9911796707
TMI Blog2024 (3) TMI 1123X X X X Extracts X X X X X X X X Extracts X X X X ..... ARA, J.M. This assessee's appeal for assessment year 2019-2020, arises against the National Faceless Appeal Centre [in short the "NFAC"] Delhi's Din and Order No. ITBA/NFAC/S/250/2022- 23/1047557881(1), dated 22.11.2022, involving proceedings u/s. 143(1) of the Income Tax Act, 1961 (in short "the Act"). Heard both the parties. Case file perused. 2. Mr. Marathe submitted at the outset that both ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d sec. 80P deduction disallowance made in assessee's hands. This is for the precise reason that legislature has introduced such a disallowance provision in sec. 143(1)(a)(v) dealing with deduction claim(s) provided in Chapter-VI-A of the Act by way of Finance Act, 2021 w.e.f. 01.04.2021 with prospective effect whereas the assessment year herein is 2017-2018 only. So far as the Revenue's case quoti ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... action being in the nature of a general provision only. I adopt principles of stricter interpretation as per Commissioner vs. Dilip Kumar And Co. & Ors. [2018] 9 SCC 1 (SC) (FB) to conclude that both the learned lower authorities action disallowing the assessee's sec. 80P deduction(s) claim(s) by way of sec. 143(1)(a)(ii) or 143(1)(a)(v) "processing" has to be reversed. Ordered accordingly. 4. T ..... X X X X Extracts X X X X X X X X Extracts X X X X
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