AA 163 VANDIPALAYAM PRIMARY AGRICULTURAL CO-OPERATIVE CREDIT SOCIETY LIMITED,UKKARAM PO SATHYAMANGALAM vs. THE INCOME TAX OFFICER, ERODE

PER MANU KUMAR GIRI, JM:

This appeal is filed by the assessee against the order of the Commissioner of Income Tax (Appeals) [CIT(A)] dated 11.07.2025, arising out of the assessment order passed under section 143(3) of the Income-tax Act, 1961 by the National Faceless Assessment Centre for the Assessment Year 2020-21.

ITA No 18/Chny/2026 (AY 2020-21) APPELLATE AUTHORITY 163 Vandipalayam P A Co op Cr S Ltd (Vs) ITO :: 2 :: 2. Brief facts of the case are that the assessee is a co-operative society registered under the Tamil Nadu Co-operative Societies Act, 1983. The assessment in this case was completed under section 143(3) read with section 144B of the Act on 29.08.2022.During the course of assessment proceedings, the Assessing Officer (AO) observed that the assessee had claimed deduction under section 80P, including deduction under section 80P(2)(a)(i) and section 80P(2)(d). The AO, however, disallowed the said deductions and made additions aggregating to Rs. 56,97,242/-, inter alia, on account of disallowance of deduction under section 80P(2)(a)(i), disallowance of deduction under section 80P(2)(d) in respect of interest/dividend income and additions based on entries reflected in the balance sheet. The assessment was completed after issuance of notices under the faceless assessment scheme. 3. The assessee preferred an appeal before the CIT(A) with a delay of 798 days (approximately 2 years and 2 months). The assessee sought condonation of delay on the ground that the assessment was conducted under faceless proceedings and the secretary of the society was not well-versed with computer operations. Hence notices issued electronically were not properly noticed. The CIT(A), after considering the submissions, held that the delay was inordinate. The reasons furnished were not sufficient, reasonable, or convincing. He further noted that lack of knowledge of faceless proceedings cannot be accepted as a valid ground. The assessee failed to demonstrate any reasonable cause preventing timely filing. Accordingly, the ld.CIT(A) refused to condone the delay and dismissed the appeal as not admitted, without adjudicating the issues on merits.

ITA No 18/Chny/2026 (AY 2020-21) APPELLATE AUTHORITY 163 Vandipalayam P A Co op Cr S Ltd (Vs) ITO :: 3 :: Now assessee is in appeal before this Tribunal. 4. The assessee has raised multiple grounds challenging validity of assessment under section 144B and alleged violation of principles of natural justice. Assessee also questioned the disallowance of deduction under section 80P and non-consideration of judicial precedents, procedural lapses in faceless assessment. 5. The ld.DR for the revenue relied upon the impugned order and prayed for the dismissal of the appeal. 6. We have heard the rival submissions and perused the material available on record.At the outset, it is noted that the CIT(A) has dismissed the appeal on account of non-condonation of delay, and therefore, the primary issue before us is whether the CIT(A) was justified in refusing to condone the delay.It is an undisputed fact that the appeal before the CIT(A) was filed with a delay of 798 days, which is admittedly substantial and inordinate.The explanation offered by the assessee is primarily that the proceedings were faceless and the secretary lacked technical knowledge hence notices were not properly tracked. In our considered view, such reasons cannot be accepted as sufficient cause within the meaning of the law.It is a settled principle that a litigant must be vigilant in pursuing his legal remedies. The assessee, being a registered co- operative society, is expected to maintain proper administrative mechanisms, including compliance with statutory notices.The plea of lack of computer knowledge or unfamiliarity with faceless proceedings does not absolve the assessee from its statutory obligations. Acceptance of such a plea would set an untenable precedent and defeat the very purpose of the faceless assessment scheme introduced under section 144B.The assessee has not

ITA No 18/Chny/2026 (AY 2020-21) APPELLATE AUTHORITY 163 Vandipalayam P A Co op Cr S Ltd (Vs) ITO :: 4 :: brought on record any material to demonstrate that the delay was caused due to circumstances beyond its control. No evidence of technical failure, non-receipt of notices, or other unavoidable circumstances has been furnished.The explanation offered is casual and general in nature and does not justify such an extraordinary delay.It is well-settled that though the provisions relating to condonation of delay should be construed liberally, the existence of “sufficient cause” is a sine qua non. Where the delay is inordinate, the burden on the assessee to establish sufficient cause becomes heavier.In the present case, the assessee has failed to discharge this burden.In view of the above, the CIT(A) has rightly appreciated the facts and the reasons for delay were duly examined. A reasoned finding has been given for refusal to condone the delay. We do not find any infirmity in the order of the CIT(A).Since the appeal before the CIT(A) itself was not admitted on account of inordinate delay, the grounds raised by the assessee on merits do not survive for adjudication. 7. The appeal filed by the assessee is dismissed. Order pronounced in the open court on the 11th day of May, 2026, in Chennai.

Sd/- Sd/- (एस. आर. रघुनाथा) (मनु कुमार िग�र) (S.R.RAGHUNATHA) (MANU KUMAR GIRI) लेखा सद*य/ACCOUNTANT MEMBER �या�यक सद*य/JUDICIAL MEMBER चे�नई/Chennai, +दनांक/Dated: 11th May 2026. SNDP, Sr. PS

ITA No 18/Chny/2026 (AY 2020-21) APPELLATE AUTHORITY 163 Vandipalayam P A Co op Cr S Ltd (Vs) ITO :: 5 :: आदेश क ��त,ल-प अ.े-षत/Copy to: 1. अपीलाथ�/Appellant 2. ��थ�/Respondent 3. आयकरआयु�/CIT, Chennai / Madurai / Salem / Coimbatore. 4. िवभागीय�ितिनिध/DR 5. गाड�फाईल/GF