SARITHA MANDANA,KOLKATA vs. ITO, WARD 33(2),, KOLKATA

IN THE INCOMETAXAPPELLATE TRIBUNAL “D” BENCH, KOLKATA Before Shri Rajesh Kumar, Accountant Member and Shri Pradip Kumar Choubey, Judicial Member ITA No.646/Kol/2026 Assessment Year: 2024-25 Saritha Mandana……………………………….………………………….Appellant 10B, O.C. Ganguly Sarani, Bhawanipur, Kolkata- 700020 [PAN No. AEAPM8464Q] Vs. ITO, Ward 33(2)……………………..…………….………... Respondent, Income Tax Office, 10B, Sir William Jones Sarani, Middleton Row, Park Street area, Kolkata- 700068 Appearances by: Shri Miraj D. Shah, Advocate, appeared on behalf of the Appellant. Shri, S.B. Chakraborthy, Addl. CIT, Sr. DR ,appeared on behalf of the Respondent. Date of concluding the hearing : May 20, 2026 Date of pronouncing theorder : June 08 ,2026 ORDER Per Pradip Kumar Choubey, Judicial Member: This appeal filed by the assessee is directed against the order dated 13.09.2025 of the National Faceless Appeal Centre (NFAC) passed under Section 154 of the Assessment Year 2024-25 of the Income-tax Act, 1961 (hereinafter referred to as “the Act”).

At the very outset it appears from the report of registry that appeal is time barred of 77 days. Assessee has filed petition to condone the delay. Going over the contents of the petition, we find the reason as explained is Bonafide, accordingly we condoned the delay.

ITA No.646/Kol/2026 Assessment Year- 2024-25 2. The brief facts of the case of the assessee are that the assessee Mrs. Saritha Mandana, filed her Income Tax Return (ITR) for the Assessment Year (AY) 2024-25 on 04/07/2024, well within the due date of 31/07/2024.In her return of income, the appellant had reported total income of Rs.2.32,50,660 after claiming deductions under Chapter VI-A of the Income Tax Act 1961 amounting to Rs.4.97,600/-. The Return was processed u/s 143(1) of the Income Tax Act, 1961, on 23/08/2024 with no demand. However, In the said intimation the deduction claimed under Chapter VI-A was completely disallowed, with the amount shown as Rs. 0 (Zero) in the compilation. The disallowance of the deduction claimed under Chapter VI-A resulted in an incorrect computation of taxable income at Ra. 2,32,50,660 instead of Rs 2.27,53,060 (after reducing the Chapter VI-A deduction of Rs. 4,97,600). Due to the said disallowance, the tax computation was erroneously higher resulting in the appellant's tax liability being incorrectly calculated. Subsequently, the appellant filed a rectification application u/s 154 on 21/02/2025 as the same appears to be a mistake apparent from records, requesting the income Tax Department to rectify this apparent mistake. However, the rectification order w/s 154 dated 21/02/2025 maintained the same error, continued to show deduction under Chapter VIA las RaO (Zero), and confirmed a tax demand of Rs.1, 40.230 Aggrieved by the said order assessee preferred appeal wherein appeal of the assessee has been dismissed as there was no response on behalf of the assessee. Being aggrieved by and dissatisfied the assessee preferred appeal before us. 3. The Ld. AR challenges the very impugned order thereby submitting that Ld. CIT(A) erred an upholding the rectification order

ITA No.646/Kol/2026 Assessment Year- 2024-25 passed u/s 154 of the Act without examining whether non-allowance of deduction under chapter VI A amounting to Rs. 4,97,000/- constitute a mistake apparent from the record. The Ld. AR submits that the deduction under chapter VI-A was rightfully claimed by the assessee and the denial of such deduction in processing u/s 143(1) and a failure to rectify the same u/s 154 is contrary to law and facts. The Ld. AR further submits that non-grant of deduction constitutes a patent computational error rectifiable u/s 154 of the Act when indeed, rectification application specifically pointed out the computational discrepancy. Hence the prayer of the AR is that rectification order passed u/s 154 be quashed and direction to be given to the AO to re compute the same after granting the legitimate deduction to pass a fresh order. 4. Contrary to that Ld. DR supports the impugned order. 5. Upon hearing the submission of the counsel of the respective parties and on perusal of the impugned order, we find that the assesseein her return of income reported a total income of Rs. 2,32,50,66/- as after claiming deduction under chapter VI-A of the Act amounting to Rs. 4,97,600/- The return was processed however in the said intimation the deduction claimed under chapter VI-A of the completely disallowed with the amount shown as Rs. 0(Zero) as in the computation the disallowance of the deduction claimed under chapter VI-A resulted in an incorrect computation of the textile income at Rs. 2,32,50,660/- instead of Rs. 2,27,53,060. The assessee filed a rectification application u/s 154 as the same appears to be mistake apparent from the records and requested the department to rectify this apparent mistake. The Assessing Officers dismissed the application filed u/s 154, the assessee filed appeal before the CIT(A) wherein appeal of the assessee has been dismissed for non-prosecution. No order has been passed by the CIT(A) on merit. The prayer of the AR is 3

ITA No.646/Kol/2026 Assessment Year- 2024-25 that appeal with the assessee be remitted back to the file of the AO with a direction to re-computed after granting the legitimate deduction. Keeping in view the facts of the case as well as considering the argument of the AR we are remitting the appeal of the assessee to the file of the AO with a direction to re-compute and pass a fresh order after hearing the assessee and grant legitimate deduction. The order passed by the lower authorities are hereby set aside. Appeal is remitted back to the file of AO for re-computation.

As a result, the appeal has been allowed for statistical purpose.

Kolkata, the 8th June, 2026.

[Rajesh Kumar] [Pradip Kumar Choubey] Accountant Member Judicial Member Dated:. 08.06.2026. DC, PS

Copy of the order forwarded to: 1. Appellant - 2. Respondent - 3. CIT(A)- 4. CIT- 5. CIT(DR)

//True copy// By order Assistant Registrar, Kolkata Benches

ITA No.646/Kol/2026 Assessment Year- 2024-25