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Facts
The assessee claimed a deduction of Rs. 25,14,054/- under Section 80JJAA for AY 2020-21. This deduction was initially disallowed by the CPC as Form 10DA was not filed with the return. The assessee filed a rectification application, which was rejected.
Held
The Tribunal noted that a subsequent order under Section 154 dated 29.04.2025 had allowed the deduction, as it pertained to earlier Assessment Years for which Form 10DA was filed. Therefore, the present appeal was rendered infructuous.
Key Issues
Whether the appeal is infructuous due to subsequent rectification order allowing the deduction for prior years and if the first appellate authority correctly appreciated the facts.
Sections Cited
154, 143(1), 80JJAA, VI-A
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Income Tax Appellate Tribunal, AHMEDABAD “A” BENCH, AHMEDABAD
Before: MS. SUCHITRA KAMBLE & SHRI NARENDRA PRASAD SINHA
O R D E R
PER SHRI NARENDRA PRASAD SINHA, AM:
This appeal is filed by the assessee against the order of the Additional/Joint Commissioner of Income Tax (A)-9, Delhi (in short “the Addl./Joint CIT(A)”) dated 27.06.2025 for the Assessment Year (A.Y.) 2020-21 in the proceeding under Section 154 of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’).
The brief facts of the case are that the assessee had filed its return of income for the A.Y. 2020-21 on 10.03.2022 declaring income of Rs.24,56,07,910/-. While processing the return under Section 143(1) of the Act, the CPC had disallowed the claim of deduction of Rs.25,14,054/- (Assessment Year: 2021-22) Mantra Softech (India) Pvt. Ltd. vs. DCIT Page 2 of 4 made under Chapter VI-A of the Act. Thereafter, the assessee had filed a rectification application u/s 154 of the Act against this adjustment, which was also rejected by the CPC vide order dated 10.01.2023.
Aggrieved with the rejection of 154 application, the assessee had filed an appeal before the first appellate authority which was decided vide the impugned order and the appeal of the assessee was dismissed.
Now the assessee in second appeal before us. The following grounds have been taken in this appeal: -
“1. The learned First Appellate Authority erred in law and on facts in confirming the rejection of the legitimate and cross verifiable deduction of Rs.25,14,054/- claimed by the Appellant under section 80JJAA of the Act. 2 The learned First Appellate Authority erred on facts in mentioning A.Y. 2020-21 as the year of appeal, whereas the appeal actually related to A.Υ. 2021-22.”
Shri B. R. Popat, Ld. AR of the assessee explained that the assessee had claimed deduction of Rs.25,14,054/- under Section 80JJAA of the Act. He explained that this deduction was in respect of generation of new employment by the assessee in the earlier two years i.e. in A.Y. 2019-20 & 2020-21. The deduction was disallowed while processing the return, for the reason that the prescribed Form 10DA was not filed with the return. The Ld. AR explained that the Form 10DA were duly filed along with the returns of income for the A.Ys. 2019-20 and 2020-21, to which the deductions pertained. As per the provisions of Section 80JJAA of the Act, the assessee was entitled to claim deduction of 30% of the additional employee cost in three years. The Ld. AR explained that the deduction (Assessment Year: 2021-22) Mantra Softech (India) Pvt. Ltd. vs. DCIT Page 3 of 4 claimed by the assessee under Section 80JJAA of the Act did not pertain to the current year but was in respect of the earlier two years. The Ld. AR submitted that when this fact was explained, the CPC had passed another order under Section 154 of the Act dated 29.04.2025 and the deduction of Rs.25,14,054/- claimed under Section 80JJAA of the Act was allowed. The Ld. AR, however, submitted that this fact was not appreciated by the Ld. Addl. CIT(A) in right perspective and the appeal filed against the earlier order under Section 154 of the Act dated 10.01.2023 was dismissed.
Per contra, Shri Saresh Kartik Laxmanbhai, Ld. Sr. DR submitted that since the grievance of the assessee was redressed by the subsequent order under Section 154 of the Act dated 29.04.2025 passed by the CPC, the present appeal becomes infructuous.
We have considered the rival submissions. So far as the deduction under Section 80JJAA of the Act is concerned, the same has been redressed by the order under Section 154 of the Act dated 29.04.2025 passed by the CPC. As explained, the deduction of Rs.25,14,054/- claimed under Section 80JJAA of the Act was pertaining to earlier two years i.e. A.Y. 2019-20 & A.Y. 2020-21. As no fresh deduction under Section 80JJAA of the Act pertaining to A.Y. 2021-22 was claimed in the return, there was no requirement for the assessee to file Form 10DA for this year. As the deductions pertained to A.Y. 2019-20 & A.Y. 2020-21, the Form 10DA were already filed with the returns for the earlier two years. Since the grievance of the assessee has already been redressed by the CPC and the deduction of Rs.25,14,054/- claimed under Section 80JJA of (Assessment Year: 2021-22) Mantra Softech (India) Pvt. Ltd. vs. DCIT Page 4 of 4 the Act has been allowed vide order under Section 154 dated 29.04.2025, the present appeal has become infructuous.
In view of the facts as discussed above, the appeal filed by the assessee is treated as allowed for statistical purpose. It is made clear that no further deduction is required to be allowed to the assessee in pursuance to this order.
In the result, the appeal of the assessee is allowed for statistical purpose. Order pronounced in the open Court on this 18th November, 2025.