2025 (8) TMI 539

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....ddhartha Nautiyal, Judicial Member For the Appellant : Shri Maulik Kansara, AR For the Respondent : Shri B. P. Makwana, Sr. DR ORDER PER SIDDHARTHA NAUTIYAL - JUDICIAL MEMBER: This appeal has been filed by the Assessee against the order passed by the Ld. Commissioner of Income Tax (Appeals), (in short "Ld. CIT(A)"), ADDL/JCIT (A)-2, Guwahati vide order dated 26.02.2025 passed for A.....

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.... r.w.s. 2(38) of the I.T. Act amounting to Rs. 43,49,352? Further, appellant craves leave to add, amend, alter or withdraw all or any ground of appeal." 3. The brief facts of the case are that the assessee, a trust, filed it's return declaring Nil income under the head "Income from Other Sources". The Centralized Processing Centre (CPC), Bengaluru processed the return under Section 143....

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....er Section 143(1) of the Act had been adhered to. The claim of alternate exemptions could not be entertained at the appellate stage, as the adjustment related specifically to the disallowance of a particular exemption initially claimed under Section 10(23AAA) of the Act, by the assessee. Therefore, the CIT(Appeals) rejected all grounds of appeal, holding that the adjustment made by the CPC was in ....

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....in their respective orders. 6. We have heard the rival contentions and perused the material on record. Having considered the rival submissions and in light of the legal position that appellate authorities are vested with the power to adjudicate on alternative legal pleas raised by the assessee even if such claims were not made in the return of income, we are of the considered view that the CIT(....