JAIN PRAVIN HIRALAL HUF,PUNE vs. ITO WARD 6(1), PUNE

ITA 1072/PUN/2025Status: DisposedITAT Pune22 September 2026AY 2020-219 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal found that the CIT(A) had erred in dismissing certain grounds and not following judicial precedents. The Tribunal set aside the CIT(A)'s order and restored the matter to the AO for re-computation, considering the assessee's submissions, legal provisions, and judicial precedents.

What were the facts?

The assessee HUF filed its return of income, which was processed under section 143(1) by the CPC. The CPC made adjustments regarding the set-off of business loss against capital gains and interest income, differing from the assessee's computation. The assessee appealed to the CIT(A).

What were the issues?

Whether the adjustments made by the CPC under section 143(1) regarding the set-off of business loss were justified and whether the CIT(A) correctly adjudicated the grounds of appeal.

Which sections of the Income-tax Act were involved?

Section 143(1),Section 71(2),Section 74,Section 115JC

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, PUNE BENCH “A”, PUNE

Before: SHRI MANISH BORAD & SHRI VINAY BHAMORE

For Respondent: Shri Rajesh Haladkar
Hearing: 01.07.2026Pronounced: 22.09.2026

PER VINAY BHAMORE, JM: This appeal filed by the assessee is directed against the order dated 04.03.2025 passed by Ld. Addl./JCIT(A)-6, Delhi [‘Ld. CIT(A)’] for the assessment year 2020-21. 2. The appellant has raised the following grounds of appeal :- “1. Whether on facts and circumstances of the case, an adjustment made u/s 143(1) is justified in law and on facts in respect of set off of loss of Rs 9756576/- arising from business which is debatable and is a contentious issue. The adjustment being unjustified in law may kindly be cancelled.

2.

Whether on facts and circumstances of the case, an adjustment made u/s 143(1) in respect of set of loss of Rs 9756576/- arising

2 from busine

The order continues below.

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