2025 (10) TMI 151

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.... of the Income-tax Act, 1961, for the assessment year 2023-24. 2. The Revenue, in substance, has assailed the action of the learned CIT(A) in deleting the disallowance of exemption of Rs.110,80,56,197/- claimed under section 10(23D) of the Act. The grievance is twofold: first, that the Assessing Officer was correct in denying such exemption while processing the return of income under section 143(1); and second, that the CIT(A) travelled beyond jurisdiction in entertaining what is alleged to be a "fresh claim" not made in the original return or through a valid revised return. 3. The relevant facts are that the assessee trust was established in 1994 and is a mutual fund duly registered with SEBI. It filed its return of income in Form IT....

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....observations: "5.1 On grounds of appeal Nos. 1.1 to 3.1:- The issue under consideration is the disallowance of exemption claimed under section 10(23D) of the Act, which was recomputed by the Centralized Processing Centre (CPC) due to mismatch in disclosure between Schedule IE and Schedule OS of the return of income. 5.2 The initial adjustment under section 143(1)(a)(ii) leading to disallowance of exemption of 1,10,80,56,197 stands nullified through rectification under section 154 dated 11.11.2024. 5.3. The variance of 1,10,80,56,197 reflected in the rectification order is due to wrong return filed by the appellant. In the return of income Part B2 of Part B - TI appellant should have claimed exemption u/s 10(23D) o....