The Ahmedabad Bench of the Income Tax Appellate Tribunal ( ITAT ) directed the Jurisdictional Assessing Officer (JAO) to rectify the intimation by the Central Processing Centre because of the rejection of Section 80JJAA of the Income Tax Act, 1961 claim due to technical default.
Vimalachal Print & Pack Pvt. Ltd., the assessee filed its income tax return for the assessment year 2020-21 declaring a total income of Rs. 27,66,79,540. The assessee claimed a deduction of Rs. 10,10,118 under Section 80JJAA of the Income Tax Act, 1961.
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The Central Processing Centre (CPC), Bengaluru when processing the income tax return under Section 143(1) rejected the deduction claim. The rejection was due to a technical default not because of ineligibility of the claim.
The deduction under Section 80JJAA had been allowed to the company in both prior and subsequent assessment years. Aggrieved, the assessee appealed the rejection before the Commissioner of Income Tax (Appeals) which upheld the CPC’s decision.
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Dissatisfied with the CIT(A)’s order, the assessee appealed to the Income Tax Appellate Tribunal (ITAT) challenging the CIT(A)’s order. The assessee’s counsel argued that the CPC’s action was beyond its jurisdiction and the adjustment was prima facie.
A single bench led by Suchitra Kamble (Judicial Member) observed during the hearing that the company’s eligibility for the deduction was not in question.
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The tribunal also observed that the rejection arose from procedural shortcomings rather than the merit of the claim. The tribunal directed the Jurisdictional Assessing Officer (JAO) to rectify the CPC’s intimation and conduct a fresh assessment. The appeal of the assessee was allowed for statistical purposes.
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