2025 (9) TMI 1394

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.... AY 2017-18. The return was processed under section 143(1) of the Income-tax Act, 1961 (for short 'the Act'). The case was selected for limited scrutiny under CASS for the following issues :- (i) The assessee has claimed substantial relief u/s 89. (ii) Salary income shown in ITR is less than the salary income as per form 26AS. (iii) Total taxable income shown in ITR is significantly less than the total taxable income shown in Annexure II of TDS Return of employer in Form 24Q. 3. Accordingly, notices u/s 143(2) and 142 (1) along with questionnaire were issued and served on the assessee. The main issue in this case was that income disclosed by the assessee is less than the income on which TDS was deducted. The as....

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....appeal filed by the assessee with the observation that the plea of the assessee was already rectified by the Assessing Officer by passing a rectification order u/s 154 of the Act and with regard to taxability of interest, the same was rejected for the reason that the amount represent taxable income. 5. Aggrieved, assessee is in appeal before us raising following grounds of appeal:- "1. The order of the Honourable CIT(A) is bad in law and against the facts placed on the file as the Honourable CIT (A) erred in Jaw in confirming the disallowance of interest received by the assessee on the orders of the Honourable Punjab & Haryana High Court under its Discretionary powers. 2. The Honourable CIT(A) erred in law in confirming....

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....sing of order u/s 143(3), the assessee made an application under Section 154 of the Income Tax Act, 1961 and the learned AO allowed the full tax rebate of Rs. 9,28,962.00." 6. At the time of hearing, ld. AR of the assessee brought to our notice page 5 of the assessment order wherein Assessing Officer has disallowed the claim of the assessee u/s 89(1) of the Act and the same was rectified by the Assessing Officer by passing a rectification order u/s 154 of the Act which is placed at page 51 of the paper book. He also brought to our notice the calculation at page 54 of the paper book wherein Assessing Officer has taken the aggregate tax liability of Rs. 9,24,623/- and since the assessee has already paid the due tax of Rs. 18,50,000/- by wa....