FIS GLOBAL BUSINESS SOLUTIONS INDIA PRIVATE LIMITED,DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, DELHI

ITA 3595/DEL/2025Status: DisposedITAT Delhi28 January 2026AY 2018-19Bench: Sh. Satbeer Singh Godara, Judicial Member & Sh. Manish Agarwal (Accountant Member)1 pages
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What did the Tribunal hold?

The Tribunal held that the assessee had initially filed the original return claiming part relief and that a revised claim would not attract Section 80A(5) if the original return was filed within the due date. The Tribunal accepted the assessee's ground in principle, considering the insertion of a new proviso to Section 80JJA.

What were the facts?

The assessee filed an appeal against the order denying deduction under Section 80JJAA for AY 2018-19. The assessee had initially claimed a deduction of Rs. 58,12,704 in the original ITR but later filed a revised claim for Rs. 3,07,55,995, supported by a revised Form 10DA.

What were the issues?

Whether a revised claim for deduction under Section 80JJAA is admissible if the original return was filed within the due date, even if a part of the deduction was claimed in the original return?

Which sections of the Income-tax Act were involved?

Section 80JJAA,Section 80A(5),Section 80AC,Section 139(1)

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Cases cited in this judgment(6)Show list

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Income Tax Appellate Tribunal, DELHI BENCH ‘E’, NEW DELHI

Before: Sh. Satbeer Singh Godara & Sh. Manish Agarwal

For Appellant: Ms. Sumish Murgai, CA, Adv. &, Ms. Kashish Gupta, CA
Hearing: 28.01.2026Pronounced: 28.01.2026

Per Satbeer Singh Godara, Judicial Member:

This assessee’s appeal for Assessment Year 2018-19 arises against the CIT(A)/NFAC, Delhi’s DIN & order No. ITBA/NFAC/S/250/2024–25/1074701797(1) dated 19.03.2025, in proceedings u/s 14(3) of the Income Tax Act, 1961 (in short “the Act”).

2.

Heard both the parties at length. Case file perused.

3.

We notice at the outset that the assessee/appellant is aggrieved against both the learned lower authorities’ action denying section 80JJA deduction herein in assessment order FIS Global Business Solutions India Pvt. Ltd. FIS Global Business Solutions India Pvt. Ltd. dated 08.04.

The order continues below.

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