2025 (9) TMI 79

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....S/250/2024-25/1064864339(1) dated 14.05.2024 for the A.Y.2018-19 arising out of order passed under section 143(3) of the Income Tax Act, 1961 (in short 'Act') dated 21.04.2021. 2. Briefly stated facts of the case are, assessee is a job worker of apparels and filed its return of income declaring a total income of Rs. 6,87,34,760/- on 30.11.2018. The return was summarily processed under section 143(1) of the Act. Assessee being an undertaking in SEZ claimed exemption under section 10AA of the Act. Subsequently, the case was selected for scrutiny and accordingly notice under section 143(2) of the Act dated 29.09.2019 was issued and served on the assessee. Subsequently, assessee filed its revised return of income on 30.10.2019 declaring a gr....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....ade by the assessee, dismissed the appeal of the assessee thereby upholding the decision of the Ld. AO allowing the deduction under section 10AA of the Act of Rs. 6,84,35,474/-. 4. Aggrieved by the order of the Ld. CIT(A), assessee is in appeal before us by raising following grounds of appeal: - "1. The order of the Commissioner of Income-tax (Appeals) National Faceless Appeal Centre, Delhi u/s 250 is erroneous in law and facts of the case. 2. The Ld. CIT(A) has erred in law in non-issuance of a speaking order while disposing off the objections raised by the Appellant against the adjustment proposed by Ld. AO u/s 143(3) of the Act. 3. The Ld. CIT (A) had erred in upholding the action of Ld. AO, denying the enha....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....des and perused the material available on record. Admittedly, assessee while filing the original return of income has filed Form 56F claiming deduction under section Rs. 6,84,35,474/-. However, subsequently assessee revised its return of income but has not filed revised Form 56F by claiming the deduction under section 10AA of the Act amounting to Rs. 11,59,27,224/-. The contention of the Ld. AO is that since the revised Form 56F was filed after the issuance of show-cause notice it cannot be considered as filed withing the prescribed time frame specified under the Act. The assessee ought to have furnished the audit report in the form specified in the I.T. Rules along with the return of income. 9. Whether filing of such audit report along ....