2025 (3) TMI 219

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.... For the Revenue : Shri Srinath Sadanala, DR ORDER PER VIJAY PAL RAO, VICE PRESIDENT This appeal by the assessee is directed against the order dated, 27/09/2024 of the learned CIT (A)-NFAC, Delhi, for the A.Y.2021-22. 2. The assessee has raised the following grounds of appeal: "1. Violation of Principles of Natural Justice. 2. The Ld. Commissioner of Income Tax (Appea....

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....erred in disallowing the 80JJAA deduction under section 143(1)(a)(ii). 6. The Appellant craves leave to add, amend, alter or rescind any of the above grounds of appeal before or at the time of hearing." 3. The assessee company filed its return of income on 22/02/2022 declaring total income of Rs. 54,77,122/- after claiming deduction u/s 80JJAA of the I.T. Act, 1961 for Rs. 6,12,505/-. ....

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....f disallowance u/s 80JJAA is a debatable issue and cannot be made in the proceedings u/s 143(i)(a) of the I.T. Act, 1961. He has further submitted that even otherwise, the rectification order was passed by the CPC on the petition filed for rectification of mistake of double disallowance and therefore, the disallowance of deduction u/s 80JJAA while passing the order u/s 154 of the I.T. Act, 1961 by....

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....ame amount was also disallowed u/s 40(a)(ia) of the Act. To rectify the mistake, the assessee filed petition u/s 154 of the Act on 3/6/2023 and consequently, the CPC passed the order u/s 154 on 7/7/2023 whereby the mistake of double disallowance was rectified but another disallowance was made on account of deduction u/s 80JJAA of the Act. On appeal, the learned CIT (A) has dismissed the appeal of ....