2025 (7) TMI 1689

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....l, Addl. CIT, Sr. D.R. ORDER PER PRADIP KUMAR CHOUBEY, JUDICIAL MEMBER:- The present appeals bearing ITA Nos. 2495/KOL/2024 and 2496/KOL/2024 are directed at the instance of assessee against the orders of Id. Additional/ Joint Commissioner of Income Tax (Appeals)-2, Vadodara dated 23.10.2024 and 09.10.2024 passed for Assessment Years 2020-2021 and 2021-2022 respectively. 2. Brief facts of the ....

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....ility at Rs. 20,08,664/-. The CPC, Bengaluru computed the total income at Rs. 77,25,630/- and kept the tax liability same. However, the AO, CPC restricted the TDs claim of the appellant of Rs. 9,21,997/- to Rs. 8,79,022/- only. The appellant sought rectification of the same u/s 154 of the Act. However, the AO, CPC rejected the said rectification application vide order dated 26.10.2022 u/s 154 of t....

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....esentative did not raise any objection in remitting the matter back to the file of ld. Assessing Officer for fresh consideration. 6. Upon hearing the submissions of the ld. Counsel of the respective parties and on perusal of the orders of lower authorities, the bone of contention and issue of appeal is not allowing the TDS of Rs. 3,39,292/- (for AY 2020-21) as the TDS allowable as per 26AS of the....

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....ut due to technical error and error in writing wrong alphabet in PAN credit of TDS of Rs. 42,975/- was not by CPC for the instant assessment year. 6.1. We find substance in the arguments of the ld. Counsel for the assessee that the objective of statute and constitution is not to punish the assessee for error of omission not done with malafide and intentional motive. It is also pertinent to mentio....