2025 (4) TMI 1996

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....er referred to as 'the Act'] whereby the Ld. CIT(A) had partly allowed the appeal against the Assessment Order, dated 25/09/2021, passed under Section 143(3) read with Section 144B of the Act for the Assessment Year 2019-2020. 2. The Assessee has raised following grounds of appeal : "1. The learned Faceless Appeal Commissioner of Income Tax, National Faceless Appeal Centre (NFAC), Delhi (Commissioner of Appeals) has erred in confirming the addition amounting to 38,40,000/- under the head income from salary. Your appellant submits that under the facts and circumstances of the appellant's case the above addition is erroneous, bad-inlaw and illegal, the same ought to be deleted. 2. The learned Commissioner of Appe....

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..... 6,75,590/- which was selected for regular scrutiny. During the assessment proceeding the Assessing Officer noted that the Assessee was a working partner in M/s. Artha Signularity Venture Partners LLP, a limited liability partnership [hereinafter referred to as 'the Firm'] and had received remuneration of INR. 39,90,000/-. As per Form 26AS, the Firm had deducted tax at source under Section 192A of the Act in respect of aforesaid remuneration whereas in the return of income the Assessee had not disclosed any salary income. Accordingly, the Assessee was asked to explain the aforesaid discrepancy. In response, the Assessee filed reply, letter dated 28/08/2021, wherein it was contended that the Assessee was a partner in the Firm and was entitl....

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....ds of the Assessee as salary income. 6. During the proceedings before the Tribunal, the Learned Authorized Representative for the Assessee relied upon the copy of submission made before CIT(A) and placed on record return of income tax return for the Assessment Year 2019-2020 filed by the Assessee and the Firm. Per contra the Learned Departmental Representative relied upon the order passed by the Assessing Officer and CIT(A). 7. On perusal of the material on record, we find that for the Assessment Year 2019-2020, the Firm had claimed deduction only to the extent of INR. 1,50,000/- paid as remuneration to the working partners. Therefore, the averment made on behalf of the Assessee that no deduction has been allowed to the Firm for INR. ....