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2022 (1) TMI 985

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..... lower authorities has not allowed deduction u/s. 80P which was allowable on the aforesaid income. Evening during the course of appellate proceedings before us, the assessee has not filed any supporting relevant material to demonstrate that how the assessee is entitled for deduction u/s. 80P on the aforesaid specific nature of income. Therefore, we do not find any infirmity in the decision of ld. CIT(A) and this ground of appeal of the assessee stands dismissed. - ITA No. 181/Rjt/2018 - - - Dated:- 18-11-2021 - Shri Mahavir Prasad, Judicial Member And Shri Amarjit Singh, Accountant Member For the Revenue : Shri S.S. Rathi, Sr. D.R. For the Assessee : Withdrawal Application ORDER PER : AMARJIT SINGH, ACCOUNTANT MEMBE .....

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..... tion / disallowance of ₹ 1,93,922/- based on presumption and cermices. The addition 7 disallowance needs deletion. 5. Taking into consideration the legal, statutory, factual and administrative aspects, no addition 7 disallowance of an amount of ₹ 1,93,922/- ought to have been made. The addition / disallowances need deletion. 6. Without prejudice, the assessment made is bad in law and deserves annulment. 7. Without prejudice, no adequate, sufficient and reasonable opportunity has been provided at the time of assessment order. The assessment needs annulment. 8. Without prejudice, no adequate, sufficient and reasonable opportunity has been provided at the time of appellate stage. The assessment needs annulment. .....

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..... ome as reported above. Therefore, the ld. CIT(A) has dismissed the appeal of the assessee. 6. During the course of appellate proceedings before us, the ld. counsel has not attended but has filed the written submission reiterating the facts which was submitted before the lower authorities that the aforesaid income was pertained to agricultural product of the society and income from sale promotion and godown rent. On the other hand, the ld. Departmental Representative has submitted that assessee has not never furnished the supporting detail and documents before the Assessing Officer and CIT(A) in its support of claim of deduction u/s. 80P. Even in its written submission there is no supporting material which could justify the claim of deduc .....

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