“Section 119(2)”

Section References (mined)Section 119Section 119(2)554 judgments

The decision most relied on for Section 119(2) is Commissioner of Customs v. Indian Oil Corporation Ltd. (267 ITR 272), cited in 501 judgments on BharatTax.

Leading authorities on Section 119(2)

Commissioner of Customs v. Indian Oil Corporation Ltd.

267 ITR 272 · 2004 · Supreme Court

501

citing judgments

CBDT and CBEC circulars, along with administrative instructions, are binding on departmental authorities, who must not act in contravention of them. However, these circulars and instructions are not binding on courts or assessees.

UCO Bank v. CIT

237 ITR 889 · 1999 · Supreme Court

486

citing judgments

CBDT circulars and instructions, while not binding on courts or assessees, are strictly binding on income-tax departmental authorities, who cannot act in contravention of them.

Gajanan Constructions v. DCIT

74 Taxmann.com 6 · 2016 · ITAT

465

citing judgments

Late fees under section 234E can only be levied prospectively from June 1, 2015. Levying late fees for periods prior to this date is not permissible.

CIT v. G.M. Knitting Industries (P.) Ltd.

376 ITR 456 · 2015 · Supreme Court

221

citing judgments

The requirement to file a certificate or form (e.g., Form 10CCB, 10-IC) along with the return of income for claiming a deduction (e.g., under sections 80-IB, 115BAA) is directory regarding its timing. Such a deduction is allowable if the requisite form is filed before the final order of assessment, as procedural requirements should not override substantive benefits.

CIT v. Gujarat Oil & Allied Industries

201 ITR 325 · 1993 · High Court

195

citing judgments

The requirement to file an audit report along with the income tax return, as specified in provisions like Section 80J(6A) or 80-IA(7), is directory and not mandatory. Substantial compliance is achieved if the audit report is submitted at any time before the assessment is framed or completed, and benefits should not be denied merely due to a delay in furnishing it.

PCIT v. Wipro Ltd.

140 Taxmann.com 223 · 2022 · Supreme Court

192

citing judgments

Exemption provisions under Chapter III, such as Section 10B(8), must be interpreted strictly, and any claim for such exemptions must be made in the return of income. The principles governing Chapter III (incomes not forming part of total income) differ from those for Chapter VIA (deductions in computing total income).

Setty & Others vs. State of Karnataka (7) (1996) 1 SCC 345- Secretary Government of Madras v. P.R. Sriramulu

4 SCC 720 · 2008 · Reported

145

citing judgments

The validity of Section 234E of the Income Tax Act, 1961, inserted by the Finance Act, 2012, is examined by the court.

CIT v. Contimeters Electricals (P.) Ltd.

317 ITR 249 · 2009 · High Court

140

citing judgments

The requirement to file an audit report along with the return of income under section 80-IA(7) and similar provisions is directory, not mandatory. Such a report suffices if filed at any time before the assessment is framed.

Judgments citing Section 119(2)

Income Tax Officer, Mumbai vs. P K Krishnan Educational Trust, Mumbai

In the result, appeal filed by the learned assessing officer is dismissed

ITA 3533/MUM/2023[2021-22]Status: DisposedITAT Mumbai07 May 2024AY 2021-22

Bench: Shri Prashant Maharishi, Am & Shri Raj Kumar Chauhan, Jm Income Tax Officer P K Krishnan Educational Trust 6Th Floor, Mtnl Building Shree Siddhi Vinayak Engl. Vs. Cumballa Hill, Pedder Road, High School, Hariyali Village Mumbai-400 026 Vikhroli (E), Mumbai-400 083 (Appellant) (Respondent) Pan No. Aaatp5026F

For Appellant: Shri Mandar Joshi, ARFor Respondent: Shri H.M. Bhatt, DR

Section 11Section 119(2)(b)Section 12ASection 139Section 139(1)Section 143(1)Section 154Section 44A

remedy to deal with such instances lies with CIT(E) as specified in CBDT Circular No. 02/2020 dt. 03.01.2020 under the provision section 119(2)(b) of the Act?” The assessee is a educational trust registered under Section 12A of 03. the Act, who filed its return of income

