SHREE NARSINHA NAGARI SAHAKARI PATSANSTHA,PUNE vs. ITO, WARD10(1), PUNE, PUNE

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ITA 386/PUN/2025Status: DisposedITAT Pune26 June 2025AY 2018-19Bench: SHRI MANISH BORAD (Accountant Member), SHRI VINAY BHAMORE (Judicial Member)3 pages

In favour of the assessee: the assessee's appeal was allowed. From the AI summary of this appeal.

AI SummaryAllowed

What did the Tribunal hold?

The Tribunal noted that the CIT(A)/NFAC had dismissed the appeals for ITA Nos. 177-178/PUN/2025 and ITA Nos. 386-387/PUN/2025 in limine for not condoning the delay. For ITA No. 388/PUN/2025, the appeal was dismissed on non-appearance. The Tribunal, considering the submissions and case laws, condoned the delay in filing the appeals and restored the matters to the CIT(A)/NFAC for adjudication on merits.

What were the facts?

The assessee, a cooperative credit society, had its cases selected for scrutiny for AY 2018-19 and AY 2020-21, with assessment orders passed under Section 144. Issues included disallowance of deduction claimed under Section 80P, addition of members' deposits as unexplained cash credit, and disallowance of expenses. The assessee filed appeals against the orders of the CIT(A)/NFAC, but faced dismissal due to delays in filing.

What were the issues?

Whether the delay in filing the appeals before the CIT(A)/NFAC should be condoned, and if so, whether the matters should be remanded for adjudication on merits.

Which sections of the Income-tax Act were involved?

Section 80P,Section 144,Section 270A,Section 271AAC(1),Section 250(6)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, PUNE BENCH “A”, PUNE

Before: SHRI MANISH BORAD & SHRI VINAY BHAMORE

For Appellant: Shri Abhay Avchat
For Respondent: Shri Amol Khairnar &, Shri Ramnath P. Murkunde
Hearing: 26.06.2025Pronounced: 26.06.2025

PER BENCH : By way of above captioned appeals, the assessee’s appeal in ITA Nos.177 – 178/PUN/2025 for A.Ys. 2018-19 and 2020-21 are directed against the order of Ld. CIT(A)/NFAC dated 30.07.2024 and for remaining assessee’s appeals relating to penalty levied u/s 270A for A.Ys. 2018-19 and 2020-21 and u/s 271AAC(1) for A.Y. 2020-21 are directed against the order of Ld. CIT(A)/NFAC dated 13.01.2025 and 07.01.2025 respectively.

2.

Since all the above captioned appeals relates to the same assessee of which ITA Nos.177 – 178/PUN/2025 are the quantum appeals and remaining three are penalty appeals, all the appeals were heard together and are being disposed of by this consolidated order for the sake of convenience and brevity.

3.

At the outset, Ld. Counsel for the assessee referring to the following written submissions has mainly contended that Ld. CIT(A)/NFAC has either not condoned the delay or has not passed the orders on merits of the case and, therefore, prayer is made for restoring the issues raised in all the instant appeals relating to the quantum/penalty to the file of Ld. CIT(A)/NFAC for necessary adjudication :- “SHREE NARSINHA NAGARI SAHAKARI PATSANSTHA NARSINH BUILDING, A/P RANJANI, TAL. AMBEGAON, AMBEGAON, DIST. PUNE - 410504, Maharashtra June 25, 2025 The

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