2026 (5) TMI 1752

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....enue Represented : Shri Ajay Uke, Sr. D.R. ORDER PER : T.R. SENTHIL KUMAR, JUDICIAL MEMBER:- This appeal is filed by the Assessee as against the appellate order dated 19.11.2025 passed by the Additional Commissioner of Income Tax/JCIT (Appeals)-4 Delhi arising out of the rectification order passed u/s. 154 of the Income Tax Income Tax Act, 1961 (hereinafter referred to as 'the Act') relat....

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....out the tax under normal rate at 30% instead of 22% as opted by the assessee u/s. 115BAA of the Act. 4. Aggrieved against the intimation, the assessee filed a rectification petition u/s. 154 of the Act as follows: "Reference Year: Deal Hop (P) Ltd. Year: Α. Υ. 2020-21 Subject: Rectification u/s. 154 of the Act. DIN: CPC/2021/A6/183994787 on 18/1....

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.... against the same, the assessee filed appeal before Addl./JCIT-4 Delhi, who has also dismissed the appeal that there is no apparent mistake available on record. 7. Aggrieved against the same, the assessee is in appeal before us raising the following Grounds of Appeal: 1) The learned CIT(A) grossly erred in confirming the appeal against order of rejecting rectification application filed....

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....our considered view, there is no mistake apparent on record in the intimation passed u/s. 143(1) of the Act, since the assessee not filed Form 10IC alongwith the Return of Income. Therefore the lower authorities are correct in dismissing the rectification application. However the assessee claims that before making the adjustments under 143(1) of the Act, the assessee was not given opportunity of h....