THE SINNIYAMPALAYAM PRIMARY AGRICULTURAL CO-OPERATIVE CREDIT SOCIETY LIMITED,ERODE vs. ITO, WARD-2(1), ERODE, ERODE

Aforesaid appeal by assessee for Assessment Year (AY) 2020-21 arises out of the order of learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi [CIT(A)] dated 30-11-2023 in the matter of an assessment framed by Ld. Assessing Officer [AO] u/s. 143(3) r.w.s. 144B of the Act on 20-09-2022. Upon perusal of assessment order, it could be seen that the assessee failed to file any reply to the queries as raised by Ld. AO on the issue of deduction u/s 80P(2)(a)(i) & 80P(2)(a)(iv). Accordingly, the deduction was denied. The assessee claimed interest expenditure which also remained unexplained and accordingly, the same was also disallowed. The position remained substantially the same during first appellate proceedings. Accordingly, the assessment was confirmed against which the assessee is in further appeal before us.

The Ld. AR has submitted that the assessee does not have any non-members and it is entitled for impugned deduction. The Ld. AR also furnished documents in support of interest expenditure. The Ld. CIT-DR submitted that the same would require verification by lower authorities. 3. Considering the facts of the case, we deem it fit to grant another opportunity of hearing to the assessee. Accordingly, the aforesaid two issues stand restored back to the file of Ld. AO for de novo assessment. The assessee is directed to substantiate its case forthwith without seeking unnecessary adjournments. 4. The appeal stand allowed for statistical purposes. Order pronounced in open court on 17th April, 2024.