2026 (5) TMI 1323

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.... u/s. 147 r.w.s. 144B of the Income Tax Act. 2. There was a delay of 16 days in filing of this appeal. The assessee has filed a condonation application along with an affidavit with a request to condone the delay. It has been explained that the assessee was not aware of the order of the Ld. CIT(A), which was communicated late due to negligence of the consultant. As a result, there was a delay in filing of the appeal, which was due to default of the counsel. Considering the explanation of the assessee, the delay in filing the appeal is condoned. 3. The brief facts of the case are that the assessee did not file its return of income for A.Y. 2018-19. The AO has received an information on Insight Portal of the Department that the assessee ....

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....rst appellate authority, which was decided by the learned CIT(A) vide the impugned order and the appeal of the assessee was dismissed. 5. Now the assessee is in second appeal before us. The following grounds have been taken in this appeal: 1. The Ld. CIT(A) has erred in law as well as on fact by upholding disallowance of deduction u/s. 80P of the Act amounting to Rs. 11,03,280/- made by the Ld. AO. 2 The Ld. CIT(A) has erred in law as well as on fact by upholding an action of Ld. AO where re-opening was made due to cash deposit and addition was made in the assessment and CIT(A) order by disallowing deduction claimed u/s. 80P. No addition can be made other than for reasons recorded while issuing notice u/s. 148A and when....