Gender Lab Foundation, Thane vs. Commissioner of Income Tax (Exemption), Pune

In the result, appeal of the assessee is allowed for statistical purpose

ITA 193/PUN/2024[-]Status: DisposedITAT Pune30 Apr 2024

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita No.193/Pun/2024 िनधा"रण वष" / Assessment Year :- Gender Lab Foundation, The Commissioner Of Flat No.2203-4, A Wing, Vs Income Tax, Tribeca Building, Hiranandani Exemption, Pune. Estate, G B Road, Chitalsar Manpada, B.O., Thane. Maharashtra – 400607. Pan: Aajcg4122B Appellant/ Assessee Respondent /Revenue Assessee By None. Revenue By Shri Keyur Patel – Cit(Dr) Date Of Hearing 29/04/2024 Date Of Pronouncement 30/04/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is Assessee’S Appeal Against The Order Of Ld.Commissioner Of Income Tax(Exemption), Pune Under Section 80G Of The Act, Dated 15.12.2023. The Ld.Cit(E) Dismissed The Application Of The Assessee On The Ground That The Application Is Time Barred. The Assessee Has Raised The Following Ground(S) Of Appeal : “1. The Cit E, Failed To Appreciate That The Appellant, Gender Lab Gender Lab Foundation [A]

Section 119(2)(b)Section 12ASection 80GSection 80G(5)

consider the appellant's application for registration under 80G afresh. j. The appellant further prays that the delay in filing Form 10AB under section 119(2)(b) of the Income Tax Act, 1961 be condoned and the application for final registration under section 80G be considered on merits ... applicant has made an application under section 119(2)(b) to the CBDT pointing out the facts of the case and asking for both a condonation and / or clarification that Circular 6/2023 also be extended to cover Section 80G 9. The appellant craves leave to add, to amend, delete and/or

Suja International, South Delhi vs. DCIT Circle 54(1), New Delhi

The appeal of the assessee is allowed for statistical purposes

ITA 670/DEL/2023[2012-13]Status: DisposedITAT Delhi26 Apr 2024AY 2012-13

Bench: BEFORESHRI VIKAS AWASTHY (Judicial Member), SHRI AVDHESH KUMAR MISHRA (Accountant Member)

Section 119Section 119(2)(b)Section 143(1)Section 154Section 194J

facts of the case and by resorting to the provision of Section 119 of the Act if the appellant-assessee files application u/s Section 119(2)(b) of the Act to get address its grievance as per the law. 7. In view of the above, the appeal of the assessee

Sunpack Barrier Films Private Limited, Ahmedabad vs. The ADIT, CPC, Bangaluru Present Juridiction the Dy.CIT, Circle-4(1)(1), Ahmedabad

In the result, the appeal of the assessee is allowed

ITA 593/AHD/2023[2021-22]Status: DisposedITAT Ahmedabad24 Apr 2024AY 2021-22

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Shri Pritesh Shah, A.RFor Respondent: Shri Sushil Kumar Katiar, Sr. DR

Section 115Section 115BSection 143(1)

ASSESSMENT YEAR 2022-22 CIRCULAR NO. 19/2023 [ F.NO. 173/32/2022-ITA-I], DATED 23-10-2023 In exercise of the powers conferred under section 119(2)(b) of the Income-tax Act, 1961 ('the Act'), the Central Board of Direct Taxes ('CBDT') by Circular No. 6/2022 of even number dated 17.03.2022 condoned ... genuine hardship to the domestic companies in exercising the option u/s 115BAA of the Act, CBDT in exercise of the powers conferred under section 119(2)(b) of the Act, hereby directs that: - The delay in filing of Form No. 10-IC as per Rule 21AE of the Rules

Shri R V Shah Charitable Trust, Bhavnagar vs. The Dy.DIT, CPC, Bengaluru Current Jurisdiction the ITO, Exemp., Bhavnagar

