TaxTMI 
TaxTMI 
2023 (10) TMI 1278
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....e Act') dated 13.05.2022 for the assessment year 2018-19. The assessee has assailed the impugned order on the following grounds of appeal: "1. In the facts & under the circumstances of the case, the ld. Commissioner of Income Tax - Appeals (NFAC) erred in upholding the order passed by CPC denying deduction u/s 80P. The appellant is entitled for deduction which has been wrongly disallowed; 2. In the facts & under the circumstances of the case, Commissioner of Income Tax -Appeals (NFAC) erred in not appreciating that the prima facie adjustment made u/s 143(1)(a) is not in accordance with provisions of law. Denial of deduction u/s 80P by way of prima facie adjustment is an apparent mistake, rectifiable u/s. 154. 3. In the facts and under....
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....before the Tribunal; therefore, some time was involved in engaging a new counsel. Apart from that, it was submitted that as the new counsel at the relevant point of time was busy with the time barring tax audit reports and returns of income, and also took some time to file the present appeal; therefore, some delay for no fault of the assessee had occasioned in the filing of the same. 3. Per contra, the Ld. Departmental Representative (for short 'DR') raised an objection to seeking of condonation of delay involved in the appeal filed by the assessee. 4. After thoughtful consideration of the reasons stated in the application for condonation of delay, it transpires that as the delay of 24 days in filing of the present appeal had occasioned b....
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....s the appeal of the assessee society against declining of its claim for deduction u/s 80P(2)(a)(i) vide intimation u/s 143(1)(a), dated 07.06.2019, was dismissed by the CIT(Appeals) vide his order dated 19.04.2022, therefore, the said intimation u/s 143(1)(a) (supra), to the said extent merged in the order of the CIT(Appeals). Although the assessee society thereafter on the aforesaid issue, i.e., declining of its claim for deduction u/s 80P(2)(a)(i) had vide its application filed with the A.O u/s 154 of the Act dated 02.05.2022 sought for rectification of the intimation issued u/s 143(1)(a), dated 07.06.2019, but the said application as per the mandate of sub-section (1A) of Section 154 of the Act was in itself not maintainable. We, say so,....