2025 (8) TMI 1086

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....ER This assessee's appeal for Assessment Year 2020-21, arises against the Addl./JCIT(A)-1, Pune's DIN & order No. ITBA/APL/S/250/2024-25/1069242502(1) dated 29.09.2024, in proceedings u/s 143(1) of the Income Tax Act, 1961 (in short "the Act"). 2. Heard both the parties at length. Case file perused. 3. The assessee pleads the following substantive grounds in the instant appeal: ....

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.... the action of Ld. ADIT CPC in assuming jurisdiction u/s 143(1) and not allowing the relief of Rs. 2,04,153/- u/s 90/90A, more so when the same is outside the purview of section 143(1) of Income Tax Act, 1961. 4. That having regard to the facts and circumstances of the case, Ld. CIT(A) has erred in law and on facts in not reversing the action of Ld. ADIT CPC in charging interest u/s 234A,....