BASHIR JAFAR BHALDAR,SONAI SERVICES 1 SONAI SERVICES, BARAMATI ROAD IND vs. ASSESSING OFFICER WARD 14(5) PUNE, AAYAKAR SADAN BODHI TOWER SALASBURY PARK GULTEKDI

ITA 2919/PUN/2025Status: DisposedITAT Pune30 January 2026AY 2023-247 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal observed that the Assessing Officer failed to specifically verify the claim in light of the provisions of Section 80JJAA and the previous year's allowance by CIT(A). Therefore, the issue was remitted back to the Jurisdictional Assessing Officer for specific verification of the deduction claim as per Section 80JJAA provisions and the CIT(A)'s finding for AY 2022-23, to allow the claim if found correct.

What were the facts?

The assessee, an individual running a proprietary concern (M/s. Sonai Services), claimed a deduction of ₹14,58,544 under Section 80JJAA for Assessment Year 2023-24, which was the third installment of the claim initiated in AY 2021-22 and allowed in AY 2022-23. The Assessing Officer denied the current claim, citing no increase in employee numbers, and the CIT(A) upheld the disallowance without addressing the merits, merely noting the case was selected for scrutiny.

What were the issues?

Whether the assessee is eligible for the third installment of deduction under Section 80JJAA of the Income Tax Act, 1961, for Assessment Year 2023-24.

Which sections of the Income-tax Act were involved?

Section 250,Section 143(3),Section 144B,Section 80JJAA,Section 44AB,Section 33B,Section 288

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, PUNE BENCHES “SMC”, PUNE

Before: DR.MANISH BORAD

For Appellant: Shri Rajkumar Doshi, Shri Shashank Ojha (virtual)
Hearing: 14.01.2026Pronounced: 30.01.2026

The captioned appeal at the instance of assessee pertaining to the Assessment Year 2023-24 is directed against the order dated 24.11.2025 of National Faceless Appeal Centre, Delhi (NFAC) passed u/s.250 of the Income- tax Act, 1961 (hereinafter also called ‘the Act’) arising out of Assessment Order dated 17.03.2025 passed u/s.143(3) r.w.s.144B of the Act.

2.

The only grievance of the assessee is that ld.CIT(A) erred in disallowing the clam of deduction u/s.80JJA of the Act.

3.

At the outset, ld. Counsel for the assessee submitted that assessee made the claim u/s.80JJA firstly for A.Y. 2021- 22 and as per the provisions of section u/s.80JJA of the Act such claim can be made for three

The order continues below.

Read the full judgment

A free account opens 10 full judgments a month. Re-reading one you have already opened does not count again.

Create a free accountSign in

See plans and prices

The summary, the parties, the sections and the citations above are open to everyone and always will be. Only the text of the order and the PDF are metered.

More judgments on Section 144B

All 10,521 judgments and leading authorities on Section 144B →

Recent GST High Court judgments

Search GST case law →