In the result, the appeal filed by the assessee is partly allowed

ITA 257/AHD/2024[2022-23]Status: DisposedITAT Ahmedabad19 Apr 2024AY 2022-23

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinhaassessment Year : 2022-23 Shri R V Shah Charitable Trust The Dy. Director Of Income C/O. Madhu Silica Pvt.Ltd. Vs Tax, Cpc 147, Gidc, Vartej Bengaluru Bhavnagar 364 060 (Current Jao : Ito (Exempt), Gujarat Bhavnagar Pan: Aaets 0593 C अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri Tushar Hemani, Sr. Adv. & Shri Parimalsinh B. Parmar, Ar Revenue By : Shri C. S. Sharma, Sr.Dr सुनवाई क" तारीख/Date Of Hearing : 17/04/2024 घोषणा क" तारीख /Date Of Pronouncement: 19/04/2024 आदेश/O R D E R Per Narendra Prasad Sinha: The Present Appeal Is Filed By The Assessee Against The Order U/S.250 Of The Income Tax Act, 1961 (Hereinafter Referred To As “The Act”) Dated 19/01/2024 Passed By The Addl./Joint Commissioner Of Income-Tax (Appeals)-8, Mumbai [“Jcit(A)” In Short] For Assessment Year (Ay) 2022-23. 2. The Assessee Is A Charitable Trust & Filed Its Return Of Income For Ay 2022-23 On 17/10/2022 Declaring Total Income Of Rs.1,48,175/-. The Said Return Was Processed By Cpc Bengaluru U/S.143(1) Of The Act On 03/03/2023 & Income Was Determined At Rs.13,64,912/-. This Was Due To Denial Of Exemption U/S.10(23C) Of The Act By The Cpc. The Assessee Had Filed An

For Appellant: Shri Tushar Hemani, Sr. Adv. &For Respondent: Shri C. S. Sharma, Sr.DR

Section 10Section 10(23)(iv)Section 11Section 11(1)Section 143(1)Section 143(1)(a)Section 234BSection 246ASection 250

Income, the only remedy available lies in the machinery provisions of the Act rather seeking legal remedy. Such provisions are found in section 119(2)(b) which enables an assessee to approach the Board for seeking relief in such cases. The provisions of section 119(2)(b) are reproduced below

Adani Kindergarten Education Foundation, Ahmedabad vs. The CIT(Exemptions), Ahmedabad

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 860/AHD/2023[NA]Status: DisposedITAT Ahmedabad17 Apr 2024

Bench: Smt. Annapurna Gupta& Shri Siddhartha Nautiyal

For Appellant: Shri Bandish Soparkar & Shri Parin ShahFor Respondent: Fr. Darsi Suman Ratnam, CIT D.R

Section 80Section 80G

before 30.09.2022, which it had failed to submit. The applicant has also not filed any request before appropriate authority for delay condonation under Section 119(2)(b) of I.T. Act, 1961. Therefore, the as per the CIT(E), the application in Form No. 10AB under Section

Adani Education Foundation, Ahmedabad vs. The CIT(Exemptions), Ahmedabad

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 859/AHD/2023[NA]Status: DisposedITAT Ahmedabad17 Apr 2024

Bench: Smt. Annapurna Gupta& Shri Siddhartha Nautiyal

For Appellant: Shri Bandish Soparkar & Shri Parin ShahFor Respondent: Fr. Darsi Suman Ratnam, CIT D.R

Section 80Section 80G

No 779 Veeraganur Primary Agricultural Co- Operative Credit Society, Salem vs. ITO, Ward-1(6), Salem

In the result, the appeal filed by the assessee in ITA 269/CHNY/2024 for assessment year 2021-2022 is allowed for statistical purposes

ITA 269/CHNY/2024[2021-22]Status: DisposedITAT Chennai17 Apr 2024AY 2021-22

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm आयकरअपील सं./ Ita No.269/Chny/2024 (िनधा"रणवष" / Assessment Year: 2021-22) No.779 Veeraraganur Primary Vs. The Income Tax Officer, Agricultural Co-Operative Credit Ward 1(6), Society, Salem. Veeragannur Post, Gangavalli, Attur Taluk, Salem. [Pan: Aaaan 3985A] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Shri. S. Sridhar, Advocate ""यथ" क" ओर से /Respondent By : Shri. P. Sajit Kumar, Irs, Jcit. सुनवाई क" तार"ख/Date Of Hearing : 17.04.2024 घोषणा क" तार"ख /Date Of Pronouncement : 17.04.2024 आदेश / O R D E R Manu Kumar Giri ()

For Appellant: Shri. S. Sridhar, AdvocateFor Respondent: Shri. P. Sajit Kumar, IRS, JCIT

Section 119(2)Section 119(2)(b)Section 143(1)Section 80PSection 80P(2)(c)Section 80P(2)(d)

Income by Intimation under Section 143(1) of the Act without waiting for the outcome of the Delay Condonation Petition filed under Section 119(2)(b) before the CBDT, despite mentioning it in the Impugned Order’’. 3. Brief facts of the case are that the Assessee filed its return ... raised by the assessee. On being aggrieved, the assessee is in appeal before the Tribunal. 5. By filing copy of the application under section 119(2) of the Act, the ld. Counsel for the assessee has submitted that the assessee has filed a condonation petition before the CBDT under section

