S1911 A.N.PUDUR PACCS,SALEM vs. ITO, WARD-1(6), SALEM

आदेश / O R D E R

PER MANU KUMAR GIRI, JM:

The captioned appeal filed by the Assessee is directed against the orders of the Ld. Commissioner of Income Tax (Appeals), NFAC, Delhi, [CIT(A)] dated 07.01.2026 for Assessment Years 2018-19. 2. The brief facts of the case are that the appellant, S1911 A.N. Pudur Primary Agricultural Co-operative Credit Society, is a society registered under the provisions of the Tamil Nadu Co-operative Societies Act, 1961. The appellant filed its return of income for the

ITA No. 1341/Chny/2026 (AY 2018-19) S1911 A.N. Pudur Primary Agricultural Co Op Credit Society Vs ITO W 1(6) :: 2 :: Assessment Year 2018-19 under section 139(1) of the Income-tax Act, 1961, on 23.10.2018 declaring a total income of 'Nil'. During the financial year 2017-18 relevant to the Assessment Year 2018-19, the appellant earned interest income amounting to Rs.3,48,81,598/-. In the return of income, the appellant disclosed Gross Total Income of Rs.1,08,56,675/- and claimed deductions under Chapter VI-A as under: • Deduction under section 80P(2)(a)(i) – Rs.1,44,18,408/- • Deduction under section 80P(2)(c)(ii) – Rs.50,000/- • Deduction under section 80P(2)(d) – Rs.1,16,57,021/- The deduction claimed under Chapter VI-A was restricted to the Gross Total Income of Rs.1,08,56,675/-, thereby resulting in a returned income of 'Nil'. The case was selected for scrutiny through CASS and notice under section 143(2) of the Act was issued on 22.09.2019. Subsequently, the Assessing Officer completed the assessment determining the total income of the appellant at Rs.10,26,58,994/- after making, inter alia, the following additions/disallowances: Particulars Amount (Rs.) Disallowance of deduction under section 80P(2)(a)(i) 1,08,56,675 Unexplained cash deposits and withdrawals 7,95,42,109 Bogus claim of interest income 1,22,60,210 Total 10,26,58,994 3. Aggrieved by the assessment order, the assessee preferred an appeal before the ld. Commissioner of Income Tax (Appeals). The ld. CIT(A), vide order dated 07.01.2025, dismissed the appeal observing that the assessee had failed to effectively prosecute the appeal and had not furnished the necessary documentary evidence

ITA No. 1341/Chny/2026 (AY 2018-19) S1911 A.N. Pudur Primary Agricultural Co Op Credit Society Vs ITO W 1(6) :: 3 :: to substantiate the grounds raised. The ld. CIT(A) also proceeded to confirm the additions made by the Assessing Officer on merits. Aggrieved by the aforesaid appellate order, the assessee is in further appeal before this Tribunal. 4. The ld. Authorised Representative (AR) for the assessee submitted that the ld. CIT(A) passed the impugned order without properly appreciating the facts and circumstances of the case. It was submitted that the assessee was unable to scan and digitally upload the relevant supporting documents on the income-tax portal and, therefore, could not effectively place the necessary evidences before the appellate authority. The ld. AR pleaded that one more opportunity may be granted to the assessee to substantiate its claims with supporting records. 5. Per contra, the ld. Departmental Representative (DR) relied upon the orders of the lower authorities and submitted that adequate opportunities had been afforded to the assessee. Accordingly, he supported the order of the ld. CIT(A) and prayed for dismissal of the appeal. 6. We have heard the rival submissions and perused the material available on record, including the orders of the authorities below. Considering the totality of the facts and circumstances of the case, we find that the appeal before the ld. CIT(A) came to be dismissed substantially for want of proper representation and supporting documentary evidence. We also note the contention of the assessee that due to practical difficulties in digitising and uploading the records, the relevant materials could not be effectively produced before the lower authorities. Having regard to the substantial additions made in the assessment and keeping in view the principles of natural justice, we are of the

ITA No. 1341/Chny/2026 (AY 2018-19) S1911 A.N. Pudur Primary Agricultural Co Op Credit Society Vs ITO W 1(6) :: 4 :: considered opinion that the assessee deserves one final opportunity to substantiate its claims before the Assessing Officer (JAO). We further note that the assessment proceedings were conducted during the Covid-19 pandemic period, when various practical and procedural difficulties were being faced by taxpayers. Accordingly, in the interest of justice, we set aside the impugned order of the ld. CIT(A) and restore the matter to the file of the Assessing Officer (JAO) for de novo assessment in accordance with law. The Assessing Officer (JAO) shall examine the evidences and explanations that may be furnished by the assessee and pass a speaking order after affording reasonable opportunity of being heard. The assessee is directed to extend full cooperation and furnish all relevant documents and details as may be called for by the Assessing Officer (JAO). Failure to do so shall entitle the Assessing Officer (JAO) to proceed in accordance with law on the basis of the material available on record. 7. In the result, appeal filed by the assessee is allowed for statistical purposes. Order pronounced in the open court on the 01st day of June, 2026, in Chennai.

Sd/- Sd/- (प�ावती एस) (मनु कुमार िग#र) (PADMAVATHY S) (MANU KUMAR GIRI) लेखा सद$या/ACCOUNTANT MEMBER %या�यक सद$य/JUDICIAL MEMBER

चे%नई/Chennai, 'दनांक/Dated: 01st June, 2026. SNDP, Sr. PS

ITA No. 1341/Chny/2026 (AY 2018-19) S1911 A.N. Pudur Primary Agricultural Co Op Credit Society Vs ITO W 1(6) :: 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