TYSPL97 POYYUR PRIMARY AGRICULTURAL COOPERATIVE CREDIT SOCIETY LTD,ARIYALUR vs. INCOME TAX OFFICER , PERAMBALUR

ITA 2239/CHNY/2026Status: DisposedITAT Chennai07 October 2026AY 2019-202010 pages
AI SummaryPartly Allowed

What did the Tribunal hold?

The Tribunal held that the issue pertaining to the denial of deduction under Section 80P, amounting to Rs. 54,08,365/-, is confirmed. However, the Tribunal noted that if the assessee obtains a condonation order for the delay in filing the return from the Principal CCIT/DGIT, the deduction under Section 80P would be allowed. Regarding the additions amounting to Rs. 3,25,17,648/- made under Section 69A, the Tribunal, considering the nature of the assessee's business, was convinced that accepting and depositing cash is part of its normal business. Therefore, the Tribunal granted another opportunity to the AO to rehear this matter. The AO was directed to provide a proper opportunity of being heard and the assessee was directed to submit details of members who contributed cash. Consequently, the grounds pertaining to the addition made under Section 69A were allowed for statistical purposes only. The appeal was partly allowed.

What were the facts?

The assessee, TYSPL97 Poyyur Primary Agricultural Cooperative Credit Society Ltd., is in appeal against the order of the Commissioner of Income Tax (Appeals) / NFAC, Delhi, dated March 12, 2026, for Assessment Year 2019-20. The Assessing Officer (AO) had issued a notice under Section 148 of the Income Tax Act, 1961, due to information about cash deposits of Rs. 3,25,17,648/-. The assessee filed a NIL income return in response. The AO made additions of Rs. 3,25,17,648/- under Section 69A for cash deposits and Rs. 54,08,365/- under Section 56 as income from other sources, while denying deduction under Section 80P. The assessee's appeal to the CIT(A) was dismissed, leading to the present appeal before the Tribunal.

What were the issues?

1. Whether the addition of Rs. 3,25,17,648/- under Section 69A of the Income Tax Act, 1961, towards cash deposits is justified, considering the assessee's contention that these represent repayment of loans advanced to members and are genuine business receipts duly recorded and audited. 2. Whether the interest income of Rs. 54,08,365/- was correctly treated as income from other sources, or if it should be considered business income derived from mandatory deposits with the cooperative bank, intrinsically linked to the assessee's business activities. 3. Whether the denial of deduction under Section 80P of the Act is justified, given the assessee's status as a Primary Agricultural Cooperative Credit Society providing credit facilities to its members, making it eligible for the deduction. Assessee's Arguments: - The cash deposits are genuine loan repayments from members and explained business receipts, recorded in books and subject to statutory audit. - Interest income is derived from business activities, arising from mandatory deposits with the cooperative bank. - As a Primary Agricultural Cooperative Credit Society, it is eligible for deduction under Section 80P(2)(a)(i) as its income is from business with members. - Delay in filing the return was due to delay in receiving the statutory audit report, beyond its control. Revenue's Arguments: - Not explicitly recorded in the judgment, but implied by the AO's actions and the CIT(A)'s upholding of those actions.

Which sections of the Income-tax Act were involved?

Section 69A,Section 56,Section 80P,Section 139,Section 148,Section 80AC,Section 119(2)(b),Section 282

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, ‘C’ BENCH: CHENNAI

Before: HONOURABLE GEORGE GEORGE K & SHRI GAGAN GOYAL

Hearing: 19.08.2026Pronounced: 07.10.2026

PER GAGAN GOYAL, AM: This is an appeal preferred by the assessee against the order of Ld. Commissioner of Income Tax (A) / NFAC, (hereinafter referred as the ‘Ld. CIT(A)’), Delhi dated 12.03.2026 for the Assessment Year (hereinafter referred as the ‘AY’) 2019-20. GROUDS OF APPEAL

1.

The Learned Commissioner of income Tax (Appeals) and the

The order continues below.

Read the full judgment

A free account opens 10 full judgments a month. Re-reading one you have already opened does not count again.

Create a free accountSign in

See plans and prices

The summary, the parties, the sections and the citations above are open to everyone and always will be. Only the text of the order and the PDF are metered.

More judgments on Section 69A

All 15,297 judgments and leading authorities on Section 69A →

Recent GST High Court judgments

Search GST case law →