A2537 BATLAGUNDU PANCHAYAT EMPLOYEES COOPERATIVE THRIFT AND CREDIT SOCIETY LTD,DINDIGUL vs. THE INCOME TAX OFFICER, DINDIGUL

आदेश/O R D E R

PER S.S. VISWANETHRA RAVI, JUDICIAL MEMBER: This appeal filed by the assessee is directed against the order dated 02.02.2026 passed by the ld. Commissioner of Income Tax (Appeals)/NFAC, Delhi [‘ld.CIT(A)’ in short] for Assessment Year 2020- 21.

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application filed seeking adjournment. The assessee called absent. We

proceed to hear the ld.DR, Ms. Gouthami Manivasagam, Addl.CIT, and

pass order by examining the material evidence available on record.

Cooperative Credit Society stated to have been engaged in money

lending loans to its members, such as jewel loans and agricultural loans

for purchase of seeds and fertilizers and other inputs for the farm,

medium term loan and self-help group loan. The Assessing Officer [‘AO’

in short] denied the deduction u/s. 80P of the Income Tax Act, 1961 [‘the

Act’ in short] for not proving that the assessee is a registered society

which is evident from Page no. 4 of assessment order vide his order

dated 19.09.2022 passed u/s. 143 r.w.s. 144B of the Income-tax Act,

1961 [‘the Act’ in short]. An appeal was preferred by the assessee before

the ld.CIT(A) with a delay of 699 days.

ld.CIT(A) in condoning the delay. The ld.CIT(A) rejected the said reasons,

but however decided the issue on merits by confirming the order of the

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AO. We find the reasons stated by the assessee that the accountant to

comply with accounting and taxation laws and procedures and oversee

the accounts of the assessee prescribed by the Assistant Director of

cooperative audit to conduct statutory cooperative audit and in the course

of their verification, due to lack of sufficient cooperative auditors in the

Cooperative Audit Department, there was a delay in completion and

issuance of reports to the society. Further, due to Corona Pandemic also

there was a delay in completion of audit and lack of manpower, due to

which there was a delay of 699 days which is evident from Para 7.2.3 of

the impugned order. The ld.CIT(A) considered said explanation found not

acceptable by holding that the assessee failed to give day-to-day

explanation with reference to delay of 699 days and the reasons stated by

the assessee cannot be regarded as a minor or technical delay which

reflects lack to due diligence on the part of the assessee which is evident

from Para no. 7.2.5 of the impugned order. Therefore, considering the

reasons recorded by the ld.CIT(A), we hold that the assessee failed to

show sufficient cause which really prevented assessee in filing the appeal

in time. Thus, we find no infirmity in the order of the ld.CIT(A) in rejecting

the delay condonation petition and dismissing the appeal in limine. Thus,

grounds raised by the assessee are dismissed.

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Sd/- Sd/- (S.R. RAGHUNATHA) (S.S. VISWANETHRA RAVI) ACCOUNTANT MEMBER JUDICIAL MEMBER Chennai, Dated 30.04.2026 JPV/- आदेशकी'ितिलिपअ.ेिषत/Copy to: 1. अपीलाथ&/Appellant, 2.'(थ&/ Respondent, 3. आयकरआयु//CIT, Chennai/Madurai/Coimbatore/Salem 4. िवभागीय'ितिनिध/DR & 5. गाड$ फाईल/GF.

PRASANNA Digitally signed by PRASANNA VANI JETTY VANI JETTY Date: 2026.05.04 10:45:29 +05'30'