disallowed.
ii. Restriction of deduction under section 80JJAA
The assessee claimed deduction under section 80JJAA
amounting to Rs. 12,31,53,732/- which included deduction ... earlier assessment years. The Assessing Officer held
that deduction under section 80JJAA is allowable only in respect
of additional employee cost relating to the relevant
Appeals) erred in confirming the disallowance of deduction
claimed under section 80JJAA of the Income-tax Act,
1961(' IT Act ') amounting ... from Form 10DA
3
ITA.No.1165/Hyd./2025
required under section 80JJAA of the IT Act. Hence, the
reliance placed
Tirupati
Organisers Pvt. Ltd. in contravention to the provisions of section
80JJAA(2)(a) of the I.T. Act.
6. In addition to the ground ... 80IA of the Act
ii. Rs.87,05,437/- u/s 80JJAA of the Act
3.1 The disallowances were primarily made on the ground that
ground being disallowance was on
account of claim of deduction u/s 80JJAA of the Act by ld AO vide order
dated 26.07.2023. Against ... made the condition applicable to all deductions under
Chapter VIA, including Section 80JJAA .
Therefore, compliance with the due date prescribed under
Section
disallowance by the ld. CIT(A) on account of deduction u/s
80JJAA of the Act.
18. Facts in brief are that, the assessee ... claimed deduction
of Rs.52,87,590/- u/s 80JJAA of the Act, in the return of income.
The ld. AO had called
claim of deduction of
Rs.3,34,16,370/- under section 80JJAA of the Act on the reasoning that the
assessee has not filed Form ... after claiming deduction of Rs.3,34,16,370/-
under section 80JJAA of the Act. The said revised ITR was processed under
section
1959/PUN/2025
of not allowing deduction u/s 80JJAA (by way of prima facie
adjustment) as claimed by the appellant in the return ... appellant having filed Form 10DA, it is
eligible for deduction under section 80JJAA.
d. The eligible amount of deduction having been duly
certified
denying the valid claim made under Section 80JJAA of
the Act is totally contrary to the facts and evidence on
record and therefore unsustainable both ... Appellant who has fulfilled all
the conditions prescribed under Section 80JJAA of the
Act.
4. The Ld. CIT(A)/Ld.AO failed to consider that
10DA along
with return of income for claiming the deduction u/s 80JJAA .
Page No.
ITA No.216 & 217/Chny/2026
12. On being ... submitted that the assessee
has filed Form 10DA claiming deduction u/s 80JJAA on 29.11.2024. The assessee
submitted before the ld CIT(A) that
officer for granting deduction of
Rs.3,06,30,724 u/s. 80JJAA claimed by the appellant.
2. On the facts and circumstances ... passing order u/s. 250 , denying the appellant the benefit of
deduction 80JJAA.
3. On the facts and circumstances of the case as well