notices issued by the AO assessee had submitted justification of the deduction u/s 10AA of the Act. Thus, as such, the issue stood examined by the learned AO and also before the assessment order was passed, the Auditor's report in form 56 stood filed. The judgments relied by the learned AR were certainly then holding the f....