Golden Charitable Trust, Sangli vs. Commissioner of Income Tax, Exemption Pune, Pune

In the result, appeal of the assessee is dismissed

ITA 933/PUN/2023[-]Status: DisposedITAT Pune12 Apr 2024

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita No.933/Pun/2023 िनधा"रण वष" / Assessment Year :- Golden Charitable Trust, The Cit Exemption, 2349, Guruwar Peth, Miraj, V Pune. Maharashtra – 416410. S Pan: Aactg0998H Appellant/ Assessee Respondent /Revenue Assessee By Shri Kishor B Phadke – Ar Revenue By Shri Keyur Patel – Cit(Dr) Date Of Hearing 24/01/2024 Date Of Pronouncement 12/04/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax(Exemption), Pune Under Section 12Ab Of The Income Tax Act, 1961, Passed On 30.06.2023.The Assessee Has Raised The Following Grounds Of Appeal : “1. Learned Cit (Exemption) Has Erred In Fact & In Law In Rejecting The Application For The Registration Of The Trust U/S. 12A(1) (Ac) Despite The Fact That Appellant Trust Is Engaged In Pursuing Purely Charitable Objects Such As Providing Medical & Educational Aid To Needy Beneficiaries & The Trust Activities Are Genuine & There Is No Contrary Finding To It. Thus The Rejection Order Is Patently Illegal & Golden Charitable Trust [A]

Section 119(2)(b)Section 12Section 12ASection 12A(1)Section 80G

ground that, application is delayed by only two days and such delay could have been condoned by CIT ( exemption) asper provisions of section 119(2)(b). 5. Learned CIT (Exemption) has erred in fact in law in passing rejection order for Registration u/s. 12(A) (1) (ac) despite the fact

Deputy Commissioner of Income Tax, Chennai vs. Kandiah Muthukrishnan, Chennai

ITA 1113/CHNY/2023[2020-21]Status: DisposedITAT Chennai03 Apr 2024AY 2020-21

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manomohan Das

For Appellant: Shri P. Sajit Kumar (JCIT) – Ld. Sr. DRFor Respondent: Shri P.M. Kathir (Advocate) and Ms. S

Section 143(3)Section 69A

आयकर अपीलीय अिधकरण ‘सी’ "ायपीठ चे"ई म"। IN THE INCOME TAX APPELLATE TRIBUNAL ‘C’ BENCH, CHENNAI माननीय +ी मनोज कुमार

Rajasthan Medical Relief Society, Administrative Block vs. ITO Exemption Ward, Cr Building

In the result, the appeal of the assessee is allowed

ITA 740/JPR/2023[2018-2019]Status: DisposedITAT Jaipur01 Apr 2024AY 2018-2019

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Sh. Sudhir Sogani (Adv.)For Respondent: Sh. Ajay Malik (CIT)

Section 11Section 12Section 12ASection 12A(1)(b)Section 143(1)Section 154

subsequent Assessment Years, the CBDT Circular No.16 of 2022 authorizes Pr.CCIT/CCIT to admit application of condonation of delay under section 119(2) of the Act and decide the same on merits. Similar powers in respect of delay upto 365 days was given to the CIT (Exemption) vide CBDT Circular ... subsequent Assessment Years, the CBDT Circular No. 16 of 2022 authorizes Pr.CCIT/CCIT to admit application for condonation of delay under section 119(2) of the Act and decide the same on merits. Similar powers in respect of delay upto 365 days was given to the CIT (Exemption) vide CBDT

M/S. Masterkey Holdings Private Limited, Bangalore vs. Deputy Commissioner of Income Tax, Circle-4(1)(1), Bangalore

In the result, appeals filed by the assessee are allowed for statistical purposes

ITA 88/BANG/2024[2021-22]Status: DisposedITAT Bangalore27 Mar 2024AY 2021-22

Bench: Shri George George K & Shri Laxmi Prasad Sahu

For Appellant: Shri. Sudheendra B. R, AdvocateFor Respondent: Shri. Stalin B, JCIT (DRs)(ITAT), Bengaluru

