vk;dj vihyh; vf/kdj.k] t;iqj U;k;ihB] t;iqj IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES,”B” JAIPUR Mk

0 ,l- lhrky{eh] U;kf;d lnL; ,oa Jh xxu xks;y] ys[kk lnL;] ds le{k BEFORE: DR. S. SEETHALAKSHMI, JM & SHRI GAGAN GOYAL, AM vk;dj vihy la-@ITA No. 901/JPR/2025 fu/kZkj.k o"kZ@

Assessment Years : 2018-19 Bajrang Wire Products (India) Private cuke Deputy Commissioner of Limited Vs. Income Tax, E-762A Road No. 9F1, Vishwakarma Circle-4, Industrial Area, S.O. Jaipur, Jaipur. Jaipur, RJN-C-(104)(1).

LFkk;hys[kk la-@thvkbZvkj la-@PAN/GIR No.: AAACB9919N vihykFkhZ@Appellant izR;FkhZ@Respondent fu/kZkfjrh dh vksjls@Assesseeby : Shri Athrav Mundra, Adv. &

Shri Shubham Sharma, Adv.

jktLo dh vksjls@Revenue by : Shri Dharma Singh Meena, JCIT lquokbZ dh rkjh[k@Date of Hearing : 13/08/2025 mn?kks"k.kk dh rkjh[k@Date of Pronouncement: 29/09/2025 vkns'k@ORDER PER: DR. S. SEETHALAKSHMI, J.M.

This is an appeal filed by the assessee against the order of ld. CIT (A), National Faceless Appeal Centre (NFAC), Delhi dated 02.06.2025 passed under section 250 of the I.T. Act, 1961, for the assessment year 2018-19. The said order of the ld. CIT (A), NFAC arises against the order 16.03.2021 passed under section

143(3) read with sections 143(3A) and 143(3B) of the Income Tax Act, 1961 by ITO National e-Assessment Centre, Delhi.

2. The assessee has raised the following grounds of appeal :-

“1. That on facts and in law, the ld. Commissioner of Income tax (Appeals)[ld. CIT(A)] has erred in not admitting the claim of deduction u/s 80JJAA of Rs. 6,71,052/-, which was raised in the grounds of appeal filed before him.

2. That the non-allowance of said claim of deduction u/s 80JJAA of Rs. 6,71,052/- by the ld. CIT (A) is against the provisions of the Act, CBDT Circular and the judicial precedents in this regard.

3. That on facts and in law, the ld. CIT (A) has erred in not allowing deduction as claimed u/s 80JJAA of Rs. 6,71,052/-. The said deduction is allowable in toto including as per prescribed auditor’s certificates.

4.That the grounds of appeal as herein are without prejudice to each other.

5. That the appellant respectfully craves leave to add, amend, alter and/or forego any ground(s) at or before the time of hearing.”

3. The brief facts of the case are that the assessee company is engaged in manufacturing of wire drawings and has three manufacturing facilities. Assessee has e-filed its Return of Income dated 25.10.2018 declaring the total income at Rs. 5,79,74,670/- for the year under consideration. The assessee filed the revised its return of income on 29.12.2018 declaring an income of Rs. 5,11,66,180/-. The case of the assessee was selected for scrutiny under CASS. Accordingly notice under section 143(2) of the Income Tax Act, 1961 was issued on 22.09.2018 through ITBA portal and duly served upon the assessee. Information under section

142(1) of the IT Act, 1961 was called for vide questionnaire through ITBA. In compliance of the said notices, the assessee has submitted the details and information through e-proceeding. The information/details so filed was examined. The assessee company submitted that it has three wire drawing manufacturing facility during the assessment year. The first two units were in operation during the start of the assessment year and third unit commence production during the assessment year itself. In the revised return filed on 29.12.2018 the assessee has claimed deduction of Rs. 6,71,052/- under section 80JJAA, which was not claimed in the original return of income filed on 25.10.2018. During the assessment proceeding, the assessee was required to furnish Form 10DA issued by Accountant and same was furnished by the assessee. As per submission, the assessee has claimed that 33 new workmen were employed during the year which were considered entitled for deduction to whom emoluments amounting to Rs, 22,36,840/- was paid and 30% of the same i.e. Rs. 6,71,052/- was claimed as deduction under section 80JJAA of the IT Act, 1961. The AO obser