2025 (8) TMI 1311

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....'s appeal for assessment year 2018-19, arises against the Commissioner of Income Tax (Appeals)/National Faceless Appeal Centre [in short, the "CIT(A)/NFAC"], Delhi's DIN and order no. ITBA/NFAC/S/250/2024-25/1068862530(1), dated 19.09.2024 involving proceedings under section 143(3) of the Income-tax Act, 1961 (hereinafter referred to as 'the Act'). 2. Heard both the parties at length. Case file....

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.... 3. That without prejudice to above grounds, the Id. CIT(A), NFAC, ought to have allowed the deduction u/s 54EC of the Act, at Rs. 50,00,000/- i.e. to the extent of investment made by the appellant, instead of restricting the same to the amount claimed in ITR at Rs. 38,93,880/- 4. The appellant respectfully craves leave to add, alter, omit or substitute any or all of the above grounds ....

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....nce margin of 10% as per section 50C 3rd proviso and it deserves to be deleted therefore. 5. The Revenue's vehement contention on the other hand is that the said margin of 10%, substituting earlier 5% difference, vide Finance Act, 2020 w.e.f. 01.04.2021 does not carry any retrospective effect. It is in this factual backdrop that the tribunal finds no merit in the Revenue's instant technical arg....