Section 115BSection 119(2)(b)Section 139(1)Section 143(1)Section 250

held that he does not have the power to condone the delay in filing Form 10-IC((iii) under section 119(2)(b) of the Act. 5. Aggrieved by the Orders of the CIT(A), assessee has filed the present appeals before the Tribunal. The learned AR submitted by placing ... whichever is later. 8. It is submitted by the learned AR that for Assessment Year 2020-21, assessee had filed an application under section 119(2)(b) of the Act for condoning the delay in filing (non-filing) of Form 10-IC and same is pending consideration before the CBDT

M/S. Masterkey Holdings Private Limited, Bangalore vs. Deputy Commissioner of Income Tax, Circle-4(1)(1), Bangalore

In the result, appeals filed by the assessee are allowed for statistical purposes

ITA 87/BANG/2024[2020-21]Status: DisposedITAT Bangalore27 Mar 2024AY 2020-21

Bench: Shri George George K & Shri Laxmi Prasad Sahu

For Appellant: Shri. Sudheendra B. R, AdvocateFor Respondent: Shri. Stalin B, JCIT (DRs)(ITAT), Bengaluru

Section 115BSection 119(2)(b)Section 139(1)Section 143(1)Section 250

Loyola High School, Kolkata vs. ITO (Exemption), Ward - 1(4), Kolkata

In the result, the appeal of the assessee is allowed

ITA 472/KOL/2022[2016-2017]Status: DisposedITAT Kolkata20 Mar 2024AY 2016-2017

Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Rajesh Kumar

Section 249Section 253Section 3Section 5

condoned by the authorities and benefit of accumulation is to be granted. 13. On the other hand, ld. D.R. submitted that as per Section 119(2)(b), the assessee ought to have approached ld. Commissioner for condonation of delay in filing the return and thereafter benefit of section 11(2 ... earlier Circulars issued in this regard, with the view in prevent hardship to the assessee and in exercise of powers conferred under section 119(2)(b) of the Act, the CBDI has decided that where the application for condonation of delay in filing form 9A and Form 10 has been

Shri Gangaparameshwari Uraban Co Op Credit Society Ltd Mudalgi, Mudalgi vs. Income-Tax Officer, Ward-1, Gokak

In the result, appeal filed by the assessee is allowed for statistical purposes

ITA 267/BANG/2024[201819]Status: DisposedITAT Bangalore15 Mar 2024

Bench: Shri George George K, Vice- & Shri Laxmi Prasad Sahu

For Appellant: Sri.Sateesh Nadagouda, CAFor Respondent: Sri.Ganesh R.Gale, Standing Counsel

Section 119(2)(b)Section 139(1)Section 143(3)Section 250Section 80ASection 80PSection 80P(2)(a)

which was introduced w.e.f. 01.04.2018), assessee cannot be allowed deduction under section 80P of the Act. However, assessee has filed application under section 119(2)(b) of the Act for condonation of delay in filing the return of income and the same is pending consideration by the PCIT. In this ... which was introduced w.e.f. 01.04.2018), assessee cannot be allowed deduction under section 80P of the Act. However, assessee has filed application under section 119(2)(b) of the Act before the CCIT, Bangalore, for condonation of delay in filing the return of income. In this context, learned AR had relied

Shree Channamaleshwara Credit C-Operative Society Ltd., Kalaburagi vs. Income-Tax Officer, Ward-1 & Tps, Gulbarga

In the result, appeal filed by the assessee is allowed for statistical purposes

ITA 203/BANG/2024[2018-19]Status: DisposedITAT Bangalore15 Mar 2024AY 2018-19

Bench: Shri George George K, Vice- & Shri Laxmi Prasad Sahu

For Appellant: Ms.Lakshmi, AdvocateFor Respondent: Sri.Ganesh R.Gale, Standing Counsel

Section 119(2)(b)Section 139(1)Section 139(4)Section 143(3)Section 250Section 80ASection 80P

which was introduced w.e.f. 01.04.2018), assessee cannot be allowed deduction under section 80P of the Act. However, assessee has filed application under section 119(2)(b) of the Act for condonation of delay in filing the return of income and the same is pending consideration by the relevant authority ... which was introduced w.e.f. 01.04.2018), assessee cannot be allowed deduction under section 80P of the Act. However, assessee has filed application under section 119(2)(b) of the Act before the CCIT, Bangalore, for condonation of delay in filing the return of income. In this context, learned AR had relied

