2025 (11) TMI 1611

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....for the Assessment Year (A.Y.) 2018-19 in the proceeding under Section 143(1) of the Income Tax Act, 1961 (hereinafter referred to as 'the Act'). 2. The brief facts of the case are that the assessee had filed its return of income for the A.Y. 2018-19 on 31.03.2019. The return was processed under Section 143(1) of the Act on 31.01.2020 by the CPC and while processing the return an adjustment of Rs. 44,00,000/- was made by the CPC. 3. Aggrieved with the adjustment made u/s 143(1) of the Act, the assessee had filed an appeal before the First Appellate Authority which was decided by the Ld. Addl./JCIT(A) vide the impugned order and the appeal of the assessee was dismissed. 4. Now the assessee in second appeal before us. The following g....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....ained that in the intimation under Section 143(1) of the Act issued by the CPC, there was an arithmetical error which had resulted in addition of Rs. 44,00,000/-. He submitted that the Ld. Addl./JCIT(A) had dismissed the appeal of the assessee without allowing any opportunity to the assessee and without correctly appreciating the facts of the case. The Ld. AR has taken us through the copy of the return as well as the intimation which were brought on record in the paper-book filed by the assessee and explained that all the deductions claimed by the assessee in the return of income were duly allowed by the CPC while processing the return and a totalling mistake was apparent in the working of CPC. He further submitted that the adjustment as ma....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....R - REVENUE ACCOUNT (24 OF SCHEDULE ER) 6,56,31,990 6,56,31,990   (II) AMOUNT APPLIED DURING THE PREVIOUS YEAR - CAPITAL ACCOUNT [EXCLUDING APPLICATION FROM BORROWED FUNDS] (8A OF SCHEDULE EC) 8,75,000 8,75,000   (III) AMOUNT APPLIED DURING THE PREVIOUS YEAR - CAPITAL ACCOUNT (REPAYMENT OF LOAN) 0 0   (IV) AMOUNT APPLIED DURING THE PREVIOUS YEAR - UTILISATION OF DEEMED INCOME OF AN EARLIER YEAR [ITEM NO.24(B) OF SCHEDULE ER + ITEM No.8(B) OF SCHEDULE EC] 0 0   (V) AMOUNT DEEMED DURING THE PREVIOUS YEAR AS PER CLAUSE (2) OF EXPLANATION TO SECTION 11(1) 18,50,000 18,50,000   (a) IF (IV) ABOVE APPLICABLE, WHETHER OPTION FORM NO.9A HAS BEEN FURNISHED TO THE ASS....