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2026 (8) TMI 1654

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....ssessee has raised the following grounds of appeal: "1. The impugned order of Learned Addl/ Joint Commissioner of Income-Tax (Appeals), Panaji, Office of Commissioner of Income-Tax Appeal, is erroneous both on facts and in law applicable to the appellant's case and is therefore not tenable. 2. The Learned Addl/ Joint Commissioner of Income Tax (Appeals), Panaji, erred both in law and on facts in holding that, Section 167B of the Income-tax Act, 1961 is applicable to the appellant and thereby upholding the adjustment made by the Centralized Processing Center, wherein the returned income of Rs. 2,47,640/- was taxed at the Maximum Marginal Rate in place of normal rates, resulting in a demand of Rs. 1,08,210/-. 2A....

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....e pleased to allow the appeal with consequential relief in favour of the Appellant, or grant any other relief that the Hon'ble Tribunal may deem fit in the facts and circumstances of the case." 3. Brief facts of the case are that, assessee is a Society Registered under Andhra Pradesh Societies Registration Act, 2001 and has filed its return of income on 31.07.2024, for the A.Y. 2024-25, declaring a total income of Rs. 2,47,640/-. The Centralized Processing Center / Ld.AO, processed the return of income and made an adjustment, by levy of tax by applying maximum marginal rates along with surcharge and cess amounting to Rs. 96,580/- and interest at Rs. 11,628/-, respectively, and raised demand of Rs. 1,08,210/-. 4. Being aggrieved by....