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2021 (10) TMI 551 - AT - Income TaxExemption u/s 54 - Claim of the assessee denied as assessee failure not to adhere to mandatory requirment to file the return of income for the year under consideration - Assessee's contention is this that the amendment of this proviso of Section 139(1) is applicable w.e.f. assessment 2020-21 which is not applied in the case of the applicant - HELD THAT:- We find merit and substance in the case made out by the assessee. It appears that the 6th Proviso of Section 139(1) after amendment is applicable for A.Y. 2020-21. The assessee's case is not coming unde the purview of such proviso. Hence, we hold that the assessee is entitled to such claim under Section 54 of the Act. We, therefore, allow the appeal by directing the Ld. AO to pass orders in accordance with law. - Decided in favour of assessee.
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