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2022 (1) TMI 985 - AT - Income TaxDeduction u/s 80P - Income from Commission,Miscellaneous Income and Net Income from public Distribution Scheme did not qualify for deduction under any of the provisions of section 80P(2)(a)/(b)/(d)/(e)/(f) - HELD THAT - After perusal of the material on record it is noticed that AO has specifically asked the assessee to submit the supporting detail pertaining to such income to justify the claim of deduction u/s. 80P, however, the assessee has not made any compliance even before the CIT(A) the assessee has not submitted any detail. During the course of appellate proceedings before us the assessee has simply stated that lower authorities has not allowed deduction u/s. 80P which was allowable on the aforesaid income. Evening during the course of appellate proceedings before us, the assessee has not filed any supporting relevant material to demonstrate that how the assessee is entitled for deduction u/s. 80P on the aforesaid specific nature of income. Therefore, we do not find any infirmity in the decision of ld. CIT(A) and this ground of appeal of the assessee stands dismissed.
Issues:
Disallowance of deduction under section 80P for specific income items. Analysis: The appeal before the Appellate Tribunal ITAT Rajkot concerned the disallowance of deduction under section 80P of the Income Tax Act, 1961, for specific income items for the assessment year 2012-13. The assessee had claimed deduction under section 80P on commission income, miscellaneous income, and income from a public distribution scheme. The Assessing Officer disallowed the claim as the assessee failed to provide supporting details to substantiate the claim. The assessee then appealed to the CIT(A), where again no relevant supporting details were furnished. The tribunal noted that the assessee did not comply with the Assessing Officer's request for supporting details, even during the appellate proceedings. The tribunal found that the assessee did not provide any material to justify the claim of deduction under section 80P for the specific nature of income in question. Consequently, the tribunal upheld the decision of the CIT(A) to dismiss the appeal, as there was no evidence presented to support the claim of deduction under section 80P for the disputed income items. The tribunal emphasized that the grounds of appeal raised by the assessee were interconnected, all relating to the disallowance of deduction under section 80P for the specified income items. Despite the assessee's contentions, the tribunal found that no supporting material was submitted before the authorities to substantiate the claim of deduction under section 80P. The tribunal highlighted that the Assessing Officer had explicitly requested the assessee to provide supporting details for the income in question, but the assessee failed to do so. Even during the appellate proceedings, the assessee did not present any relevant material to demonstrate entitlement to deduction under section 80P for the specific nature of income. Consequently, the tribunal concluded that there was no basis to overturn the CIT(A)'s decision to dismiss the appeal, as the assessee did not provide any evidence to support the claim of deduction under section 80P for the disputed income items. In conclusion, the Appellate Tribunal ITAT Rajkot upheld the decision to dismiss the appeal of the assessee regarding the disallowance of deduction under section 80P for commission income, miscellaneous income, and income from a public distribution scheme. The tribunal found that the assessee failed to provide any supporting material to justify the claim of deduction under section 80P for the specific income items in question. Therefore, the tribunal affirmed the CIT(A)'s decision, as there was no substantiation for the claim of deduction under section 80P for the disputed income items.
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