Mantra Softech (India) Private Limited Vs DCIT (ITAT Ahmedabad)
80JJAA Deduction Already Allowed by Subsequent 154 Order—Original 154 Appeal Becomes Infructuous; ITAT Dismisses Appeal as Only Academic
The Assessee filed return for AY 2021-22 declaring ₹24.56 crore. While processing the return u/s 143(1), CPC disallowed ₹25,14,054 claimed as 80JJAA deduction, stating that Form 10DA was not filed with the return. The Assessee sought rectification u/s 154, explaining that the deduction did not pertain to AY 2021-22 at all, but represented the second & third-year continuing claim for additional employee cost relating to AYs 2019-20 and 2020-21, for which Form 10DA had already been filed in those respective years. CPC, however, initially rejected the rectification on 10-01-2023, which led to the first appeal.
During pendency of the appeal before CIT(A), CPC passed a fresh 154 order on 29-04-2025, now allowing the entire 80JJAA claim of ₹25,14,054, accepting that no new Form 10DA was required for AY 2021-22 and that the deduction legitimately flowed from earlier years. Despite this, the CIT(A) dismissed the appeal by not appreciating that the grievance had already been fully addressed.
Before ITAT, the Assessee demonstrated that the subsequent rectification order had completely granted the relief, and therefore the original dispute no longer survived. The Department also agreed that the grievance stood redressed and that the appeal had become infructuous.
The Tribunal held that since CPC had already allowed the 80JJAA deduction through the later 154 order, no further adjudication was required, though it clarified that no additional 80JJAA deduction beyond what CPC already allowed could be claimed through this appeal.
FULL TEXT OF THE ORDER OF ITAT AHMEDABAD
