2025 (11) TMI 894

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....18-19. 2. The assessee has raised the following grounds of appeal : Ground No.1 The order of the learned Additional / Joint Commissioner of Income-tax (Appeals) - 1, Chandigarh is erroneous in law and on the facts of the case. Ground No.2 The learned Additional / Joint Commissioner of Income-tax (Appeals) - 1, Chandigarh erred in sustaining the addition of Rs. 23,67,760 made by CPC, in the order passed u/s 143(1). Ground No.3 The learned Additional / Joint Commissioner of Income-tax (Appeals) - 1, Chandigarh erred in not allowing the claim of deduction u/s 40(a)(ia) of Rs. 23,67,760 for the mere apparent mistake of non-mention of the same in Schedule - Ol of ITR-6 without considering ....

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....under section 143(1) of the Act vide intimation dated 04.01.2019, disallowed the claim thereby reducing the returned loss to Rs. 51,53,918/-. 4. Aggrieved with the order of CPC, the assessee filed appeal before the Ld. First Appellate Authority. The Ld. First Appellate Authority dismissed the appeal holding that the assessee failed to substantiate that the said amount was disallowed in the preceding year and that the corresponding TDS was deposited during the current year. 5. Aggrieved with the order of Ld. First Appellate Authority, the assessee is in further appeal before us. The Learned Authorised Representative (Ld. AR) invited our attention to page no.46 of the order of Learned Assessing Officer ("Ld. AO") passed under section 14....