2024 (5) TMI 220

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....ehta ORDER PER SATBEER SINGH GODARA, J.M. : This assessee's appeal for assessment year 2017-18, arises against the National Faceless Appeal Centre [in short the "NFAC"] Delhi's Din and Order No. ITBA/NFAC/S/250/ 2023-24/1061238617(1), dated 21.02.2024, involving proceedings u/s. 144 of the Income Tax Act, 1961 (in short "the Act"). Heard both the parties. Case file perused. 2. The a....

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....- representing the total of cash deposits during demonetization period made by the AO, overlooking the submissions of the appellant in this respect. The appellant craves leave to add to, amend, alter, delete or modify all or any of the above ground of appeal or raise a new ground of appeal before or at the time of hearing." 3. Learned counsel representing the assessee invited my attent....

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....0P of the Act. This is for the precise reason that such a deduction has to be claimed in "a return" going by sec. 80A(5) of the Act which has been held to be a mandatory condition as per EBR Enterprises vs. Union of India [2019] 107 taxmann.cm 220 (Bom.) (HC). It is made clear that there is no material in the case file indicating the assessee to have raised the foregoing sec. 80P claim in a return....