2026 (6) TMI 869

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....5 and has furnished its return of income u/s 139(4) of the IT Act by declaring income of Rs. Nil after claiming deduction of Rs. 56,32,62,698/- u/s 57 of the IT Act. The case was selected for scrutiny and notices u/s 143(2), 142(1) and show cause notices respectively were issued to the assessee. Not being satisfied with the reply of the assessee, the Assessing Officer vide order dated 21.03.2024 completed the assessment proceedings u/s 143(3) r.w.s. 144B of the IT Act by determining the income of Rs. 56,32,62,698/- as against income of Rs. Nil returned by the assessee. The above assessed income includes addition of Rs. 56,32,62,698/- on account of disallowance of expenses claimed u/s 57 of the IT Act. 3. Being aggrieved with the above as....

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....2023-24 were filed before Ld. CIT(A)/NFAC and the appeal for assessment year 2022-23 was decided by Ld. CIT(A)/NFAC and the appeal for assessment year 2023-24 is still pending before Ld. CIT(A)/NFAC as informed by the assessee. We further find that the assessee explained before the Assessing Officer that due to mistake while filing the return of income instead of claiming exemption u/s 10(20) of the IT Act, deduction u/s 57 of the IT Act was claimed, however, a revised computation of income was furnished before the Assessing Officer wherein exemption u/s 10(20) of the IT Act was mentioned. In this regard, we find that both the lower authorities were of the opinion that any claim can be made through revised return only and therefore, the ben....