SHARADCHANDRA NAGARI SAHAKARI PATSANSTHA MARYADIT,PUNE vs. ITO WARD -10(1), PUNE

ITA 44/PUN/2026Status: DisposedITAT Pune26 March 2026AY 2022-23Bench: SHRI R. K. PANDA (Vice President), Ms. ASTHA CHANDRA (Judicial Member)12 pages
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What did the Tribunal hold?

The Tribunal restored the appeals to the CIT(A)/NFAC, directing them to condone the delay and decide the matters on merit, citing Supreme Court judgments on substantial justice. The Tribunal also partly deleted the penalty under Section 270A based on a prior ITAT decision allowing a significant portion of the Section 80P deduction.

What were the facts?

The assessee society's appeals were dismissed by the CIT(A)/NFAC due to a delay in filing. The assessee claimed the delay was due to the assessment order being sent to an old email address. The assessee also contested additions and penalties related to the disallowance of deductions under Section 80P.

What were the issues?

Whether the delay in filing the appeal should be condoned and whether the disallowance of deduction under Section 80P and the subsequent penalty under Section 270A were justified.

Which sections of the Income-tax Act were involved?

Section 80P,Section 270A,Section 143(2),Section 142(1),Section 144,Section 144B

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

Before: SHRI R. K. PANDA & Ms. ASTHA CHANDRA

For Appellant: Shri Abhay Avachat
For Respondent: Shri Gaurav K Singh, JCIT

PER BENCH:

ITA No.43/PUN/2026 filed by the assessee is directed against the order dated 08.12.2025 of the Ld. CIT(A) / NFAC, Delhi relating to assessment year 2022-23 confirming the penalty levied by the Assessing Officer u/s 270A of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’). ITA No. 44/PUN/2026 filed by the assessee is directed against the order dated 20.11.2025 of the Ld. CIT(A) / NFAC, Delhi relating to assessment year 2022-23 confirming the addition of Rs.1,25,13,425/- made by the Assessing Officer as ‘Income from other sources’. ITA No.45/PUN/2026 filed by the assessee is directed against the order dated 18.12.2025 of the Ld. CIT

The order continues below.

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