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2024 (5) TMI 814

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..... d by the assessee is accordingly, allowed for statistical purposes. Disallowance of deduction claimed under Chapter VI-A - deduction u/s 80C - AO rejected the claim on the basis that the assessee failed to furnish any supporting evidences - as contended by the assessee that the amount was deposited in PPF Account and hence, he was entitled for deduction u/s 80C - HELD THAT:- Having considering the submissions of the assessee, this contention needs verification at the end of AO and the AO would verify the correctness of the claim of the assessee that the amount was deposited in PPF Account if it was found that amount was deposited in the PPF Account of the assessee during the Financial year, the AO would delete the addition. Adhoc disallowan .....

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..... ('the Ld. AO') in the assessment proceedings against the Appellant and, as such, the same is contrary to principles of natural justice, apart from being without jurisdiction, and that the Ld. CIT(A) has erred in dismissing the plea of the Appellant in this regard. 3. That on the facts and in the circumstances of the case and in law, the Ld. CIT(A) has erred in upholding an addition of INR 3,42,000 under section 68/69A read with section 115BBE of the Income-tax Act, 1961 ('the Act'). 4. That on the fact and in the circumstances of the case and in law, the Ld. CIT(A) has erred in upholding the addition of INR 1,00,000 claimed under Chapter VI-A of the Act. 5. That on the facts and in the circumstances of the case and in law, t .....

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..... d Representatives of the parties and perused the material available on record. It is the contention of the assessee that Ld.CIT(A) did not consider the submissions, made during the course of hearing. This objection of the assessee will be considered while disposing of the other grounds of appeal. Therefore, this ground needs no separate adjudication hence, dismissed. 10. Ground No.3 raised by the assessee is against the sustaining of addition of INR 3,42,000/- u/s 68/69A r.w.s. 115BBE of the Act. 11. Ld. Counsel for the assessee submitted that Ld.CIT(A) without considering the submissions and giving opportunity to explain the source of cash deposit of INR 3,42,000/-, sustained the impugned addition. He contended that the assessee had filed .....

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..... , Ld. Sr. DR for the Revenue opposed these submissions and supported the orders of the authorities below. He submitted that the assessee is required to prove that the deduction under Chapter VI-A of the Act, is allowable to the assessee. 17. I have heard Ld. Authorized Representatives of the parties and perused the material available on record and gone through the orders of the authorities below. The AO rejected the claim on the basis that the assessee failed to furnish any supporting evidences. However, it is contended by the assessee that the amount was deposited in PPF Account and hence, he was entitled for deduction u/s 80C of the Act. Having considering the submissions of the assessee, I am of the view that this contention needs verifi .....

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