DCIT, Circle-7(1), Delhi vs. Eicher Motors Limited, Delhi

ITA 3721/DEL/2023[2015-16]Status: DisposedITAT Delhi15 Mar 2024AY 2015-16

Bench: Shri Kul Bharat & Dr. B.R.R. Kumarassessment Year: 2015-16

Section 35

considered by assessing officer ('AO')/CIT(A) and that the appellant ought to have taken recourse of the specific remedy available under section 119(2)(b) of the Act. 03. That the learned CIT(A) grossly erred on facts and in law in holding that the AO was right ... judicial precedents relied upon by the appellant holding the same to be "per- incuriam" having been passed without considering the provisions under section 119(2)(b) of the Act. 06. That the CIT(A) grossly erred on facts and in law in not allowing deduction of ESOP expenditure, even though

Eicher Motors Limited, New Delhi vs. DCIT Circle 7(1) New Delhi, New Delhi

ITA 3525/DEL/2023[2015-16]Status: DisposedITAT Delhi15 Mar 2024AY 2015-16

Bench: Shri Kul Bharat & Dr. B.R.R. Kumarassessment Year: 2015-16

Section 35

Pasumpon Thevar Educational Charitable Trust, Thoothukudi, Chennai vs. ITO, Exemption Ward Tirunelveli, Tirunelveli

The appeal stand allowed for statistical purposes

ITA 1543/CHNY/2023[2021-22]Status: DisposedITAT Chennai12 Mar 2024AY 2021-22

Bench: Hon’Ble Shri Mahavir Singh, Vp & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपीलसं./ Ita No.1543/Chny/2023 (िनधा*रणवष* / Assessment Year: 2021-22) Pasumpon Thevar Educational Ito Charitable Trust Exemption Ward, बनाम/ Vs. 22, Sethu Palace, Kovilpatti Tirunelveli Thoothukudi Dist -628 502. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aactp-7987-R (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ" कीओरसे/ Appellant By : Shri N. Arjun Raj (Ca) For Shri S. Sridhar (Advocate)- Ld. Ars " थ"कीओरसे/Respondent By : Shri D. Hema Bhupal (Jcit)-Ld. Sr. Dr सुनवाई की तारीख/Date Of Hearing : 12-03-2024 घोषणा की तारीख /Date Of Pronouncement : 12-03-2024 आदेश / O R D E R

For Appellant: Shri N. Arjun Raj (CA) for Shri S. SridharFor Respondent: Shri D. Hema Bhupal (JCIT)-Ld. Sr. DR

Section 11Section 119(2)Section 12ASection 139(1)Section 143(1)

आयकर अपीलीय अिधकरण “बी” "ायपीठ चे"ई म"। IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH, CHENNAI माननीय "ी महावीर िसंह

Sri Praja Co-Operative Credit Society Limited, Bangalore vs. Income-Tax Officer, Ward-2(2)(1), Bangalore

In the result, appeal filed by the assessee is allowed for statistical purposes

ITA 28/BANG/2024[2020-21]Status: DisposedITAT Bangalore06 Mar 2024AY 2020-21

Bench: Shri George George K & Shri Laxmi Prasad Sahuassessment Year : 2020-21 M/S. Sri Praja Co-Operative Credit Society Ltd., Vs. Ito, No.1, 3Rd Main Road, Nagappa Block, Ward – 2(2)(1), Sriramapura, Bengaluru. Bengaluru – 560 021. Pan : Aaajs 1557 Q Appellant Respondent Assessee By : Shri. Srinivas Bharath, Ca Revenue By : Shri. Subramanian S, Addl. Cit(Dr)(Itat), Bengaluru. Date Of Hearing : 06.03.2024 Date Of Pronouncement : 06.03.2024

For Appellant: Shri. Srinivas Bharath, CAFor Respondent: Shri. Subramanian S, Addl. CIT(DR)(ITAT), Bengaluru

Section 119(2)(b)Section 139(1)Section 139(4)Section 143(3)Section 250Section 80ASection 80PSection 80P(2)(a)Section 80P(2)(d)

which was introduced w.e.f. 01.04.2018), assessee cannot be allowed deduction under section 80P of the Act. However, assessee has filed application under section 119(2)(b) of the Act for condonation of delay in filing the return of income and the same is pending consideration by the CBDT. In this ... which was introduced w.e.f. 01.04.2018), assessee cannot be allowed deduction under section 80P of the Act. However, assessee has filed application under section 119(2)(b) of the Act before the CCIT, Bangalore, for condonation of delay in filing the return of income. In this context, learned AR had relied