DADA MOTOR ENTERPRISES LLP,LUDHIANA vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1, LUDHIANA

ITA 25/CHANDI/2025Status: DisposedITAT Chandigarh10 March 2026AY 2023-24Bench: SHRI RAJPAL YADAV (Vice President), SHRI KRINWANT SAHAY (Accountant Member)4 pages
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What did the Tribunal hold?

The Tribunal held that while processing returns under section 143(1), the AO's scope is limited to verifying completeness of details, not examining other conditions, which would necessitate a scrutiny assessment. The Tribunal vacated the CIT(A)'s direction to satisfy other conditions, asserting that the assessee is entitled to the deduction under section 80JJAA(2) and the original disallowance by the AO is deleted.

What were the facts?

The assessee claimed a deduction under section 80JJAA, which the Assessing Officer disallowed because Form 10DDA was uploaded after the return filing due date but before processing. The CIT(A) allowed the deduction, concluding that delayed submission cannot deny it, but controversially directed the AO to verify other conditions under section 80JJAA(2). The assessee's appeal before the Tribunal challenges this specific direction of the CIT(A).

What were the issues?

Whether a deduction under section 80JJAA can be denied solely due to delayed submission of Form 10DDA if uploaded before processing, and whether the CIT(A) can direct the AO to verify other conditions after allowing the deduction.

Which sections of the Income-tax Act were involved?

Section 80JJAA,Section 80JJAA(2),Section 143(1)

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Income Tax Appellate Tribunal, DIVISION BENCH, ‘A’ CHANDIGARH

Before: SHRI RAJPAL YADAV & SHRI KRINWANT SAHAY

For Appellant: Shri Parikshit Aggarwal, CA
For Respondent: Shri Vivek Vardhan, Addl.CIT, Sr.DR
Hearing: 24.02.2026Pronounced: 10.03.2026

PER RAJPAL YADAV, VP

The assessee is in appeal before the Tribunal against the order of the ld. Commissioner of Income Tax (Appeals) [in short ‘the CIT (A)’] dated 25.11.2024 passed for assessment year 2023-24. 2. The solitary grievance of the assessee is that ld.CIT (Appeals) has erred in deleting the disallowance of Rs.18,11,579/- which was A.Y.2023-24 2

added by denying the claim made u/s 80JJAA of the Income Tax

Act.

3.

With the assistance of ld. Representative, we have gone

through the record carefully. It emerges out that the claim of the as

The order continues below.

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