360 ONE DISTRIBUTION SERVICES LIMITED (EARLIER KNOWN AS IIFL WEALTH CAPITAL MARKETS LTD),MUMBAI vs. DCIT, CIRCLE 1, THANE

ITA 5282/MUM/2025Status: DisposedITAT Mumbai20 February 2026AY 2018-197 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal upheld the denial of the deduction, citing Section 80A(5) of the Act, which mandates that a deduction can only be allowed if it is claimed in the original return of income. Non-compliance with this and other procedural requirements disentitled the assessee.

What were the facts?

The assessee claimed a deduction under Section 80-JJAA for additional employee costs but failed to make this claim in its original return of income or during assessment proceedings. The mandatory Form 10DA was also not filed within the prescribed due date.

What were the issues?

Whether a deduction under Section 80-JJAA can be allowed when it was not claimed in the original return of income and mandatory procedural requirements were not met.

Which sections of the Income-tax Act were involved?

Section 80JJAA,Section 80A(5),Section 250,Section 143(3)

AI-generated summary — verify with the full judgment below

Cause title — parties, addresses and appearances
ITA No.5282/MUM/2025 (Assessment Year : 2018-19) 360 One Distribution Services Limited, (earlier known as IIFL Wealth Capital Markets Limited) 360 One Centre Kamala City, Senapati Bapat Marg, Lower Parel West, Mumbai - 400013 PAN: AACCL4268L Appellant Deputy Commissioner of Income Tax, Circle-1, Asher IT Park, Wagle Estate, Thane - 400604 v/s Respondent Assessee by : Shri Pritesh Mehta Revenue by: Shri Virabhadra Mahajan, Sr. DR Date of Hearing – 10/02/2026 Date of Order - 20/02/2026

ORDER PER SANDEEP SINGH KARHAIL, J.M. The assessee has filed the present appeal against the impugned order dated 30.07.2025, passed under section 250 of the Income Tax Act, 1961 ("the Act") by the learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi [“learned CIT(A)”], for the assessment year 2018-19. 2. In this appeal, the assessee has raised the following grounds: - “1. On the facts and in the circumstances of the case, necessary direction may be given to the learned assessing officer for granting deduction of Rs.3,06,30,724 u/s. 80JJAA claimed by the appellant.

2.

On the facts and circumstances of the case as well as in law, the Learned CIT has erred in passing order

The order continues below.

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