2025 (6) TMI 891

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....for Assessment Year 2021-22. 2. Grounds taken by the assessee are reproduced as under: "1. Under facts and circumstances of the case the Learned Commissioner of Income Tax (Appeal) has erred in not allowing carry forward of entire current year business loss amounting to INR 1,04,57,56,800 which was claimed by the Appellant in its ROI and as reflected in ITR-V 2. Under facts and circumstances of the case the Learned Commissioner of Income Tax (Appeal) erred in facts and in law by granting only partial credit of prepaid taxes to the extent of INR 2,41,28,920 as against INR 7,02,91,070 duly reflected in Form no. 26AS for the captioned year and as claimed by the Appellant in its ROI filed on March 16, 2022 3. Under facts and circumstance....

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....assessee declared a net business loss of Rs. 1,04,57,56,800/- resulting into Nil taxable income and claimed credit of prepaid taxes amounting to Rs. 7,02,91,067/- that was duly reflected in Form No. 26AS for the captioned Assessment Year, resulting into refund due of Rs. 7,02,90,070/- to the assessee. Subsequently, the return of income was processed and an intimation was issued u/s. 143(1) of the Act dated 26.07.2022, wherein the credit of prepaid taxes allowable to the assessee was restricted to Rs. 2,27,32,121/-. Further, the refund determined in this regard amounting to Rs. 2,37,93,118/- was adjusted against the outstanding demand for Assessment Year 2020-21 on 08.09.2022. Against the said intimation, assessee made online application for....

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....lted in a delay of 28 minutes in filing the return within the due date u/s. 139(1) of the Act. The email is reproduced below: 4.1. In support of the above email, assessee has also furnished screen shots for the technical glitches faced by it. 5. We have considered the submission made before us along with documentary evidences placed on record. Assessee has elaborately explained the technical difficulty faced by it and all the possible steps taken by it to resolve the same for filing the return within the prescribed due date u/s. 139(1) but failed, resulting into a delay of 28 minutes in filing the return. Considering the facts on record and the bonafide hardship faced by the assessee, as well as considering the claim made by the assessee ....