IN THE INCOME TAX APPELLATE TRIBUNAL, CUTTACK BENCH CUTTACK BEFORE SHRI GEORGE MATHAN, JUDICIAL MEMBER AND SHRI MADHUSUDAN SAWDIA, ACCOUNTANT MEMBER (Assessment Year: 2021-22)

Gram Vikas, I.T.O., Mohuda, B.O. Narsinghpur, Ganjam, Exemption Ward, Vs.

Ganjam-760002 (Odisha) Berhampur.

PAN No. AAAJG 0107 C Appellant/ Assessee Respondent/ Revenue Assessee represented by Shri Nanak Fogia, A.R.

Department represented by Shri Sajib Banerjee, Sr. DR Date of hearing 23/02/2026 Date of pronouncement 23/02/2026

O R D E R

PER: BENCH

1. This is an appeal filed by the assessee against the order of the ld.

Addl/JCIT(A)-2, Coimbatore in Appeal No. NFAC/2020-21/10199542 dated

18/03/2024 for the A.Y. 2021-22.

2. Shri Nanak Fogia, ld. A.R. appeared on behalf of the assessee and Shri Sanjib Banerjee, ld. Sr. DR represented on behalf of the revenue.

3. The appeal of the assessee is delayed by 559 days. In this regard, the assessee has filed an application for condonation of delay supported with an affidavit stating therein sufficient reasons for delay in filing the appeal before the Tribunal, which are not found to be false. Ld. Sr. DR did not object to condone the delay. Accordingly, we condone the delay of 559 days in filing the appeal before the Tribunal and appeal of the assessee is admitted for hearing.

4. It was submitted by the ld. AR that the addition as made in the assessment order was to an extent of Rs. 3,51,46,410/-. It was the submission that on appeal, the ld. JCIT(A) had deleted the addition. It was the submission that, however, in the finding portion of the order, the ld. Addl./JCIT(A) has erroneously put the figure at Rs. 3,10,46,410/-. It was the submission that the assessee is unable to file a rectification application under Section 154 of the Income Tax Act, 1961 before the ld. JCIT(A) as the portal of the Income Tax Department does not permit the same. The ld. AR of the assessee has also filed an affidavit to this effect.

5. In reply, the ld. Sr.DR has submitted that there seems to be an error in the order of the ld. Addl./JCIT(A) in respect of the quantification of the addition which has been deleted by the ld. Addl./JCIT(A).

6. We have considered the rival submissions. As it is noticed that the ld.

Addl./JCIT(A) has deleted the addition in its entirety but the figure has been wrongly typed as Rs. 3,10,46,410/- as against Rs. 3,51,46,410/-, the error in the order of the ld. Addl./JCIT(A) stands corrected and the addition as deleted by the ld. Addl./JCIT(A) is to be taken as Rs.

3,51,46,410/-.

7. In the result, appeal of the assessee is allowed.

Order dictated and pronounced in the open court on 23/02/2026.

Sd/- Sd/-

(MADHUSUDAN SAWDIA) (GEORGE MATHAN) ACCOUNTANT MEMBER JUDICIAL MEMBER Ranchi, Dated: 23/02/2026 *Ranjan Copy to:

1. Assessee 2. Revenue

3. CIT(A)

4. CIT 5. DR

6. Guard File By Order Assistant Registrar, ITAT, Cuttack