PARTHA SARATHY JUPUDY,RAJAHMUNDRY vs. ITO, WARD-1, RAJAHMUNDRY

ITA 225/VIZ/2026Status: DisposedITAT Visakhapatnam15 July 2026AY 2022-235 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the AO/CPC was not justified in altering the assessee's lawful computation of set-off under section 143(1) as it was beyond the scope of prima facie adjustments. The rejection of the rectification application was also unsustainable.

What were the facts?

The assessee claimed set-off of current year's business loss against income from other heads in his return. The AO/CPC altered this set-off during processing under section 143(1), increasing taxable income. A rectification application under section 154 was rejected, and this was upheld by the CIT(A).

What were the issues?

Whether the AO/CPC could alter the inter-head set-off of business loss during section 143(1) processing, and whether the denial of rectification was justified.

Which sections of the Income-tax Act were involved?

Section 71,Section 154,Section 143(1)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, VISAKHAPATNAM BENCH,

Before: SHRI RAVISH SOOD, HON’BLE & SHRI OMKARESHWAR CHIDARA, HON’BLE

For Respondent: Shri A.P. Babu, Sr-AR

PER RAVISH SOOD, JM:

The present appeal filed by the assessee is directed against the order of the Commissioner of Income Tax (Appeals), National Faceless Appeal Center, Delhi [for short, "the CIT(A)"], dated 23.01.2026, which in turn arises from the order

ITA 225/VIZ/2026 passed under section 154 of the Income Tax Act, 1961 (for short, “Act”) dated 05.07.2024 fo

The order continues below.

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