2026 (4) TMI 191

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....Act') for the Assessment Year (AY) 2018-19. 2. The assessee, in this appeal, is aggrieved by the action of the Ld. CIT(A) in dismissing the appeal of the assessee field against the order of the Assessing Officer (AO) passed u/s. 154 of the Act rejecting the application of the assessee for rectification of mistake. 3. The brief facts of the case are that the assessee filed its return of income declaring total income from capital gain and from other sources. However, at the time of processing of the return u/s. 143(1) of the Act, the CPC issued a defect notice stating that though the assessee had shown receipts from 'business or profession' of rupees more than 1 crore, but in the subsequent columns relating to 'business or profession' n....

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....ent No.9376944. However, the AO vide his order dated 06/02/2023, rejected the application of the assessee, stating that jurisdiction to validate the return lied with the CPC. 5. Being aggrieved by the order of the AO, the assessee preferred an appeal before the Ld. CIT(A), however, the Ld. CIT(A) dismissed the appeal of the assessee stating that the Jurisdictional AO had acted correctly within the confines of his jurisdiction and that the jurisdiction vested with the CPC and not with the Jurisdictional AO. He further observed that the issue raised by the assessee required factual determination which was not within the purview of section 154 of the Act and, hence, he dismissed the appeal of the assessee. 5. Being aggrieved by the order....