SHREE JALARAM COOP. CREDIT SOCIETY LTD,VIRAMGAM vs. THE ITO, WARD-3(2)(1), AHMEDABAD

ITA 1951/AHD/2025Status: DisposedITAT Ahmedabad06 January 2026AY 2019-20Bench: Ms. Suchitra Kamble (Judicial Member)4 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal ruled that the assessee was entitled to the Section 80P deduction for interest from fixed deposits with a co-operative bank. It further held that the adjustment under Section 143(1)(a)(v) for non-filing of ITR within the due date, being effective from April 1, 2021, was not applicable to Assessment Year 2019-20, rendering the CPC's disallowance illegal and without jurisdiction for this period.

What were the facts?

The assessee, a credit society, filed its income tax return for AY 2019-20 claiming a nil income after deducting Rs. 20,05,865/- under Section 80P. The CPC Bengaluru processed the return under Section 143(1), disallowing the deduction. This disallowance was upheld by a rectification order under Section 154 and subsequently by the CIT(A), leading to the present appeal.

What were the issues?

1. Whether the disallowance of deduction under Section 80P through an intimation under Section 143(1) was valid for Assessment Year 2019-20. 2. Whether the provisions of Section 143(1)(a)(v) regarding disallowance due to non-filing of ITR within the due date applied to Assessment Year 2019-20, considering its effective date.

Which sections of the Income-tax Act were involved?

Section 80P,Section 143(1),Section 154,Section 143(1)(a)(v),Section 139(1),Section 80P(2)(a)(i)

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Income Tax Appellate Tribunal, AHMEDABAD “SMC” BENCH

Before: Ms. Suchitra Kamble

For Appellant: Shri S.N. Divetia, Shri Samir Vora, A.Rs
For Respondent: Shri Suresh Chand Meena, Sr. D.R

This is an appeal filed against the order dated 29-09- 2025 passed by ADDL/JCIT(A)-3, Chennai for assessment year 2012-13. 2. The grounds of appeal are as under:- “1.1 The order u/s. 250 passed on 29.09.2025 by Addl./JCIT(A)-

3.

Chennai [For short CIT(A)] upholding the prima facie adjustment by way of disallowance u/s 80P aggregating to Rs. 20,05,865/ made in order passed u/s 143(1) on 23.09.2020 by CPC Bengaluru is wholly illegal, unlawful and against the principles of natural justice.

1.

2 The Ld.CIT(A) has erred in law and on facts in not appreciating that the prima facie adjustment by way of disallowance u/s 80P aggregating to Rs. 20,05,865/- made in order passed u/s 143(1) on 23.09.2020 b

The order continues below.

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