2023 (10) TMI 700

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....he AO'] order passed u/s 143(3)/154 of the Act. 2. The assessee has taken the following ground: "1. That under the facts and circumstances of the case, the Id. CIT(A) NFAC grossly erred in confirming the action of assessing officer CPC u/s 154 read with S. 143(1) for making prima facie adjustment and thereby computing the total income of the appellant institution at Rs. 930659/- as against NIL returned income on the reasoning that the accumulation of income u/s 11(2) has correctly been allowed at Rs. 420986/- instead of Rs. 1351645/- claimed by the appellant particularly when such prima facie adjustment is not in consonance with the provisions of 143(l)(a)(ii) of the Act. 2. That under the facts and circumstances of the....

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.... The CPC issued intimation u/s 143(1) dated 27.03.2018 restricted accumulation of income u/s 11(2) amount to Rs. 4,20,986/- instead of 13,51,645/- and the tax was calculated on the amount to Rs. 9,30,659/- and tax liability was calculated amount to Rs. 1,37,998/-. The assessee made the rectification u/s 154 but the ld. AO had not accepted and confirmed the demand in intimation u/s 143(1). Aggrieved assessee filed an appeal before the ld. CIT(A). The ld. CIT(A) upheld the order of the ld. AO. Being aggrieved assessee filed an appeal before us. 4. We heard the rival submission and consider the documents available in the record. The ld. AR submitted a written submission which are kept in the record. The issue is well settled, and the ld. DR....