TaxTMI 
TaxTMI 
2025 (11) TMI 889
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....o rectification by the ld. Assessing Officer. It was submitted by the ld. AR that in the rectification order the Assessing Officer mentions that the assessee has filed his objections. Ld. AR drew my attention to pages 92 to 98 of the paper book, which are the copies of the objections filed and the same reads as follows:- 4. It was the submission that the issue relates to an interest on the I.T. Refund to an extent of Rs. 30,59,290/-. The assessee had carried forward business loss of Rs. 6,39,44,308/- and carried forward depreciation loss of Rs. 1,24,37,142/-. It was the submission that admittedly the interest on the income tax refund is liable to be assessed only under the head income from other sources. There is no dispute that in regard to set off against the carried forward loss, admittedly the same cannot be set off against the carried forward business loss but the assessee is fully entitled to set off the said interest income under the head income from other sources against the carried forward depreciation loss as also the depreciation loss of current year. It was the submission that this was also brought to the attention of the AO in the reply filed to rectification u/s.15....
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....scription [ITBA]Hearing Notice u/s 154of Income Tax Act 195 Notice Issue Date 11-Sep-2023 Due Date for Submission 18-Sep-2023 Communication Sent date Document Reference 10 ITSA/REC/F/REC_1/2023-24/1055918068(1) RESPONSE SUBMITTED Please find our Written Submission against your as attachment together with relevant document Novce u's 154 486wa 99661e20bdae266f4cbed268f42fb491Tb4c946686a944b7 2894eb#7eaD Remarks Hash * Value Of Remarks SI No Description Attachment Size(bytes Hash * value of Attachment Name 1 BCCB- REPLY Written Submission 376466 @3ffe3323d64ef7dc AGAINST 154.pdf 39d8e181ff295 Text from Dir. Tax Text from Direct Tax 130280 0069558bade41a08 Law & Practice- Law & Practice Singhania.pdf 9e37e03160a5762c This is a system generated acknowledgement and does not require signature * Hash : This value will uniquely identify the uploaded files and remarks Certified Truy Advocato The 19th September, 2023. The A. C.L.T., -27(1) HALDIA. Dear Sir, Sub: Suo-moto rectification proposed u/s 154 of the Income Tax Act, 1961 of the Order u/s 143(3) in the case of Balageria Cen....
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.... preciation for the purpose of claiming assuming without : Even assuming without admitting your contention with the furnish hereinunder the manner undertaken by us in relatics to the im pushed matter forward unabs lation to setting off of brough years depreciation : orbed business loss as well as setting off current y Particulars claimed to b to be y bes mount ciminied to 1.44,23,472.00 13,84,132.00 Add .¿ Current Vear Depreciation Account 1,04,70,009.00 $0,59,290.00 Lessi Current Year Depreciation 1 below) 0,39,290.00 of brought Tor Lessz Set off of brought forward 1,35,29-007.00 135:29. 007.00 Total Income chargeable to T claimed to b to be y Note-1 _: . Depreciation , be it f can be set off against 'Income from Other can be set off aminst income from Other Sources"- Direct EsPes Las separate attachment from the Text Book of Talent" & Practice by Dr. V.K. Singhania for ready oferta Conad ___ 3" Certifi. A Tru From the above submission, it is unequivocally proved beyond any ambiguity that there remained no under-assessment of income as alleged and the said proposal for rectification was made misconstruing the f....
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....sment increasing the tax liability is liable to be dropped instantaneously for being no mistake contained in the record. Thanking you, Yours faithfully, For Balageria Central Co-Operative Bank Ltd. Assistant General Manager Authorized Signatory Ench: As above. INDIAN INCOME TAX RETURN ACKNOWLEDGEMENT [Where the data of the Return of Income In Form ITR-1 (SAHAJ), ITR-2, ITR-3, calle with digital slanaturel ITR-4, ITR-5, ITR-6,ITR-7 transmitted electronically with digital signature] Assessment Year 2018-19 Name PAN BALAGERIA CENTRAL. CO OPERATIVE BANK LIMITED AAALBO087A PERSONAL INFORMATION AND THE Fat/Door/Bluck No Name Of Premises/Buliding/Village Form No. watch has been 7 [TR-S DATE OF ELECTRONIC transmitter Road/Street/Post Office AT-SARASWATITALA Area/Locality DIST- PURBA MEDINIPUR TRANSMI Status Local Authority Tuwn/City/District Siete Pin/ZipCode |Aadhaar Number/Enrollment ID CONTAI WEST BENGAL 21401 Designation of AO(Ward/Circle) |CIRCLE 27, HALDLA Original or Revised ORIGINAL Date(DD/MM/YYYY) 25-09-2018 E-filing Acknowledgement Number 305634071250918 Gross total income 2 Deduct....