STATE BANK OF INDIA OFFICERS COOPERATIVE THRIFT AND CREDIT SOCIETY LIMITED,CHENNAI vs. THE INCOME TAX OFFICER, NON-CORPORATE WARD - 12(1), CHENNAI

ITA 4474/CHNY/2026Status: DisposedITAT Chennai16 October 2026AY 2022-234 pages

AI SummaryRemanded

What did the Tribunal hold?

The provided text is an excerpt and does not contain the Tribunal's decision or reasoning. It only sets out the parties, assessment years, the authorities involved, and the dates of hearing and pronouncement. Therefore, what the Tribunal decided, the reasoning, the ratio, and the operative directions are not recorded in this portion of the judgment. No issue was expressly left undecided as the substantive part of the judgment is missing.

What were the facts?

The assessee, M/s. State Bank of India Officers Cooperative Thrift and Credit Society Ltd., filed appeals against two orders dated 29.07.2026 passed by the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi. These orders were passed under section 250 of the Income Tax Act, 1961. The appeals pertain to Assessment Years 2021-22 and 2022-23. The assessee is a cooperative society registered with the relevant authorities. The appeals were heard on 14.10.2026 and pronounced on 16.10.2026. The dispute involves the Income Tax Officer, Non-Corporate Ward 12(1), Chennai, as the respondent.

What were the issues?

1. Whether the Commissioner of Income Tax (Appeals) erred in upholding the action of the Assessing Officer regarding the disputed issue (the specific nature of the dispute is not detailed in the provided text)? Assessee's Contention: The assessee, represented by Shri R. Joseph Richard, Advocate, is in appeal against the orders of the CIT(A). Specific arguments and reliance on authorities are not recorded in the provided text. Revenue's Contention: The revenue, represented by Shri J. Nagaraj, JCIT, is the respondent. Specific arguments and reliance on authorities are not recorded in the provided text.

Which sections of the Income-tax Act were involved?

Section 250

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, ‘B’ BENCH, CHENNAI

Before: SHRI GEORGE GEORGE K & SHRI GAGAN GOYAL

Hearing: 14.10.2026Pronounced: 16.10.2026

आदेश/ O R D E R PER GEORGE GEORGE K, VICE PRESIDENT: These appeals filed by the assessee are directed against two orders of the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi both dated 29.07.2026, passed under section 250 of the Income Tax Act, 1961 (hereinafter called ‘the Act’). The relevant Assessment Years are 2021-22 & 2022-23.

- 2 - ITA Nos.4473 & 4474/CHNY/2026 SBI Officers Co-Op Thrift and Credit Society Ltd. 2. Brief facts of the case are as follows: The assessee is a co-operative society registered with the Registrar of Co-operative Societies vide Registration No. XC114 dated 09.06.1975, with the objective of promoting thrift among its members, who are employees of the State Bank of India, and providing credit facilities to needy members. For the assessment years 2021-22 and 2022-23, the assessee filed its returns of income belatedly, beyond the due dates prescribed u/s.139(1) of the Act. The AO processed the returns and denied the deduction claimed u/s.80P of the Act on the ground that the returns were not filed within the due dates prescribed u/s.139(1) of the Act.

Aggrieved, assessee filed appeals before the First Appellate Authority (FAA). The FAA partly-allowed the appeals of the assessee for statistical purposes. Since the assessee’s grievance petition before the CBDT seeking condonation of delay in filing the return of income was pending disposal, the FAA directed the AO to allow the claim of deduction, subject to the outcome of the CBDT’s decision.

The Ld. AR submitted that the assessee had filed a petition u/s. 119(2)(b) of the Act before the CCIT, Chennai, seeking condonation of delay, which was rejected on the ground that the matter did not fall within the powers delegated to him under CBDT Circular No. 13/2023

- 3 - ITA Nos.4473 & 4474/CHNY/2026 SBI Officers Co-Op Thrift and Credit Society Ltd. dated 26.07.2023. The CCIT observed that the said Circular covers only those societies required to get their accounts audited under the respective State laws and does not extend to Multi-State Co-operative Societies, such as the assessee, as provided in para 6(ii) of the Circular. Aggrieved by the rejection, the assessee filed a grievance petition before the CBDT, which is pending disposal. The Ld. AR submitted that the outcome of the said petition has a direct bearing on the issue under consideration and, therefore, pleaded that the matter be restored to the file of the AO to await the outcome of the CBDT's decision.

The Ld.DR supported the order of the FAA.

We have heard the rival submissions and perused the material available on record. We notice that the assessee's claim for deduction u/s.80P of the Act was denied on the ground that the returns of income were not filed within the due dates prescribed u/s.139(1) of the Act. The assessee has submitted that its petition seeking condonation of delay u/s.119(2)(b) of the Act was rejected by the CCIT, Chennai, and a grievance petition filed before the CBDT against such rejection is pending disposal. Considering that the outcome of the petition before the CBDT may have a bearing on the assessee's claim, we deem it appropriate to restore the matter to the file of the AO for fresh

- 4 - ITA Nos.4473 & 4474/CHNY/2026 SBI Officers Co-Op Thrift and Credit Society Ltd. examination after taking into consideration the outcome of the grievance petition before the CBDT and in accordance with law, after affording adequate opportunity of being heard to the assessee. The assessee is directed to keep the AO informed of the outcome of the grievance petition and cooperate with the proceedings. Accordingly, the appeals are allowed for statistical purposes.

In the result, the appeals filed by the assessee are allowed for statistical purposes.

Order pronounced in the open court on 16th October,2026 at Chennai.

Sd/- Sd/- (गगन गोयल) (जॉज� जॉज� के) (GAGAN GOYAL) (GEORGE GEORGE K) लेखा सद�य/ACCOUNTANT MEMBER उपा�य� /VICE PRESIDENT चे�नई/Chennai, �दनांक/Dated, the 16th October, 2026 RSR, Sr.PS आदेश क� ��त�ल�प अ�े�षत/Copy to: 1. अपीलाथ�/Appellant 2. ��यथ�/Respondent 3. आयकर आयु�त /CIT, Chennai 4. �वभागीय ��त�न�ध/DR 5. गाड� फाईल/GF. By Order Digitally signed by REKHA REKHA SENTHIL RAJ SENTHIL RAJ Date: 2026.10.22 12:07:01 +05'30'

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