2025 (4) TMI 875

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....erred to as the "Act"), dated 24.02.2023, for Assessment Year 2021-22. 2. Grounds taken by the Assessee are reproduced as under: 1) 1.1) The Learned Commissioner of Income Tax (Appeals) has erred in confirming the order u/sec 154 of the Act passed by the learned The Learned Deputy Director of Income Tax CPC, Bangalore, who has erred in not rectifying the intimation u/sec 143(1) of the Act, wherein, while processing the return of income, an addition of Rs. 52,16,56,993/-has been made being "written off bad debts recovered", by not considering the fact that the said amount of Rs. 52,16,56,993/- has already been credited to the Profit and Loss Account of the appellant for FY 2020-21, and was included in the net profit before tax for FY 2020....

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....d on 06 July, 2023, was brought to the notice of The Learned Commissioner of Income Tax (Appeals), in the written submissions filed in the appellate proceedings. 2) Without having any prejudice of whatsoever nature to the Ground No.1, The Learned Commissioner of Income Tax (Appeals) has erred in confirming the order u/sec 154 of the Act, passed by the Learned Deputy Director of Income Tax CPC, Bangalore, who having made an addition of Rs. 52,16,56,993/- to the returned income, has further erred in not re computing and revising the deduction claimed U/s.36(1)(viia) of the Act, by not considering the fact that the deduction u/s 36(1) (viia) of the Act, is calculated on the basis of Income computed under the head Profits & Gains of Business ....