2026 (5) TMI 835

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....e Respondent : Shri Ajay Kumar Arora, Sr. DR ORDER PER AMITABH SHUKLA, AM, This appeal filed by the assessee is against order dated 31.10.2025 of the Learned ADDL/JCIT (A)-2, Pune [hereinafter referred to as 'ld. CIT(A)] arising out of assessment order dated 31.07.2024 passed u/s. 154 of the Income Tax Act, 1961 pertaining to Assessment Year 2021-22. The word 'Act' herein this order would....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....gned Order has been passed without following the laid down procedure as per Provisions of Income Tax Act, and CBDT Circular/Notification/Instruction, therefore the impugned Assessment Order is unsustainable in law and liable to be quashed 4. That the Ld. CIT(A) has also erred in law and on facts making addition of Rs. 97,66,255 thereby indirectly disallowing the genuine and actual expense....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....refore liable to be deleted. 8. That any other relief or reliefs as your honour may deem fit in the facts and circumstances of the case, be granted. Your humble appellant craves leave to add, amend or withdraw of any Grounds of Appeal on/or before hearing of appeal. 3. The only issue seminal to the present appeal is regarding the denial of appellant's claim of exemption by the CPC on a....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....l submitted that the delayed filing of Return of Income was attributable to prevailing Covid pandemic. 4. Per Contra, the ld. DR relied upon the order of the lower authorities. 5. We have heard the rival submission and perused the material available on record. There is no dispute regarding the delayed filing of return and the condonation of delay in Form 10B granted to the assessee. It is no....