9911796707
TMI Blog2025 (4) TMI 875X X X X Extracts X X X X X X X X Extracts X X X X ..... ferred to as the "Act"), dated 24.02.2023, for Assessment Year 2021-22. 2. Grounds taken by the Assessee are reproduced as under: 1) 1.1) The Learned Commissioner of Income Tax (Appeals) has erred in confirming the order u/sec 154 of the Act passed by the learned The Learned Deputy Director of Income Tax CPC, Bangalore, who has erred in not rectifying the intimation u/sec 143(1) of the Act, wherein, while processing the return of income, an addition of Rs. 52,16,56,993/-has been made being "written off bad debts recovered", by not considering the fact that the said amount of Rs. 52,16,56,993/- has already been credited to the Profit and Loss Account of the appellant for FY 2020-21, and was included in the net profit before tax for FY 202 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ed on 06 July, 2023, was brought to the notice of The Learned Commissioner of Income Tax (Appeals), in the written submissions filed in the appellate proceedings. 2) Without having any prejudice of whatsoever nature to the Ground No.1, The Learned Commissioner of Income Tax (Appeals) has erred in confirming the order u/sec 154 of the Act, passed by the Learned Deputy Director of Income Tax CPC, Bangalore, who having made an addition of Rs. 52,16,56,993/- to the returned income, has further erred in not re computing and revising the deduction claimed U/s.36(1)(viia) of the Act, by not considering the fact that the deduction u/s 36(1) (viia) of the Act, is calculated on the basis of Income computed under the head Profits & Gains of Business ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... From the perusal of the order passed u/s.154, it is noted that the grievance of the assessee, by way of the present appeal before the Tribunal has been addressed. Fact of this was brought to the knowledge of ld. CIT(A), however, the appeal was dismissed. 3.1. Since ld. CIT(A) did not take cognisance of the order u/s 154 rectifying the mistake, under the compelling reasons, assessee had to come up in appeal before the Tribunal to get the first appellate order set aside so as to avoid conflict on passing of effect giving order. 4. We find that the issue raised by the assessee, in the present appeal has been addressed by rectification order passed u/s.154, dated 06.07.2023. In order to avoid any conflict which may arise on account passing of ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
