2025 (10) TMI 144

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.... are related to Assessment Year 2018-19, therefore, they are taken together for consideration. First we take ITA No. 3610/Del/2024. ITA No.3610/Del/2024 3. This appeal is filed by the assessee against the order of Ld. CIT(A), NFAC in Appeal No. CIT(A), NFAC/2017-18/10051718 dated 14.06.2024 passed u/s 250 of the Act arising out of the order passed u/s 143(3) dated 24.03.2021 for Assessment Year 2018-19. 4. Brief facts of the case are that assessee is a firm/LLP engaged in the business of manufacturing of wearing apparels since inception. The return of income was filed on 29.10.2018 declaring total income of Rs. 20,29,310/- after claiming deduction of Rs. 30,34,160/- u/s 8-JJAA which was disallowed by the AO for the reason that audi....

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.... it on the e-filing portal and even submitted the same manually during the course of assessment proceedings which is placed on record, containing all the details pertaining to additional employees, which has been arbitrarily ignored by lower authorities. 4. The learned Commissioner of Income Tax (Appeals) has passed the Order brushing aside arbitrarily the replies filed by assessee during the course of appellate proceedings and written submissions filed before it justifying their claim of deduction u/s 80JJAA of the Act. 5. The learned Commissioner of Income Tax (Appeals) has failed to appreciate that the appellant had duly discharged its onus by bringing all material facts on record, in order to substantiate the genuinene....

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....sessee e-filed report in Form 10DA alongwoth the return of income filed and deduction u/s 80JJAA was also claimed in the return as is apparent from perusal of the return of income placed at pages 54 to 130 of the Paper Book. It is also seen that originally in Form 10DB inadvertently the column No.5(a) and 5(b) of the audit report, the figures of new workmen employed was filled as 0(Zero) however, the said report was revised and modified report duly signed by the Auditors was filed before the AO vide letter dated 28.12.2020. 8. It is not the case of the Revenue that any additional / fresh claim was made by the assessee during the course of the assessment proceedings rather deduction u/s 8-JJAA was already made in the return of income file....