2025 (8) TMI 1311

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....rises 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 perused. Assessee pleads the following su....

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....), 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 of appeal, at any time before or at the time of appeal. 3. Learne....

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.... 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 argument in light of (2021) 123 taxmann.com 252 (Mum) Maria Fernandes Chery....