Denial of Section 80JJAA Employment Deduction Cannot Be Done Through Rectification Under Section 154 of Income Tax Act

ITAT ruled that denial of deduction under section 80JJAA through rectification proceedings under s.154 was invalid. The tribunal emphasized that s.154's scope is strictly limited to correcting apparent mistakes from records and cannot extend to complex issues requiring detailed examination. The claim for employment-related deduction under s.80JJAA involves analysis of multiple conditions and factual verification, making it a debatable matter falling outside s.154's purview. The Centralized Processing Center's attempt to disallow the deduction through rectification was held improper as it required substantive legal interpretation. The tribunal allowed the assessee's appeal, setting aside the rectification order. .....

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