2025 (11) TMI 1174

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.....    P.C.:- 1. Heard Mr. Gupta, learned counsel for the Appellant and with his assistance, we have perused the record. 2. Mr. Gupta urges that the Appeal be admitted on the questions of law set out in paragraph 4 of the Appeal Memo. These, according to Mr Gupta, pose substantial questions of law. 3. The tax effect in the appeal memo, as set out in paragraph 12, is Rs. 1,67,72....

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....s issued to the Respondent. 5. During the reassessment proceedings under Section 148 of the IT Act, the AO vide order dated 30 March 2015 rejected the entire deduction of Rs. 7,39,07,383/- claimed by the Respondent under Section 10B of the IT Act, for want of approval by the Development Commissioner. The AO also rejected the alternative claim made by the Respondent under Section 10A of the IT A....

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....hat such a mistake was rectifiable and ought to have been accordingly rectified, which the ITAT ought to have considered and appreciated. 8. Mr Gupta, in making the above submissions, has fairly accepted that there was no rectification proceeding in terms of the above initiated on behalf of the Appellant as prescribed under Section 154 of the IT Act. Considering such a position, we find that th....