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Facts
The assessee preferred two appeals against orders pertaining to AY 2021-22 and 2022-23. The grievance in both appeals relates to the disallowance of expenditure incurred towards the object of the trust. The assessee's appeal before the CIT(A) was dismissed without deciding the relevant grounds.
Held
The Tribunal observed that the CIT(A) did not decide the relevant grounds raised by the assessee and that the assessee had also filed a rectification application u/s 154 of the Act which was not acted upon. Accordingly, the Tribunal directed the CIT(A) to decide the application and rectify the mistake apparent from record.
Key Issues
Whether the CIT(A) should have decided the grounds related to disallowance of expenditure incurred towards the trust's object and whether rectification u/s 154 was necessary.
Sections Cited
143(1), 154
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Income Tax Appellate Tribunal, “K(SMC
Before: SHRI NARENDRA KUMAR BILLAIYA, HON’BLE & SHRI RAHUL CHAUDHARY, HON’BLE
O R D E R PER NARENDRA KUMAR BILLAIYA, AM: & 3104/Mum/2024, are two separate appeals preferred by the assessee against two separate orders of ld. CIT(A)/Addl./JCIT(A)-1 Bengaluru, dt. 29/03/2024 pertaining to AY 2021-22 and 2022-23 respectively.
Since the grievance is common in both the appeals and since the underlying facts are identical, both the appeals are disposed of by this common order, for the sake of convenience and brevity.
The common grievance in both the appeals relates to the disallowance made by CPC on expenditure incurred towards the object of the trust. The quantum may differ.