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TMI Blog2021 (6) TMI 617X X X X Extracts X X X X X X X X Extracts X X X X ..... laiming deduction u/s 80 IA (4) considering the submissions from both the sides we remit this issue back to the file of AO for de-novo assessment. Needless to say that the assessee shall be given a reasonable opportunity of hearing. Assessee is directed not to seek unnecessary adjournments, and appear before the Assessing Officer on or before 30.09.2021 within three effective opportunities at asse ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 77; 3,60,31,451/- In the return of income filed by the assessee in ITR 6 Para A General in Audit information under the head Are you liable to furnish a report u/s 92E N . The return was processed u/s 143(1) of the Act on 05.03.2013 on the returned income declared by the assessee and did not give benefit of deduction under chapter VI A of the Act As per the intimation letter the due date of filin ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... t dated 22.10.2011 was obtained from a Chartered Accountant. The due date for filing of return was 30.11.2011 and Form no 10 CEB was also obtained by the assessee on 05.09.2011 from a Chartered Accountant before filing the return of income. There was a apparent mistake on the record for not granting the deduction u/s 80 IA(4) of the Act In support of his argument he relied on a number of judgement ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... y both sides, there is no doubt that the assessee has suppressed the facts of his activity and filed return of income before obtaining report in prescribed Form no. 3 CEB dated 22.10.2011. Since this is the 8th year for claiming deduction u/s 80 IA (4) of the Act, considering the submissions from both the sides we remit this issue back to the file of Assessing Officer for de-novo assessment. Needl ..... X X X X Extracts X X X X X X X X Extracts X X X X
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