2024 (12) TMI 1549

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....the Revenue : Shri Mahesh Pamnani (Sr DR) ORDER PER AMIT SHUKLA (J.M): The aforesaid appeals have been filed by the assessee against separate impugned order of even date 10/05/2024, by Addl./JCIT (A)-9, Delhi in relation to the adjustment made u/s. 143(1) for the A.Y. 2013-14 and 2014-15. 2. The common ground raised by the assessee in both the years are that the ld. CIT(A) has erred in....

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....ppeal before the ld. CIT (A) as intimation order was served to the assessee on 02/02/2020 and appeal was filed on 14/02/2020. 4. On merits, it is seen that that the CPC has made adjustment u/s. 80P of Rs. 4,91,145/- in A.Y. 2013-14 and Rs. 9,84,335/- in A.Y. 2014-15 by disallowing the claim of deduction u/s. 80P(2)(d). Before us, it has been contended that, the said adjustment u/s. 80P in A.Y. ....

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....e due date specified under sub-section (1) of Section 139. Thus, prior to A.Y. 2021-22, no such adjustment could have been made. Moreover, here in this case as held above, the return of income was furnished within the due date prescribed u/s. 139(1). Thus, the entire disallowance was beyond the scope of Section 143(1) itself. Accordingly, the disallowance made by the CPC and as confirmed by the ld....