MANTRA SOFTECH (INDIA) PRIVATE LIMITED,AHMEDABAD vs. THE DY. CIT, CIRCLE-2(1)(1), AHMEDABAD

ITA 1614/AHD/2025Status: DisposedITAT Ahmedabad18 November 2025AY 2021-22Bench: MS. SUCHITRA KAMBLE (Judicial Member), SHRI NARENDRA PRASAD SINHA (Accountant Member)1 pages
AI SummaryAllowed

What did the Tribunal hold?

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.

What were the 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.

What were the 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.

Which sections of the Income-tax Act were involved?

Section 154,Section 143(1),Section 80JJAA

AI-generated summary — verify with the full judgment below

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

Before: MS. SUCHITRA KAMBLE & SHRI NARENDRA PRASAD SINHA

For Appellant: Shri B.R. Popat
For Respondent: Shri Saresh Kartik Laxmanbhai, Sr. DR
Hearing: 03.11.2025Pronounced: 18.11.2025

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’).

2.

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

The order continues below.

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