2025 (11) TMI 1408

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.... to condone the delay is filed by the assessee, in which it is stated that assessee was filed the appeal inadvertently before the Hon'ble ITAT Pune Bench, instead of the appropriate jurisdictional bench in Delhi. The appeal filed by the assessee before the Hon'ble ITAT bench was withdrawn and later on filed before this Bench. The assessee has shown the sufficient the cause not to file the appeal with in time. Therefore, we condoned the delay in filing the appeal and admit for adjudication. 3. The assessee has raised the following ground in appeal:- 1.1 That on the facts and circumstances of the case, the CIT(A) was not justified in upholding the Rectification Order passed by the CPC, Bangalore u/s 154 of the Income Tax Act, 1961....

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...."the Act") accepting the declared income. Thereafter Suo-moto a rectification order under section 154 of the Act was issued, raising a demand of Rs. 24,34,590/-. Aggrieved the rectification order the assessee filed an appeal, before the Ld.CIT(A), which was dismissed vide order dated 30-06-2024 upholding the action of the CPC. Being aggrieved the order of the Ld. CIT(A), the assessee is in appeal before the tribunal. Ld. CIT(A) has observed in his order,: "7. In its reply the appellant has submitted that it had filed form no. 10 B within the due date. On verification it is seen that the extended due date for filing of return was 15.03.2022 and the appellant has filed its ITR on 05.03.2022 and the audit report in form no. 10 B has b....

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....was wrongly applied because the said provisions are not relevant to the year under consideration. It was also submitted that the provision of the section 12AB was inserted by the amendment with effect from the 01-04-2021. The assessee was filed the return for the A.Y. 2021-22 and has a valid registration. The assessee filed the paper book containing paper no 1 to 25, in which paper no.1is a filed the registration certificate, to prove that trust having a registration certificate for the A,Y,2021-22. 6. Ld. DR has relied the order of the lower authority. We have heard the parties and gone through the material available on record. The appeal of the assessee was dismissed on the ground that the application for registration under new provisi....