Loading judgment…
No AI summary yet for this case.
Income Tax Appellate Tribunal, KOLKATA ‘B’ BENCH, KOLKATA
Before: SONJOY SARMA & SRI RAKESH MISHRA
order : 04-August-2025 ORDER PER BENCH: These four appeals filed by the assessee are against the separate orders of the Addl/JCIT(A)-1, Nashik [hereinafter referred to as the ‘Ld. Addl/JCIT(A)’] passed u/s 250 of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) for AYs 2019-20, 2020-21, 2021-22 & 2022-23 dated 02.01.2025, which have been passed against the intimations dated 26.02.2020, 30.09.2021, 26.05.2022 & 08.11.2022, respectively issued u/s 143(1) of the Act. Since the issues in all the four appeals are AY 2021-22, Ground No. 1 has been inadvertently split into Ground Nos. 1 and 2.
We shall first take up the appeal in AY 2019-20 as the lead case. Brief facts of the case mentioned in the Statement of Facts are that the assessee is an Individual and she e-filed her return of income for the said assessment year on 12/11/2019 declaring total income of Rs. 1,36,79,759/- and claiming credit of taxes paid of Rs. 46,52,910/-. However, the Ld. Assessing Officer, the Asst. Director of Income Tax, CPC, Bengaluru vide the Intimation issued u/s 143 (1) of the Act on 26/02/2020 accepted the returned income but allowed credit of taxes paid of Rs.24,46,589/- only as against the tax credit claimed at Rs. 46,52,910/- and raised consequential demand of Rs.25,98,755. Details of credit of taxes claimed by the assessee and credit allowed by the department have been mentioned as ₹46,52,910/- and ₹24,46,589/- respectively and a sum of ₹22,06,321/- being the TDS in the name of the husband has not been allowed. In the return of income, in addition to her own income of Rs.59,33,102/- (income from other sources-interest income), the assessee also offered total income of Rs.73,13,808/- comprising income from M/s Elco Enterprise and Interest income from Bank (both in the name of Late Jagbandhu Das) for taxation and corresponding TDS of Rs.28,42,910/- (in the assessee's