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Income Tax Appellate Tribunal, COCHIN BENCH, COCHIN
Before: Shri Satbeer Singh Godara & Shri Amarjit Singh
O R D E R Per Bench These assessee’s twin appeals & 162/Coch/2024 arise against orders of the CIT(A)-3, Bengaluru in proceedings u/s. 250 of the Income Tax Act, 1961 (the Act) as under : - DIN & Order No. Date No. 1 161/Coch/2024 2014-15 ITBA/APL/S/250/2023- 11.01.2024 24/1059626120(1) 2 162/Coch/2024 2015-16 ITBA/APL/S/250/2023- 11.01.2024 24/1059626278(1)
Heard both the parties at length. Case files perused.
We note at the outset that the sole substantive clinching issue herein is regarding correctness of both the lower authorities action disallowing the assessee’s & 162/Coch/2024 Chandranagar Co-operative House Building Society Ltd. section 80P deduction(s) of Rs.5,69,051/- and Rs.10,00,793/- in section 143(1)(a)(v) “processing” dated 03.06.2015 and 30.06.2016; assessment year-wise; respectively.
We next note that both the learned lower authorities could not have disallowed assessee’s sec.80P deduction claim in sec.143(1)(a)(v) “processing” once the corresponding amendment to this effect therein; by the Finance Act 2021, w.e.f. 01.04.2021, carries prospective effect only whereas we are in assessment years 2014- 15 and 2015-16. The assessee succeeds in it’s instant twin appeals. Ordered accordingly.