DHURJYOTI TEA COMPANY PRIVATE LIMITED,PENGREE vs. INCOME TAX OFFICER, WARD-1, DIGBOI, DIGBOI

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ITA 104/GTY/2024Status: DisposedITAT Guwahati20 January 2025AY 2021-2022Bench: DR.MANISH BORAD (Accountant Member), SHRI MANOMOHAN DAS (Judicial Member)6 pages
AI SummaryRemanded

Facts

The assessee, a private limited company manufacturing black tea, claimed deductions under Section 80IE for Assessment Years 2020-21 and 2021-22. However, the Tax Audit Report (Form 10CCB) supporting these claims inadvertently mentioned A.Y. 2017-18 instead of the correct assessment years. Consequently, the CPC made prima-facie adjustments under Section 143(1)(a) denying the deductions, which was upheld by the CIT(A).

Held

The Tribunal set aside the CIT(A)'s order and remitted the matter back to the CIT(A) for fresh adjudication. The assessee is instructed to submit the correct Audit Reports and a certificate from the Tax Auditor explaining the error. The CIT(A) is directed to decide the case on merits in accordance with the law after providing the assessee a fair hearing, and the appeals were allowed for statistical purposes.

Key Issues

Denial of deduction under Section 80IE due to the filing of a Tax Audit Report (Form 10CCB) reflecting an incorrect assessment year, leading to a prima-facie adjustment under Section 143(1)(a).

Sections Cited

Section 250, Section 143(1)(a), Section 139(1), Section 80IE

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, GUWAHATI BENCH, GUWAHATI

Before: DR.MANISH BORAD & SHRI MANOMOHAN DAS

For Respondent: Shri Kausik Ray, JCIT
Hearing: 26.11.2024Pronounced: 20.01.2025

आदेश क� �ितिलिप अ�ेिषत / Copy of the Order forwarded to : अपीलाथ� / The Appellant. 1. ��यथ� / The Respondent. 2. 3. The Pr. CIT concerned. िवभागीय �ितिनिध, आयकर अपीलीय अिधकरण, “, Guwahati” ब�च, 4. / DR, ITAT, Guwahati Bench गाड� फ़ाइल / Guard File. 5.

आदेशानुसार / BY ORDER,

// True Copy // Assistant Registrar

DHURJYOTI TEA COMPANY PRIVATE LIMITED,PENGREE vs INCOME TAX OFFICER, WARD-1, DIGBOI, DIGBOI | BharatTax