2024 (1) TMI 658

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.... CIT-D.R. ORDER PER : SUCHITRA KAMBLE, JUDICIAL MEMBER:- This is an appeal filed against the order dated 21-01- 2022 passed by Principal Commissioner of Incomer Income, PCIT, Rajkot-1 for assessment year 2017-18. 2. The grounds of appeal are as under:-   Grounds of Appeal Tax effect relating to each Ground of appeal 1 The grounds of appeal mentioned hereunder are wi....

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....thereby setting aside the order passed u/s.143(3) of the Act dated 10.12.2019. The order u/s 263 of the Act is totally unjustified on facts as also in law therefore the same may kindly be quashed. N.A. As appeal is against the validity of revisional jurisdiction of Pr. CIT. 4 Your Honour's appellant craves leave to add, to amend, alter, or withdraw any or more grounds of appeal on ....

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....e, as per Form No. 10CCB, the date of commencement of operation/activity by the assessee was 01-04-2016 hence the assessee is not eligible for deduction u/s. 80IB(11) of the Act. The Assessing Officer while completing the assessment has not examined the conditions stipulated in section 80IB(11A) as the assessee is having business of processing, observation and packaging of fruits and vegetables an....

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..... further submitted that the assessment order is not erroneous or prejudicial to the interest of Revenue and therefore section 263 order be set aside. 6. The ld. D.R. relied upon the order of Pr. CIT and submitted that since the assessee has wrongly availed the deduction under different section under which he is not eligible. The Assessing Officer has not taken cognizance of the same and passed....