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TMI Blog2019 (12) TMI 453X X X X Extracts X X X X X X X X Extracts X X X X ..... rned CIT(A), Bengaluru 6, Bengaluru passed under section 250 the Act in so far as it is against the appellant is opposed to law, equity, weight of evidence, facts and circumstances in the Appellant's case. 2. The learned CIT(A), Bengaluru - 6 , Bengaluru has erred in law in not adjudicating on grounds 1, 2, 3&5of the appeal filed. 3. The learned CIT(A) Bengaluru - 6, Bengaluru is not justified in law in denying the eligible deduction claimed by the appellant as per provisions of section 80P(2)(d) of the Act, on merits. 4. The Order of Assessment passed by the learned Assessing Officer is bad in law in adding a sum of Rs. 21,99,628 as "Income from other sources", voluntarily disclosed by the appellant in his return of income, as ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Tumkur (ITA No.307 of 2014) and in catena of cases of this Hon'ble bench in M/s. Kanyakaparameswari Credit Cooperative Society Ltd Vs ITO in ITA No.2900/Bang/2017 dated 22.03.2018. 9. Without prejudice to the right to seek waiver as per the parity of reasoning of the decision of the Hon'ble apex Court in the case of Karanvir Singh 349 ITR 692, the appellant denies itself liable to be charged to interest under section 234A & 234 B of the Income Tax Act under the facts and circumstances of the case. 10. The appellant contends that the levy of interest under section 234A & 234 B of the Act is also bad in law as the period, rate, quantum and method of calculation adopted by the learned assessing officer on which interest is levie ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the case of Totgar's Co-operative Sale Society Ltd (citation not given), held that the assessee is not entitled for deduction u/s 80P of the Act. Though the AO has stated in paragraph 9 of its order that he is adding an amount of Rs. 21,99,628/- as "income from other sources, yet while computing total income the AO determined total income at Rs. 43,99,256/- (Rs. 45,14,399/- less set off of current year loss of Rs. 1,15,143/-) 4. Thereafter, the assessee filed a rectification petition u/s 154 of the Act before the assessing officer, wherein it was pointed out that (a) the AO having stated that he is adding a sum of Rs. 21,99,628/- has actually added Rs. 45,14,399/- resulting in excess assessment of Rs. 23,14,771/-. (b) the assessee ..... X X X X Extracts X X X X X X X X Extracts X X X X
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